1. Introduction

This Privacy Notice explains what we do with information that we may hold about you (your “personal data”).

It describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your rights.

For the purpose of applicable data protection legislation, the company responsible for your personal data is Lothbury Business Management Ltd, “us” or “we”).

We may amend this Privacy Notice from time to time. Please visit this page if you want to stay up to date as we will post any changes here.

Your privacy is really important to us. If you are dissatisfied with any aspect of this Privacy Notice or our handling of your personal data, please contact us using the details set out in section 9 below.

2. What kind of personal information do we collect?

We will collect personal data that relates to our customers. Normally this is in the form of email addresses, postal addresses or phone numbers. In order to provide you with appropriate communications, we collect and use your personal data.

3. How we use your personal data?

The main reason for us to use your personal data is in order to continue providing our services to you. Occasionally, we may send targeted marketing to you. If you wish not to receive this, please contact us using the ‘Contact us’ section on our website.

4. Who do we share your personal data with?

We do not share your personal data with any third parties for their own purposes and so you will not receive any communications from third parties as a result of giving us your personal data.

We may need to share limited personal data with our service providers who help us to prepare and send you our communications. However, we do not allow these organisations to use your personal data for their own purposes and take care to ensure that they keep your personal data secure and delete it when it is no longer needed.

5. How do we protect your personal data?

We care about protecting your personal data. That’s why we put in place appropriate security measures, including encryption techniques, which are designed to prevent any misuse of the data that you provide to us.

If you suspect any misuse, loss, or unauthorised access to your personal data please let us know immediately using the ‘Contact us’ section on our website. We will investigate the matter and update you as soon as possible on next steps.

6. How long do we keep your personal data for?

We will not keep your personal data for longer than is necessary. That means that we will keep your personal data for the length of time for which we are providing you with services.

However, if you contact us to request your data be removed, we will delete your personal data from our database unless we believe that we are required by law to keep the data (for example, because of a request by a tax authority or in connection with any anticipated litigation).

7. Your rights

The law provides that you have various rights in relation to the personal data that we hold about you. We have described these rights below.

Right to object

This right enables you to object to us processing your personal data where we do so to send you direct marketing materials. If you object, then we will not be able to continue to send you direct marketing communications.

Right to withdraw consent

Where you have consented to us processing your personal data, you may withdraw this consent at any time. If you withdraw your consent then we will not be able to continue to send you marketing or other communications, unless we consider that there is an alternative legal basis to justify our continued processing of your data for this purpose, in which case we will inform you of this condition.

Right of access

You may ask us to confirm what personal data we hold about you at any time, and request us to modify, update or delete such information. If we provide you with access to the personal data, we hold about you, we will not charge you for this unless your request is “manifestly unfounded or excessive”. If you request further copies from us, we may charge you a reasonable administrative cost. Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will always tell you the reasons for doing so.

Right to be forgotten

You have the right to request that we “erase” your personal data in certain circumstances. For example, where you have withdrawn your consent to us processing your personal data, and there is no other valid reason for us to continue processing.

We would only be entitled to refuse to comply with your request in certain limited circumstances. For example, to enable us to exercise or defend a legal claim.

Right to restrict processing

You have the right to request that we restrict our processing of your personal data in certain circumstances. If you exercise this right, we will be able to continue to store your data on our database but we will not be able to do anything else with it until either the issue is resolved, you consent, or further processing is necessary for either the establishment, exercise or defence of legal claims, the protection of the rights of another individual, or reasons of important EU or Member State public interest.

We will, of course, notify you before lifting any restriction on processing your personal data.

Right to rectification

You also have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you.

Right of data portability

If you wish, you have the right to transfer your personal data between organisations. In effect, this means that you are able to transfer the details we hold on you to a third party. To allow you to do so, we will provide you with your data in a commonly used format so that you can transfer the data to a third party of your choice. Alternatively, we may directly transfer the data for you.

Right to lodge a complaint with a supervisory authority

You also have the right to make a complaint to your local supervisory authority which is the Information Commissioner’s Office.

You can contact them in the following ways:

Phone: 0303 123 1113

Email: casework@ico.org.uk

Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF If you would like to exercise any of these rights, please contact us using the details set out in section 8, below. Please note that we may keep a record of your communications to help us resolve any issues which you raise.

8. Cookies and IP addresses

We may obtain information about your computer, which includes your IP address, browser type and operating system where available. This accumulation of data is used to assist system administration.

We may also collect information regarding your browsing activity and interests through use of a cookie file. This cookie file is stored on the hard drive of your computer and contains information that is transferred to your computer’s hard drive. We use the collection of this data to help us improve the experience of users on our website, and to deliver a more personalised service with more relevant content. The collection of this data allows us to:

store data indicative of your preferences, allowing us to adjust our website to appeal to your individual interests;

estimate the size and usage patterns of our audience;

record the details of any transactions carried out by you through our website;

identify you upon your return to our website; and/or

increase the speed of your searches.

9. Contact us

Lothbury Business Management Ltd is responsible for processing your personal data.

If you have any comments or suggestions concerning this Privacy Notice, please contact us using the ‘Contact us’ section on our website. We take privacy seriously and will get back to you as soon as possible.

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