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OTB Eveling LLP

Section A - Privacy Policy (Clients and Business Contacts)

Section B - Website Terms of Use &

                       Privacy Policy for Website Users & Cookie Policy 

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Section A - Privacy Policy (Clients and Business Contacts)

1. Introduction and Privacy Notice

1.1. This Privacy Policy is provided for the benefit of clients and business contacts (“you”) of OTB Eveling LLP ("We "or "us").  Separate privacy policies are applicable to website users, and for our staff, respectively.

1.2. We are committed to protecting and respecting your personal information and privacy. This privacy policy relates to our use of any personal information we collect from you during the course of our business or our dealings with you, for which we are the “Data Controller”.

1.3. We are required to only handle your personal information in line with data protection law; including the General Data Protection Regulation (GDPR) and the Data Protection Act. 

1.4. One such requirement is that we are required to provide you with a “privacy notice”, which is what this Privacy Policy is intended to do. The terms “privacy notice” and “privacy policy” may be used interchangeably within this document.

 

2. Information about us and how to contact us

2.1. OTB Eveling LLP, is a limited liability partnership registered in England and Wales under OC371214 whose registered address is Senate Court, Southernhay Gardens, Exeter EX1 1NT.

2.2. OTB Eveling LLP is authorised and regulated by the Solicitors Regulation Authority under number 566522.

2.3. You can contact us via our Practice Manager using the following details:

For the attention of: The Practice Manager, OTB Eveling LLP, Senate Court, Southernhay Gardens, Exeter EX1 1NT.

Email: clientrelations@otbeveling.com  Telephone: 01392 823811

 

3. Responsibility for data protection

3.1. Responsibility for data protection lies with our Practice Manager.

 

4. Data Protection Principles

4.1. We will comply with data protection law, which means that the personal information we hold about you must be:

  •  Used lawfully, fairly and in a transparent way.
  • Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  • Relevant to the purposes we have told you about and limited only to those purposes.
  • Accurate and kept up to date.
  • Kept only as long as necessary for the purposes we have told you about.
  • Kept securely.

 

5. Entitlement to process Personal Information

5.1. We are entitled to process your personal information if:

  • We have a “justification” for doing so; or
  • We have your consent.

5.2. We do not need your consent in circumstances where we already have a justification for the processing of your personal information. This document sets out the basis upon which we do have justification for processing your personal information.

 

6. Your rights

In addition to your right to be provided with a privacy notice and receive the information provided to you within this document, you have the following rights under the GDPR:

6.1. Right of Access

  • You may request access to your personal information, which we hold or process, by making a “data subject access request”. 
  • Your request should be made in writing to our Practice Manager. 
  • If you request access to a large amount of information, we may ask you to more clearly specify the information to which your request relates.
  • We shall provide you with access to the requested information unless your request is manifestly unfounded or excessive, or if it adversely affects the rights of someone else.

6.2. Right to Correction

  • You may require us to correct any inaccurate personal information, or complete any incomplete personal information, that we hold about you.
  • You should request any such correction in writing to our Practice Manager. 

6.3. Right to Erasure

  • Also known as the right to be forgotten - You have the right to request the erasure of personal information if: a) it is no longer necessary for us to hold it for the purpose it is or was intended; or b) if you withdraw previously given consent; and (in both cases) we do not have any other legal justification for holding that information.
  • You should request any such erasure in writing to our Practice Manager.

6.4. Right to Object 

  • You have the right to object to our processing of your personal information based on legitimate interests; or the performance of a task in the public interest; or for the purposes of statistics.
  • You also have the right to object to the processing of your personal information for direct marketing purposes, if relevant.
  • Your objection must be made on grounds relating to your particular situation.
  • Your objection must be made in writing to our Practice Manager.
  • If these conditions are met, we shall stop processing that personal information, unless we have compelling legitimate grounds for the processing, which justify its continued processing; or unless the processing is necessary for the establishment, exercise or defence of legal claims.

6.5. Right to Restrict Processing

  • You have the right, in some circumstances and subject to exemptions, to restrict the processing by us of your personal data.
  • Where processing has been restricted, we shall only process your personal data (excluding storing them):
  • with your consent;
  • for the establishment, exercise or defence of legal claims;
  • for the protection of the rights of another person; or
  • for reasons of important public interest.
  • Prior to lifting the restriction, we shall inform you of the lifting of the restriction.
  • You should request any such restriction in writing to our Practice Manager.

6.6. Right to Data Portability

  • You have the right, in certain circumstances, to receive your personal data that you have provided to us in a structured, commonly used and machine-readable format that you can then provide to another company.
  • We shall provide you with the requested data unless your request is manifestly unfounded or excessive, or if it adversely affects the rights of someone else.
  • Your request should be made in writing to our Practice Manager. 

6.7. Right not to be subject to Automated Decision Making

  • We do not currently use any automatic decision-making processes.

6.8. Right to make a complaint 

  • If you believe that we have breached your data protection rights, we encourage you to raise a complaint under our Complaints Policy, a copy of which will be made available upon request.
  • If you are still unhappy with our personal information rights practices, you may complain or report a concern to the Information Commissioner’s Office. Details can be found at: https://ico.org.uk/concerns/

 

7. Personal information collected by us

7.1. We process both Personal and Sensitive (Special) categories of data. Personal data we process may include name, address and email address. Due to the nature of our business we also process Sensitive (Special) categories of data, such as health data, racial or ethnical origin and biometric data (passports for identification and verification purposes as required by law).

7.2. We may receive your personal information via the following methods:

  • Through correspondence with you.
  • Through telephone and face to face communications with you.
  • Via Courts, tribunals, regulatory authorities.
  • Via third party referrals, and other parties connected with any matter we are assisting you with.
  • Through engagement of service providers, such as identity checks, and publicly available sources.

7.3. Personal Information we collect and hold may include:

  • Contact details including email address, landline and mobile numbers.
  • Name, address, gender and date of birth.
  • Marital status, dependents and family.
  • Photographic identification documents including drivers licences, passports amongst others.
  • Bank account details, payroll records & tax status information.
  • Payments records, via bank transfer, debit card, cheques or otherwise.
  • Financial records including tax, pensions, income, and other personal financial information.
  • Details of property and assets.
  • Sensitive data – a special category of personal information including amongst others: medical, police and accident records and information containing racial or ethnical origin and/or biometric data eg passport.
  • Any other personal information necessary for regulatory reasons or for the conduct of your matter.

7.4. We only collect the above information because we need it. We do not, therefore, collect all of this information in every case.

7.5. These items of personal information may be collected, held and processed where and to the extent that this is necessary, for the performance of our obligations to you as your legal advisers and pursuant to our contract of services with you. This may also be necessary to enable us to comply with our legal and regulatory obligations for example for the purpose of satisfying Money Laundering requirements.

 

8. How personal information is used 

8.1. We have justification for processing your personal information in the following ways:

  • To carry out our duties relating to any contracts entered into between you and us.
  • To adequately and appropriately advise you in relation to any matter we are assisting you with, or in relation to any matters that we are aware could impact upon you legally or financially.
  • To provide you with information, products or services that you request from us or which we feel may interest you, where you have either consented to be contacted for such purposes or because we have a "legitimate interest" in doing so. 
  • To comply with any legal or regulatory requirement that we are subject to.
  • To carry out necessary maintenance to our IT or accounts systems. 

 

9. Sharing personal information with others

9.1. Subject to the circumstances outlined below, we shall not share your personal information with anyone unless it is required or permitted by law or it is necessary in the course of the matter we are assisting you with (specific to your circumstances), such as communications with the other side in litigation or on a transaction; registration organisations such as Companies House or the Land Registry; Courts, tribunals or regulatory bodies.

9.2. We do use third party service providers (data processors) to supply and support our services to you, with whom some of your personal may be shared.

9.3. The table below lists our regular data processors’ services.

Data Processor Service
Accountants
Accounts and Document Management Software supplier
Cleaning service (Offices)
Data Room provider (if relevant to your matter)
IT Consultants
Secure document waste disposal
Secure IT hardware disposal
Storage Facility

9.4. We have contracts in place with our data processors, requiring them not to do anything with your personal information unless we have instructed them to do so. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct.

 

10. How long we keep Personal Data

10.1. Our Data Retention Periods are set out in the attached schedule at the Appendix to this Privacy Policy.

 

11. Changes

11.1. We keep our privacy notice under regular review and changes may be made to it from time to time. The current version of our privacy notice will be posted on our website so that you are aware of its contents.

 

APPENDIX

Data Retention Periods For Personal Information relating to Clients and Business Contacts

Client Instructions

Document Description Retention Period
Contact details of client for communication purposes (address, telephone, email) For the period that it takes to accept and fulfil instructions to their satisfactory conclusion, and then for a further 2 years unless a longer retention is necessary under one of the categories below
Contact details of non-client business contact (name, address, telephone, email) For the period of our business-related dealings and interactions, and then for a further 2 years
Personal information obtained for the purpose of fulfilling your instructions; appropriately advising you in relation to any matter we are assisting you with, or in relation to any matters that we are aware could impact upon you legally or financially. Including: name, gender and date of birth; Marital status, dependents and family; Financial records including tax, pensions, income, and other personal financial information; Details of property and assets; or any other personal information necessary for the conduct of your matter (including special categories of personal information such as   medical, police and accident records and information containing racial or ethnic origin etc) For the period that it takes to accept and fulfil instructions to their satisfactory conclusion, and then for a further 7 years unless such are required to be kept pursuant to ‘disposal hold’ as referred in this Data Retention Policy
Working files (paper and electronic) which may include advice, correspondence and personal details listed above For the period that it takes to accept and fulfil instructions to their satisfactory conclusion, and then for a further 7 years or such additional period as is required for regulatory or professional indemnity purposes
Details of client billing information For the period that it takes to receive full payment on a matter, and then for a further 7 years following the end of the financial year in which that payment was received
Details of payments received via bank transfer, cheques or otherwise For the period that it takes to receive full payment on a matter, and then for a further 7 years following the end of the financial year in which that payment was received
Debit card details in respect of payments received  For the duration of taking payment but no longer than until satisfactory completion of the payment 
Details of payments made via bank transfer or otherwise For the period that it takes to make or receive payments on a matter, and then for a further 7 years following the end of the financial year in which that payment was received
Deeds                          For the period we have been asked or are expected to store them

 

Client and contact databases (used for marketing purposes) 

Document Description Retention Period

Details of client (name, address, telephone, email, contact details etc)

For the period that the information is accurate and up to date (and can be verified as such) and for a period of 2 years from the date of the last completed instruction or transaction (such as payment) unless the individual has given and not withdrawn consent
Details of prospect (name, address, telephone, email, contact details etc) For the period during which we are actively seeking to do business with a client prospect, and then for a further 2 years
Details of subscriber to any newsletter or other content via the website or other internet source (name, title, email etc)                                                                                                                                                                                                                                                                                                                                                                                                                                               For the period the subscription continues, or for the period that the information can be verified as accurate and up to date (if shorter)

 

Regulatory requirements

Document Description  Retention Period
Photographic identification documents including drivers licences, passports amongst others; proof of source and destination of funds and any other information necessary for compliance with Money Laundering or Prevention of Mortgage Fraud Regulations  For the period that it takes to accept and fulfil instructions to their satisfactorily conclusion, and then for a further 7 years 
Details of financial records and transactions between us which we are obliged to maintain in accordance with HMRC or Solicitors Accounts Rules and associated auditing processes For the period that it takes to receive full payment on a matter, and then for a further 7 years following the end of the financial year in which that payment was received

 

Complaints or Claims

Document Description  Retention Period
Details of complainant or Claim (name, address, contact details), client identity, and other necessary identifying features                                                                                                                                                        For the duration of the complaint, until it has been satisfactorily resolved or disbanded by the complainant, and then for a further 7 years
Details of nature of the complaint (such as service or billing issue) For the duration of the complaint, until it has been satisfactorily resolved or disbanded by the complainant, and then for a further 7 years
Outcome of complaint (along with details of client identifier details such as name and client number but no address or billing information) For a period of 7 years after the satisfactory resolution of the complaint (or for so long required by the relevant industry regulator if applicable)
Any other personal information that we are required to maintain or renew our professional indemnity insurance For as long as we need to rely on that information for the purpose of our professional indemnity insurance

 

Visitor records

Document Description  Retention Period
Log in and log out records of visitors to our offices, including any car registration details                                                                                                                                                                                                                                                                                                                                                                                                                                           For the duration of the visit and for so long as reasonably necessary for the identification, investigation and conclusion of any health and safety or security incident (usually up to 6 months unless there is an ongoing incident investigation)

 

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Section B - Website Terms of Use

These terms of use apply to the entire contents of this website under the domain name http://www.otbeveling.com/ ("Website") and to any correspondence by e-mail between us and you, related to your use of the Website.

Please read these terms of use carefully before using this Website. By using this Website, you indicate that you accept these terms. Please do not use this Website if you do not accept our terms of use. This notice is issued by OTB Eveling LLP ("OTB Eveling").

OTB Eveling tries to ensure that this Website is available 24 hours a day. OTB Eveling will not be liable if this Website is unavailable at any time or for any period for any reason.

Access to this Website may be suspended temporarily and without notice in the case of system failure, maintenance or repair or for reasons beyond OTB Eveling's control.


Information About Us
the Website, www.otbeveling.com, is owned and operated by OTB Eveling LLP, a limited liability partnership registered in England and Wales under OC371214 whose registered address is Senate Court, Southernhay Gardens, Exeter EX1 1NT
OTB Eveling LLP is authorised and regulated by the Solicitors Regulation Authority under number 566522.

 

1. Introduction and Privacy Policy

1.1 You may access any area of this Website without registering your details with us.

1.2 You are deemed to have accepted this legal notice in full by entering any part of this website. You must leave this Website immediately if you do not accept any of these terms and conditions in full.

1.3 OTB Eveling’s Privacy Policy for Website Users is attached to these terms of use at Appendix 1 and forms part of these terms of use.

1.4 The Privacy Policy for Website Users attached at Appendix 1 also contains our Cookie Policy, which also forms part of these terms of use.

1.5 OTB Eveling can revise these terms of use or the appended policies at any time. You should check whether the terms of use have changed on our Website, as they are binding. Provisions of these terms of use may be superseded by expressly designated legal notices or terms which are located elsewhere on the Website.

 

2. Access and Use of Our Website
2.1 You are allowed to download and print extracts from this website from this Website for your own use but only if the below conditions are met. The use of any extracts other than in accordance with the below conditions is forbidden.

a) no documents or related graphics on this Website can be modified in any way;
b) no graphics on this Website can be used separately from accompanying text;
c) OTB Eveling's copyright and trade mark notices and at notice that you are “using the content with the permission of OTB Eveling LLP”  must appear in all copies of this Website; and
d) any such use is for your own personal use only and no materials should be used for any commercial purposes whatsoever.

2.2 Unless otherwise stated, the copyright and other intellectual property rights in all material on this Website (including without limitation photographs and graphical images) are owned by OTB Eveling (or its licensors).

2.3 If you breach any of the terms in these terms of use, your permission to use this Website automatically terminates and you must immediately destroy any downloaded or printed extracts from this Website. You may also be liable to indemnify us against any losses we incur as a result of your use of this Website or any information extracted from it.

2.4 Subject to paragraph 2.1, you may only reproduce or store part of this Website in any other website or include any part of the website in any public or private electronic retrieval system or service if you have OTB Eveling's prior written permission.

2.5 Any rights not expressly granted in these terms are reserved.

 

3. Visitor Behaviour
3.1 Other than personally identifiable information, which is covered under OTB Eveling's Privacy Policy, which is attached at Appendix 1 to these terms of use, any material you transmit or post to this Website will be considered non-confidential and non-proprietary and OTB Eveling will have no obligations in respect of this material.

3.2 OTB Eveling and its designees are free to copy, disclose, distribute, incorporate and otherwise use all material and all data, images, sounds, text and other things that you provide for any and all commercial or non-commercial purposes. This will not apply to any emails sent to us via our website which OTB Eveling will treat as confidential on receipt. However, you are responsible for ensuring any email is correctly addressed as email is not necessarily secure. 

3.3 We recommend that you contact OTB Eveling either by email or post to the firm's office address or the email address clientrelations@otbeveling.com your correspondence contains any sensitive or confidential information so that we can make appropriate arrangements.

3.4 You are prohibited from posting or transmitting to or from this Website any material:

(a) that is threatening, defamatory, indecent, seditious, offensive, pornographic, abusive, liable to incite racial hatred, discriminatory, in breach of confidence, privacy or anything which may cause insult, annoyance or inconvenience; or
(b) for which you have not obtained all necessary licences and/or approvals; or
(c) which constitutes or encourages conduct that would be considered a criminal offence, give rise to civil liability, or otherwise be contrary to the law of or infringe the rights of any third party, in the UK or any other country in the world; or
(d) which is technically harmful (including, without limitation, computer viruses, logic bombs, Trojan horses, worms, harmful components, corrupted data or other malicious software or harmful data).

3.5 You may not misuse the Website (including, without limitation, by hacking).

3.6 OTB Eveling will fully co-operate with any law enforcement authorities or court order requesting or directing OTB Eveling to disclose the identity or locate anyone posting any material in breach of paragraph 3.4 and/or  paragraph 3.5

 

4. Links to and from Other Websites
4.1 Links on this Website to third party's websites are only provided for your convinience. You will leave this Website if you use these links. OTB Eveling has not reviewed all of these third party websites and does not control and is not responsible for these websites or their content or availability. OTB Eveling does not endorse or make any representations about third party links, or any material found there, or any results that may be obtained from using third party links. You access any third party websites linked to the Website entirely at your own risk.

4.2 You are not allowed to create links to this website. Please contact us  if you want to do so and we will consider whether to discuss the matter.

 

5. Disclaimer

5.1 While OTB Eveling tries to ensure that the information on this Website is correct, OTB Eveling does not warrant the accuracy and completeness of the material on this Website. OTB Eveling may make changes to the material on this Website, or to the services described in it, at any time without notice. The material on this Website may be out of date, and OTB Eveling makes no commitment to update such material.

5.2 The material on this Website is provided “as is”, without any conditions, warranties or other terms of any kind. Accordingly, to the maximum extent permitted by law, OTB Eveling provides you with this Website on the basis that OTB Eveling excludes all representations, warranties, conditions and other terms (including, without limitation, the conditions implied by law of satisfactory quality, fitness for purpose and the use of reasonable care and skill) which but for this legal notice might have effect in relation to this Website.

5.3 Where any information is provided on this Website or in any newsletter or similar correspondence we may send you at any time, such materials are provided for general information and reference purposes only and they should not be relied upon. Any such materials represent only our perspective or understanding of law and practice at the time of writing.

5.4 If you have any specific queries then you should seek legal advice and we will not be liable for any action you take or failure to act following a review of the information placed on the Website.

 

6. Liability
6.1 OTB Eveling, and any of OTB Eveling’ partners, employees agents or commercial partners exclude all liability and responsibility for any amount or kind of loss or damage that may result to you or a third party (including without limitation, any direct, indirect, punitive or consequential loss or damages, or any loss of income, profits, goodwill, data, contracts, use of money, or loss or damages arising from or connected in any way to business interruption, and whether in tort (including without limitation negligence), contract or otherwise) in connection with this Website in any way; or in connection with the use, inability to use or the results of use of this Website, any websites linked to this Website or the material on such websites, including but not limited to loss or damage due to viruses that may infect your computer equipment, software, data or other property on account of your access to, use of, or browsing this Website or your downloading of any material from this Website or any websites linked to this Website.

6.2 Nothing in these terms of use excludes or limits OTB Eveling’s liability for:
a) death or personal injury caused by negligence (as such term is defined by the Unfair Contract Terms Act 1977); or
b) fraud; or
c) misrepresentation as to a fundamental matter; or
d) any liability which cannot be excluded or limited under applicable law.

6.3 You assume and will be responsible for all costs if any material on this Website results in the need for servicing, repair or correction of equipment, software or data.

6.4 You shall fully indemnify OTB Eveling for any loss or damage suffered by OTB Eveling for breach of these terms of use.

 

7. Right of Revocation
7.1 OTB Eveling expressly reserves the right to revoke any rights granted under these terms of use, including in particular right granted in paragraph 2.1, for any breach of these terms of use, and to take any action it deems appropriate in response.
 

8.  Governing Law and Jurisdiction

8.1 These terms of use are governed by and construed in accordance with English law.

8.2 Disputes arising in connection with this legal notice are subject to the exclusive jurisdiction of the English courts.

8.3 This Website is intended for users in the UK. We make no representations that the materials and Website are suitable for users outside England and Wales, and if you access the Website from outside of England or Wales you are solely responsible for ensuring compliance with all relevant local laws, and you hereby indemnify us from any liability arising in connection with your use and access to the Website.

 

Appendix 1

Privacy Policy for Website Users and Cookie Policy

 

Background:

OTB Eveling LLP understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits the Website and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.
This Policy applies to Our use of any and all data collected by us in relation to your use of the Website. Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy and Cookie Policy is deemed to occur upon your first use of the Website. If you do not accept and agree with this Privacy Policy, you must stop using the Website immediately.

 

1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings: 

“Account” means an account or subscription required to access and/or use certain areas and features of the Website or to receive updates or communications;
“Cookie” means a small text file placed on your computer or device by the Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the Cookies used by the Website are set out in section 12, below;
“the Website” means this website, www.otbeveling.com;
“UK and EU Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015; and
“We/Us/Our” means OTB Eveling LLP, a limited liability Partnership company registered in England and Wales with number OC371214 and is authorised and regulated by the Solicitors Regulation Authority under number 566522 with registered office is at Senate Court, Southernhay Gardens, Exeter EX1 1NT.

 

2.  Information About Us

2.1 the Website, www.otbeveling.com, is owned and operated by OTB Eveling LLP, a limited liability partnership registered in England and Wales under OC371214 whose registered address is Senate Court, Southernhay Gardens, Exeter EX1 1NT 

2.2 We are authorised and regulated by the Solicitors Regulation Authority under number 566522. 

 

3.  Scope – What Does This Policy Cover?

This Privacy Policy applies only to your use of the Website. It does not extend to any websites that are linked to from the Website (whether We provide those links or whether they are shared by other users). We have no control over how your data is collected, stored or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

 

4.  What Data Do We Collect?

Some data may be collected automatically by the Website (for further details, please see section 12 on Our use of Cookies, other data will only be collected if you voluntarily submit it and consent to Us using it for the purposes set out in section 5, for example, if registering or signing up for any kind of Account. Depending upon your use of the Website, We may collect some or all of the following data:

4.1 name;

4.2 business/company name

4.3 job title;

4.4 profession;

4.5 contact information such as email addresses and telephone numbers;

4.6 demographic information such as post code, preferences and interests;

4.7 IP address (automatically collected);

4.8 web browser type and version (automatically collected);

4.9 operating system (automatically collected);

4.10 a list of URLs starting with a referring site, your activity on the Website, and the site you exit to (automatically collected)

 

5.  How Do We Use Your Data?

5.1 All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on security see section 6, below.

5.2 We use your data to provide the best possible services to you. This includes:

5.2.1 Providing and managing your access to the Website;

5.2.2 Personalising and tailoring your experience on the Website;

5.2.3 Personalising and tailoring Our services for you;

5.2.4 Responding to communications from you;

5.2.5 Supplying you with email updates that you may have subscribed to (you may unsubscribe or opt-out at any time); 

5.2.6 Analysing your use of the Website to enable Us to continually improve the Website and your user experience; 

5.3 In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the services We can provide you without your consent for Us to be able to use such data.

5.4 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email telephone and post with information, news and offers on Our services or legal updates. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.

5.5 Under GDPR we will ensure that your personal data obtained via the Website is processed lawfully, fairly, and transparently, without adversely affecting your rights.  We will only process your personal data obtained via the Website on the following basis:

5.5.1 you have given consent to the processing of your personal data for one or more specific purposes;

5.5.2 processing is necessary for compliance with a legal obligation to which we are subject;

5.5.3 processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, such as promoting our services to you as a user of or visitor to the Website.

 

6.  How and Where Do We Store Your Data?

6.1 We only keep your data for as long as We need to in order to use it as described above in section 5, and/or for as long as We have your permission to keep it.  In any event, We will conduct an annual review to ascertain whether we need to keep your data. Your data will be deleted if we no longer need it in accordance with the terms of our Data Retention Policy. Our Data Retention Policies is available on our website. 

6.2 Your data will only be stored within the UK and European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein).

6.3 Data security is of great importance to Us, and to protect your data. We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through the Website.

6.4 Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.

 

7.  Do We Share Your Data?

7.1 Subject to clauses 7.2 and 7.3 below, we will not share your personal data obtained via the Website with third parties for commercial business or any other reasons.

7.2 We may compile statistics about the use of the Website including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. 

7.3 In certain circumstances We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.

 

8.  What Happens If Our Business Changes Hands?

8.1 We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Data provided by users will, where it is relevant to any part of Our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the data for the purposes for which it was originally collected by Us.

8.2 In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.

 

9.  How Can You Control Your Data?

9.1 When you submit information via the Website, you may be given options to restrict Our use of your data. We aim to give you strong controls on Our use of your data (including requirement for you to opt-in to updates and emails; and the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details).

 

10.  Your Right to Withhold Information & Your Right to Withdraw Information After You Have Given it

10.1 You may access the Website without providing any data at all. 

10.2 You may restrict your internet browser’s use of Cookies. For more information, see section 12.

10.3 You may withdraw your consent for Us to use your personal data as set out in section in 5 at any time by contacting Us using the details set out in section 1, or by contacting our Practice Manager, and We will delete Your data from Our systems.  

 

11.  How Can You Access Your Data?

You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact our Practice Manager for more details.

 

12.  What Cookies Do We Use and What For?

12.1 the Website may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We may use Cookies to facilitate and improve your experience of the Website and to provide and improve Our services. For more details, please refer to section 5, above, and to section 12.6 below. We shall carefully choose such Cookies and will take steps to ensure that your privacy is protected and respected at all times.

12.2 All Cookies used by and on the Website shall be used in accordance with current English and EU Cookie Law.

12.3 By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended. 

12.4 The following first party Cookies may be placed on your computer or device:

Name of Cookie Purpose Strictly Necessary
PHPSESSION ID an internal id of the php session on the apache server side to securely store authentication details
Resolution  screen resolution of the user For user experience
__utma  stores the amount of visits (for each visitor), the time of the first visit, the previous visit, and the current visit For Google Analytics

__utmb 

__utmc

used to check approximately how fast people leave: when a visit starts, and approximately ends (c expires quickly) For Google Analytics
__utmk  to digest hashes of utm values For Google Analytics
__utmv  used for user-custom variables in Analytics For Google Analytics
__utmx  used by Website Optimizer, when it is being used For Google Analytics
__utmz  records whether the visitor came from a search engine (and if so, the search keyword used), a link, or from no previous page (e.g. a bookmark) For Google Analytics

 

12.5 the Website uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use the Website. This, in turn, enables Us to improve the Website and the services offered through it. You do not have to allow Us to use these Cookies, as detailed below, however whilst Our use of them does not pose any risk to your privacy or your safe use of the Website, it does enable Us to continually improve the Website, making it a better and more useful experience for you.

12.6 The analytics service(s) used by the Website use(s) Cookies to gather the required information. Certain of these Cookies may be placed immediately when you first visit the Website and it may not be possible for Us to obtain your prior consent.

12.7 You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

12.8 You can choose to delete Cookies at any time however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, login and personalisation settings.

12.9 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

 

13.  Summary of Your Rights under GDPR

Under the GDPR, you have:

13.1 the right to request access to, deletion of or correction of, your personal data held by Us; 

13.2 the right to complain to a supervisory authority.  The relevant authority is the Information Commissioner’s Office (“ICO) who can be contacted by using this link (https://ico.org.uk/global/contact-us/)

13.3 be informed of what data processing is taking place;

13.4 the right to restrict processing;

13.5 the right to data portability;

13.6 object to processing of your personal data;

13.7 rights with respect to automated decision-making and profiling.

To enforce any of the foregoing rights or if you have any other questions about the Website or this Privacy Policy and Cookie Policy, please contact Us using the details set out in section 14 below.

 

14.  Contacting Us

If you have any questions about the Website or this Privacy Policy, please contact our Practice Manager by emailing clientrelations@otbeveling.com or by using the contact information on the Website. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 11, above).

 

15.  Changes to Our Privacy Policy

We may change this Privacy Policy as we may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on the Website and you will be deemed to have accepted the terms of the Privacy Policy on your first use of the Website following the alterations. We recommend that you check this page regularly to keep up-to-date.