PRIVACY NOTICE

Introduction

This is the Privacy Notice of Theseus Partners LLP. Theseus respects your privacy and is committed to protecting your personal data. This privacy notice is designed to inform you as to how we look after your personal data when you visit our website, register an interest or engage our services, and to tell you about your privacy rights and how the law protects you.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below:

  1. Important information

    This privacy notice aims to give you information on how Theseus collects and processes your personal data through: your use of this website, including any data you may provide through this website when you register an interest; request information regarding our services; engage us in contractual work.

    It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

    Changes to the privacy notice and your duty to inform us of changes

    This Privacy Notice was last updated on 8th May 2018.

    It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

    Third-party links

    This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

  2. The data we collect about you

    Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

    We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

    • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
    • Contact Data includes billing address, delivery address, email address and telephone numbers.
    • Financial Data includes bank account and payment card details.
    • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
    • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
    • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
    • Usage Data includes information about how you use our website, products and services.
    • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

    If you fail to provide personal data

    Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

  3. How is your personal data collected

    We use different methods to collect data from and about you including through:

    • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
      • enquire about or engage our services;
      • create an account on our website;
      • subscribe to our service or publications;
      • request marketing to be sent to you;
      • respond to a promotion or survey;
      • give us some feedback.
    • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies.
  4. How we use your personal data

    We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

    • Where we need to perform the contract we are about to enter into or have entered into with you.
    • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
    • Where we need to comply with a legal or regulatory obligation.

    We may rely on consent as a legal basis for processing your personal in relation to sending direct marketing communications, news bulletins or interest documents to you via email or post. You have the right to withdraw consent to marketing at any time by contacting us.

    Purposes for which we will use your personal data

    We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

    Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

    Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
    To register you as a new customer (a) Identity
    (b) Contact
    Performance of a contract with you
    To provide services to you or your employer (a) Identity
    (b) Contact
    (c) Financial
    (d) Transaction
    (e) Profile
    (a) Performance of a contract with you
    (b) Necessary for our legitimate interests (to establish necessary information about you in order to provide our services)
    To process and deliver your contract including:
    (a) Manage payments, fees and charges
    (b) Collect and recover money owed to us
    (a) Identity
    (b) Contact
    (c) Financial
    (d) Transaction
    (e) Marketing
    (a) Performance of a contract with you
    (b) Necessary for our legitimate interests (to recover debts due to us)
    To manage our relationship with you which may include:
    (a) Notifying you about changes to our terms or privacy policy
    (b) Asking you to leave a review or take a survey
    (a) Identity
    (b) Contact
    (c) Profile
    (d) Marketing
    (a) Performance of a contract with you
    (b) Necessary to comply with a legal obligation
    (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
    To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
    (b) Contact
    (c) Technical
    (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
    (b) Necessary to comply with a legal obligation
    To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity
    (b) Contact
    (c) Profile
    (d) Usage
    (e) Marketing
    (f) Technical
    Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
    To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical
    (b) Usage
    Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
    To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity
    (b) Contact
    (c) Technical
    (d) Usage
    (e) Profile
    Necessary for our legitimate interests (to develop our products/services and grow our business)
  5. Disclosures of your personal data

    We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

    1. We do not disclose personal information you provide to any third parties other than as follows:
      • As part of the provision of our services we may disclose information to associates, additional suppliers or other interested parties. We will seek consent before sharing in such a manner.
      • if we are under a duty to disclose or share your personal data in order to comply with any legal obligation (for example, if required to do so by a court order or for the purposes of prevention of fraud or other crime);
      • in order to enforce any terms or agreements for our services;
      • to protect our rights, property and safety, or the rights, property and safety of our users or any other third parties. This includes exchanging information for the purposes of fraud protection and credit risk reduction.
    2. Other than as set out above, we will not disclose any of your personal information unless you give us permission to do so. If we do supply your personal information to a third party, we will take steps to ensure that your privacy rights are protected and that third party complies with the terms of this notice.
  6. International transfers
    1. Our services can be international in nature. As part of the services we provide and at your request or instruction, information may be transferred to, processed and stored at, countries or international organisations outside of the EEA.
    2. We do not transfer any data in a systematic way outside the EEA, nor without your consent to do so, but there may be circumstances in which certain personal information is transferred outside of the EEA, in particular:
      • We may communicate with individuals or organisations outside of the EEA in delivering our services, those communications may include personal information (such as contact information);
      • We may be required to provide certain personal information as part of a legal reporting obligation to an entity outside the EEA;
      • From time to time your information may be stored in devices which are used by our staff outside of the EEA (but staff will be subject to our data control and protection policies).
    3. If we transfer your information outside the EEA, and the third country or international organisation in question has not been deemed by the EU Commission to have adequate data protection laws, we will provide appropriate safeguards and your privacy rights will continue to be enforceable against us as outlined in this notice.
    4. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
  7. Data security

    We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

    We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

  8. Data retention

    How long will you use my personal data for?

    We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

    To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

    Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

    In some circumstances we may anonymise your personal data so that it can no longer be associated with you for research, statistical or planning purposes in which case we may use this information indefinitely without further notice to you.

  9. Your legal rights

    Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

    Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

    Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

    Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

    Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

    Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

    Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

    Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

    Contact us

    If at any time you would like to contact us about exercising your rights set out at section 8, or with any enquiry relating to your personal information or how it is handled, you can do so via the following addresses Theseus Partners LLP, Suite G6 Kingsbury Hall, King Street, Melksham SN12 6HD or by email to Mr. Andrew Wolfe Murray at info@theseusllp.com.

    If we are unable to resolve any issues you may have or you would like to make a further complaint, you can contact the Information Commissioner’s Office by visiting https://ico.org.uk/ for further assistance. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.