1. PURPOSE OF THIS NOTICE
This notice describes how we collect and use personal data about you, in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act 2018 and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (‘Data Protection Legislation’).
Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
2. ABOUT US
Assynt Corporate Finance Limited (“Assynt”) (“We”) is an authorised corporate finance service provider. We are registered in England and Wales as a limited liability company under number: 08414792 and our registered office is at the Business & technology Centre, Bessemer road Stevenage, Hertfordshire. SG1 2DX.
For the purpose of the Data Protection Legislation and this notice, we are the ‘data controller’. This means that we are responsible for deciding how we hold and use personal data about you. We are required under the Data Protection Legislation to notify you of the information contained in this privacy notice.
We have appointed a Data Protection Officer. Our Data Protection Officer is our Data Protection Point of Contact and is responsible for assisting with enquiries in relation to this privacy notice or our treatment of your personal data. Should you wish to contact our Data Protection Point of Contact you can do so using the contact details noted at paragraph 12 (Contact Us), below.
3. HOW WE MAY COLLECT YOUR PERSONAL DATA
We obtain personal data about you, for example, when:
• you request a proposal from us in respect of the services we provide;
• you OR your employer OR our clients] engages us to provide our services and also during the provision of those services;
• you contact us by email, telephone, post or social media (for example when you have a query about our services); or
• from third parties and/or publicly available resources (for example, from your employer or from Companies House).
4. THE KIND OF INFORMATION WE HOLD ABOUT YOU
The information we hold about you may include the following:
• your personal details (such as your name and/or address);
• details of contact we have had with you in relation to the provision, or the proposed provision, of our services;
• details of any services you have received from us;
• our correspondence and communications with you;
• information about any complaints and enquiries you make to us;
• information from research, surveys, and marketing activities;
• Information we receive from other sources, such as publicly available information, information provided by your employer OR our clients or information from our member network firms.
5. HOW WE USE PERSONAL DATA WE HOLD ABOUT YOU
We may process your personal data for purposes necessary for the performance of our contract with you OR your employer OR our clients and to comply with our legal obligations.
We may process your personal data for the purposes necessary for the performance of our contract with our clients. This may include processing your personal data where you are an employee, subcontractor, supplier or customer of our client.
We may process your personal data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This includes processing for marketing, business development, statistical and management purposes.
We may process your personal data for certain additional purposes with your consent, and in these limited circumstances where your consent is required for the processing of your personal data then you have the right to withdraw your consent to processing for such specific purposes.
Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.
Situations in which we will use your personal data
We may use your personal data in order to:
• carry out our obligations arising from any agreements entered into between you OR your employer OR our clients and us (which will most usually be for the provision of our services);
• carry out our obligations arising from any agreements entered into between our clients and us (which will most usually be for the provision of our services) where you may be a subcontractor, supplier or customer of our client;
• provide you with information related to our services and our events and activities that you request from us or which we feel may interest you, provided you have consented to be contacted for such purposes;
• seek your thoughts and opinions on the services we provide; and
• notify you about any changes to our services.
In some circumstances we may anonymise or pseudonymise the personal data so that it can no longer be associated with you, in which case we may use it without further notice to you.
If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered into with you. Alternatively, we may be unable to comply with our legal or regulatory obligations.
We may also process your personal data without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.
We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected.
When assessing what retention period is appropriate for your personal data, we take into consideration:
• the requirements of our business and the services provided;
• any statutory or legal obligations;
• the purposes for which we originally collected the personal data;
• the lawful grounds on which we based our processing;
• the types of personal data we have collected;
• the amount and categories of your personal data; and
• whether the purpose of the processing could reasonably be fulfilled by other means.
Change of purpose
Where we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal data where that reason is compatible with the original purpose.
Should it be necessary to use your personal data for a new purpose, we will notify you and communicate the legal basis which allows us to do so before starting any new processing.
6. DATA SHARING
Why might you share my personal data with third parties?
We will share your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so.
Which third-party service providers process my personal data?
“Third parties” includes third-party service providers. The following activities are carried out by third-party service providers: IT and cloud services, professional advisory services, administration services, marketing services and banking services.
All of our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.
What about other third parties?
We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or to otherwise comply with the law.
7. TRANSFERRING PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)
We will not transfer the personal data we collect about you outside of the EEA.
Should the necessity arise then we will contact you to obtain your permission so to do.
8. DATA SECURITY
We have put in place commercially reasonable and 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 and other third parties 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 data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
9. RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us, using the contact details below.
Your rights in connection with personal data
Under certain circumstances, by law you have the right to:
• Request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully.
• Request correction of the personal data that we hold about you.
• 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 exercised your right to object to processing (see below).
• 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 basis. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible.
If you want to exercise any of the above rights,[please email our data protection point of contact email@example.com.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
11. RIGHT TO WITHDRAW CONSENT
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose (for example, in relation to direct marketing that you have indicated you would like to receive from us); you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email our data protection point of contact firstname.lastname@example.org.
Once we have received notification that you have withdrawn your consent, we will no longer process your personal information (personal data) for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
12. CHANGES TO THIS NOTICE
Any changes we may make to our privacy notice in the future will be provided to you by way of an update to our web site www.assyntcf.co.uk.
This privacy notice was last updated on 23rd May 2018.
13. CONTACT US
If you have any questions regarding this notice or if you would like to speak to us about the manner in which we process your personal data, please email our Data Protection Point of Contact Andrew Watkin who can be contacted on email@example.com or telephone our Data Protection Point of Contact on 07860 898452.
You also have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, at any time. The ICO’s contact details are as follows:
Information Commissioner’s Office
Telephone – 0303 123 1113 (local rate) or 01625 545 745
Website – https://ico.org.uk/concerns
Details of cookies we use and what we use them for.
What are cookies?
A cookie is a tiny file that is saved by your browser when you visit a website. It enables certain information about your visit to be stored by the site.
Some of these cookies are essential in order for a website to run as you expect it to (for example, placing an item in a shopping basket) while others allow us to provide you with a better service (for example, understanding what content is most popular, to provide you more of the same).
Or we can identify common journeys to popular content and refine the site to help users access that content quicker.
After reviewing the cookies we use (see ‘What cookies we use’ section below) and the benefit they provide our visitors and members, we currently operate an ‘implied consent’ policy. This means that we assume you agree with the usage of our cookies. If you do not agree, we have provided guidance to help you to alter your browser settings to match the level of privacy you require (see ‘How to manage cookies via your browser settings’ section below).
For users of our website, if your cookies aren’t enabled on your computer, it will mean that your experience when logged in to our website will be limited to browsing (for example, you won’t be able to add products to your basket and buy them).
For more details about cookies, visit www.aboutcookies.org.
The cookies we use
The following describes the cookies we use across all of our websites and what we use them for.
Cookies essential for website use
asp.net_sessionid This is essential for browsing and the website wouldn’t work for you without it. This cookie allows us to identify your particular session (the time between arriving at and leaving icaew.com) and means that we can remember you as you move from one page to the next, thereby improving your experience on our site. This cookie will be automatically deleted from your computer when you close your browser.
audience, cfid, cftoken, chktoken, csession, lastvisit, persvalue These cookies are used to:
• identify user session to the servers
• define the content you are or are not allowed to access
• remember a user from page to page
• store the last time a user visited our website
• remember a user’s movements between different parts of our website.
.aspxauth This is created if you have logged in successfully. Without it you will not be able to proceed to the members’ pages and view restricted member content. This cookie will be automatically deleted from your computer when you close your browser.
reference This is used to remember a user’s movements between different parts of our community site ion.icaew.com.
returnurl This is used to set where a user will return to after logging in. Without it, you would always return to the home page after being asked to log in, no matter where you were on the site.
username This is used to generate a username on a page after logging in.
website#lang This is used to retain language settings as a user moves around the site, if multiple languages are available. Without it, you would have to reset your language settings every time you moved from one page to another.
player.vimeo.com(Note: This is a third party cookie) This is used to show Vimeo videos and track where a video has been played. If this cookie can’t run, there’s no way to watch the videos on our website.
Vvcu, vvct These cookies are used if you take part in a web chat session and are used to distinguish users and identify an individual visit by a user.
Non-essential cookies for website analytics and helping you share content
12 ‘sharethis’ cookies for our social buttons
(Note: These are third party cookies) These enable users to share web pages. There are buttons for: Twitter, Facebook and LinkedIn. If you click on any of these buttons, a direct link to the server of the respective social network is established. The contents of the button are then transmitted from the social network directly to your browser and incorporated in the website by it. We don’t control the setting of these cookies, so we recommend you check the third-party websites for more information about their cookies and how to manage them:
(Note: These are third party cookies) Collects advertising information for the Google Analytics Demographics and Insight report
Non-essential cookies for online usability testing
__ar*, _ga, _gat, __utm*, _hjUserId, _hjClosedSurveyInvites, _hjDonePolls, _hjMinimizedPolls, _hjDoneTestersWidgets, _hjMinimizedTestersWidgets, _hjIncludedInSample, JSESSIONID, NREUM, NRAGENT, optimizely*, session These cookies are used to record session information including mouse movements, clicks and search terms using the HotJar online usability testing tool.
Essential third party cookies:
ShoppingCart ShoppingCartVa These cookies will be created by our business partner My Custom Event (MCE) if you book an event on-line. These cookies allow MCE to manage your booking.
Providing you with this information is part of our initiative to fulfil recent legislation. We want to be sure that we are clear and honest about your privacy when using our website.
For independent information about cookies, visit www.aboutcookies.org.
How to manage cookies via your browser settings
Visit www.aboutcookies.org or use the guidance below.
Establish the type and version of the web browser you use to access the internet
Click on ‘Help’ at the top of your browser window and select the ‘About’ option.
Click on the Apple menu and select the ‘About’ option.
Choose your preferred settings
Microsoft Internet Explorer
1. Click on ‘Tools’ at the top of your browser window and select ‘internet options’
2. Click on the ‘Privacy’ tab
3. Move the slide to choose your preferred settings
1. Click on ‘Tools’ at the top of your browser window and select ‘Options’
2. Then select the Privacy icon in the left-hand panel
3. Click on Cookies and choose your preferred settings
1. Click on ‘Tools’ at the top of your browser window and select ‘Options’
2. Click the ‘Under the Bonnet’ tab, locate the ‘Privacy’ section, and choose the ‘Content settings’ button
3. Click the ‘Cookie settings’ tab and choose your preferred settings
All other browsers and/or versions
Please consult your browser online help files, or visit www.aboutcookies.org.
Updated May 2018