GROWER FREEMAN PRIVACY POLICY

In this Privacy Policy the terms, 'we' or 'us' is Grower Freeman and we will refer to www.growerfreeman.co.uk as “our website”.

Your privacy is important to us and we are committed to keeping your information secure and managing it in accordance with our legal responsibilities under applicable data protection laws. We are registered with the UK Information Commissioner's Office (ICO) as a data controller under registration number Z1095997.

Please read this Privacy Statement carefully as it contains important information to help you understand how and why we process any personal information that you give to us.

What information we collect and how

We process personal information which you give us:

  • when you ask for our assistance.
  • as a client so that we can provide you with legal services.
  • in person, in writing or over the phone.
  • When you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
  • Third parties or publicly available sources. We will receive personal data about you from third parties:
  • Technical Data from the following parties:

(a) analytics providers such as Google and Monster Insights based outside the EU.

(b) advertising networks Google Ads based outside the EU.

What we may need from you  

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Purpose of this Privacy Policy  

This privacy policy aims to give you information on how Grower Freeman collects and processes your personal data through your use of this website.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy 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 policy supplements other notices and privacy policies and is not intended to override them.

What kinds of personal information we process

This includes:

  • Personal details such as your date of birth, address, National Insurance Number, telephone number and email and postal addresses.
  • Identity information such as your passport, driving licence, utility bills or national identity card.
  • Credit history and records relating to you, your partner or anyone else you are financially linked with (we obtain this information from credit reference and fraud prevent agencies).
  • Family, lifestyle, financial and social circumstances.
  • Financial details such as your income and information about your bank accounts.
  • Employment/self-employment details.
  • Technical Data such as 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.
  • Usage data - information about how you use our website.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

Special Categories of Personal Data

We do not collect Special categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

We do not generally process such information unless you have voluntarily provided this to us, or it is relevant to the legal service you have asked us to provide you with. For example, in Private Client matters, or where you have advised us of an issue, such as your health, which could mean that you may be classed as a “vulnerable client” i.e. due to your personal circumstances or personal characteristics you are particularly vulnerable to financial detriment. We will process sensitive information where you have provided this information to us and have agreed that we can use this information to deliver products and services to you. Where possible we shall seek to minimise the collection and use of such special categories of personal data.

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 carry out your instructions to provide legal services to you. In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

How we use your Information

We use your information to:

  • provide legal services to you.
  • provide and service your relationship with us.
  • comply with legal obligations for the prevention of financial crime and money laundering.

We will process your information in order to meet our contractual obligations to you, were have a legitimate interest to do so, where we are permitted by law or to comply with applicable laws and regulation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. 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 Legal basis for use of data
Providing a service and internal processing
·     To assess your needs and provide you with suitable products and services ·     Contractual obligation to provide you with, or a proposal including a costs estimate

·     Where special categories of personal data are processed, these are necessary to assess your needs

·     To service and administer your matter including billing ·     Legitimate interests to provide and manage the service
·     To verify the identity of our clients ·     To comply with legal obligations to prevent money laundering
·     To confirm, update and improve our client records ·     To comply with legal obligations in the Data Protection legislation
·     To provide you with any information on the services that you have requested ·     To meet our contractual obligation to provide information on the services you have requested
Relationship Management
·     To manage and develop our relationship with you ·     Legitimate interest to service your matter and improve our service to you
·     To inform you of products and services that may be of interest to you, where you have chosen to be made aware of this ·     To ensure that this is performed with your consent
Training and development
·     For training purposes and to improve our service to you ·     Legitimate interests to improve our services and develop our employees
Complying with Legal Obligations
·     To prevent, investigate and prosecute crime, fraud and money laundering ·     To comply with legal obligations for prevention of financial crime and money laundering
·     For auditing purpose ·     To comply with our legitimate interest to conduct audits
·     If we are obliged to disclose information by reason of any law, regulation or court order ·     To comply with legal obligations
Electronic information and marketing
·     To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (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 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 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 Necessary for our legitimate interests (to develop our products/services and grow our business)
Other
·     To transfer information to any entity which may acquire rights in us ·     Legitimate interests for commercial interests
·     For any other purpose to which you agree. ·     To ensure that this is carried out with your consent

Marketing

 

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us and you have not opted out of receiving that marketing.

Third-Party Marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting Out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service or other transaction.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Change Of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

How we retain your personal information and for how long

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

We will take reasonable steps to destroy or anonymise personal information we no longer need for the purposes we have set out above.

Our retention periods are as follows:

Type of personal Information Retention Period
General personal data which includes your normal personal data, personal identity and personal financial data ·     6 years after the end of our business relationship with you, or the end of your matter which ever comes later
Client Due Diligence Material which includes copies of your Passport, Drivers Licence, Bank Statements and any associated documents and explanations you have given to us to prevent fraud, financial crime and money laundering ·     5 years after the end of our business relationship with you, or the end of your matter which ever comes later
Special categories of personal data ·     6 years after the end of our relationship with you

 

How we share your information

Where necessary or required we share information with:

  • Regulatory authorities to comply with our legal obligations.
  • Credit reference agencies to check your identity in accordance with our legal obligations. Property Search Companies to identify any issues that might influence your decision to buy or sell a property.
  • Insurers for the purpose of providing you with appropriate financial cover for an identified insurable risk, or in connection with any claim made by you against us.
  • Property Agents, Brokers, Lenders, other Solicitors involved in your transaction representing other party(ies) in your matter to enable them and us to fulfil our obligations to you.
  • Other Government Departments such as HMRC, Companies House, Probate Registry, Court of Protection or HM Land Registry to fulfil your and our legal obligations.
  • Experts and Barristers required to work on your matter.
  • Our Auditors and external assessment bodies to achieve and maintain any Regulatory or Quality Assurance Standards and accreditations which meet our legal obligations and enable us to provide quality legal services to you.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Information 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 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 personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Updates

We will keep this Privacy Policy under review and make updates from time to time. Any minor changes to this Privacy Statement will be posted on this page and we will communicate any major changes to you.

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 policy of every website you visit.

Cookies

Our website uses cookies (including Google Analytics cookies to obtain an overall view of visitor habits and visitor volumes to our Website).

Your Rights

You have the right to request copies of your personal information. If you think any of the personal information we hold about you is inaccurate, you may also request it is corrected or erased. You also have a right, in certain circumstances, to object to our processing of your personal information, to require us to stop processing your personal information and/or to withdraw your agreement to processing based on 'consent', but this does not apply where we have other legal justifications to continue processing your data or an overriding legitimate interest.

In relation to all of these rights, please write to us at the address below.

Fees for accessing your personal data

Depending on the nature of your request, you will not usually have to pay a fee to access your personal data.  However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.  Alternatively, we could refuse to comply with your request in these circumstances.

 Complaints Process

If you have a complaint about how we have handled your personal information you may contact us using the details below and we will investigate your complaint. You also have the right to complain to the Information Commissioner's Office - (www.ico.org.uk).

Contact Us

You can contact us by writing to us at:

Data Protection Officer

Grower Freeman
Ivor House

25-26 Ivor Place

London NW1 6HR
Email: DPO@growerfreeman.co.uk