Privacy Policy | Alston Asquith

INTRODUCTION

Welcome to Alston Asquith Limited, (‘Alston Asquith’) privacy notice, which has been updated to comply with the General Data Protection Regulation (‘GDPR’) (EU) 2016/679 and the Data Protection Act 2018).

Alston Asquith respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and 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. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

IMPORTANT INFORMATION AND WHO WE ARE
THE DATA WE COLLECT ABOUT YOU
HOW IS YOUR PERSONAL DATA COLLECTED
HOW WE USE YOUR PERSONAL DATA
DISCLOSURES OF YOUR PERSONAL DATA
INTERNATIONAL TRANSFERS
DATA SECURITY
DATA RETENTION
YOUR LEGAL RIGHTS
GLOSSARY

IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how Alston Asquith collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase a product or service or take part in a competition.

This website is not intended for children and we do not knowingly collect data relating to children.

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.

CONTROLLER

Alston Asquith is the controller and responsible for your personal data (collectively referred to as “Alston Asquith”, “we”, “us” or “our” in this privacy notice).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

CONTACT DETAILS

Our full details are:

Full name of legal entity: Alston Asquith Limited

Name or title of DPO: The Privacy Officer

Email address: admin@alstonasquith.com

Postal address: 45 Moorfields, Moorgate, London EC2Y 9AE

Telephone number: +44 (0)20 3950 3538

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on 25 May 2018 and historic versions can be obtained by contacting us.

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.

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.
Correspondence Data: includes any correspondence between us and you about an enquiry.
Enquiry Data: includes your enquiries about engaging us for legal advice or job opportunities.
Financial Data: which includes bank account and/or other billing details.
Transaction Data: includes details about payments to and from you and other details of legal 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.
Tracking Data: such as information we or others collect about you from cookies and similar tracking technologies, such as web beacons, pixels, and other digital identifiers.
Usage Data: includes information about how you use our website and services.
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 may be derived from your personal data but is not considered personal data in law as this data does 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 notice.

We do not usually collect any Special Categories of Personal Data about you, but you may choose to disclose this data to us. 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.Unless we are required to do so to comply with a legal obligation, or as an integral part of providing relevant legal services to you, we do not usually collect any personal data about you relating to criminal convictions or offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by: law and/or regulation; by court order; 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.

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 by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our legal services;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- 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, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies Please see our cookie policy for further details.
Third parties or publicly available sources.We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
  - analytics providers such as Google based outside the EU;
  - advertising networks such as Facebook based inside the EU; and
  - search information providers such as Yell.com based outside the EU.
- Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

HOW WE USE YOUR PERSONAL DATA

Our core purposes for processing personal data are to promote and operate the business of being a law firm, to provide legal services to our clients, to maintain our client and business records, to recruit, and to comply with the law and regulations.

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 a contract which we are about to enter into or have entered into with you (for example, a contract between you and us for us to provide legal advice to 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 (for example, to monitor our IT systems and protect them).
Where we need to comply with a legal or regulatory obligation (for example, the rules which require us to verify the identity of someone before they can become a client).
Where we have your consent to do so (for example, if you are not a client and you ask us to sign you up for news and updates by email)

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to 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/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To provide the Site to you	(a) Technical Data	Legitimate interests (to promote our business and services via the web)
To register you as a recipient of our newsletters and updates	(a) Identity Data (b) Contact Data (c) Technical Data (d) Marketing and Communications Data	(a) Legitimate interests, including for any soft opt-in (to undertake direct marketing to promote our business and services) (b) In the limited circumstances where the Privacy and Electronic Communications Regulations mandate that consent is required for electronic marketing, and we are not relying on your opt-in, the lawful basis will be consent (See Advertising, marketing and your communications preferences below)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking for feedback	(a) Identity Data (b) Contact Data (c) Enquiry Data (d) Correspondence Data (e) Marketing and Communications Data	(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 ensure we provide our services on our most recently updated terms)
To register you as a new client and respond to your enquiry	(a) Identity Data (b) Contact Data (c) Enquiry Data (d)Correspondence Data	(a) Performance of a contract with you (b) Legitimate interests, including pursuing an opportunity to win you as a new client before ground (a) above applies
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity Data (b) Contact Data (c) Enquiry Data (d) Correspondence Data (e) Technical Data (f) Tracking Data (g) Marketing and Communications Data	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 Site and the client experience	(a) Identity Data (b) Technical Data (c) Tracking Data	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 and deliver our marketing strategy)
To target potential new clients and lawyers via social media and the web	(a) Identity Data (b) Technical Data (c) Tracking Data	Necessary for our legitimate interests (to engage with the new clients and potential new lawyers via social media and the web (for example, via LinkedIn))
To undertake anti-money laundering checks and conflict checks	(a) Identity Data(b) Matter Data (c) Financial Data	(a) Necessary to comply with a legal obligation (b) Necessary for our legitimate interests (to administer the client opening process)
To undertake the core task of providing legal advice to you and progressing your matter as instructed (using personal data)	(a) Identity Data(b) Matter Data	(a) Performance of a contract with you(b) Necessary for our legitimate interests (to recover debts due to us)
To undertake the core task of providing legal advice to you and progressing your matter as instructed (using special category data)	Special categories of personal data include 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.	(a) Performance of a contract (b) Explicit consent, given by way of the engagement letter or on a case-by-case basis
To undertake the core task of providing legal advice to you and progressing your matter as instructed using criminal convictions and offences data)	Personal data about you relating to criminal convictions or offences	(a) Performance of a contract with you(b) Explicit consent, given by way of an engagement letter on a case-by-case basis
To liaise with third parties as necessary to progress your matter as instructed (for example overseas law firms, patent agents, forensic accountants, experts or barristers)	(a) Identity Data (b) Matter Data(c) Financial Data(d) Transactional Data	(a) Performance of a contract (b) Necessary for our legitimate interests (to liaise with other professionals or such other individuals as may be required necessary to progress your matter)
To collect and recover money owed to us.	(a) Matter Data (b) Financial Data (c) Transactional Data	Necessary for our legitimate interests (to collect money owed to us)

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly aroundmarketing and advertising. We have established the following personal data control mechanisms:

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 or purchased services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, 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 company outside the Alston Asquith Limited group of companies for marketing purposes.

OPTING OUT

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

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 purchase, product/service experience or other transactions.

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. For more information about the cookies we use, please see: https://www.alstonasquith.com/cookies.

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.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

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.

DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

Internal Third Parties as set out in the Glossary
External Third Parties as set out in the Glossary
Specific third parties listed in the table in above
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 notice.

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.

INTERNATIONAL TRANSFERS

We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. These rules are called “binding corporate rules”. For further details, see European Commission: Binding corporate rules.

Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see: European Commission: Adequacy of the protection of personal data in non-EU countries.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see: European Commission: Model contracts for the transfer of personal data to third countries.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see: European Commission: EU-US Privacy Shield.

Please Contact usif you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

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 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.

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.

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.

If you wish to exercise any of the rights set out above, please Contact us.

NO FEE USUALLY REQUIRED

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 is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

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.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

GLOSSARY

LAWFUL BASIS

Legitimate Interest:means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting us

Performance of Contract:means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation:means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

INTERNAL THIRD PARTIES

Other companies in the Group acting as joint controllers or processors and who are based in the present jurisdiction and provide IT and system administration services and undertake leadership reporting.

EXTERNAL THIRD PARTIES

Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
The Solicitors Regulation Authority, HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances, or other personal data, in certain circumstances.
Facebook: we share your data with Facebook so that we can display adverts to you on Facebook. For more information on Facebook advertising, and how you can control your settings, see here.
We embed a Facebook widget to allow you to see number of likes/shares/recommends and “like/share/recommend” our webpages. This widget may collect your IP address, your web browser User Agent, store and retrieve cookies on your browser, embed additional tracking, and monitor your interaction with the widget, including correlating your Facebook account with whatever action you take within the widget (such as “liking/sharing/recommending” our webpage), if you are logged in to Facebook. For more information about how this data may be used, please see Facebook’s data privacy policy
Google: we share your data with Google so that we can display adverts to you on the world wide web and make use of its Google Analytics product. For more information on Google, and how you can control your settings, see here.
We use Google Analytics to track social shares made on our website. Google automatically collect and store certain information in their server logs which includes device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL, cookies that may uniquely identify your browser or your Google Account, in accordance with their data privacy policy
We use a Linkedin Share widget at our website to allow you to share our webpages on Linkedin. These requests may track your IP address in accordance with their data privacy policy
We use Pinterest Save widget at our website to allow you to pin images to Pinterest from our webpages. These requests may track your IP address in accordance with their data privacy policy
We use Reddit widget at our website which may log information when you interact with the widget. This may include your IP address, user-agent string, browser type, operating system, referral URLs, device information (e.g., device IDs), pages visited, links clicked, user interactions (e.g., voting data), the requested URL and hardware settings, in accordance with their privacy policy

YOUR LEGAL RIGHTS

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.

We cannot advise you in connection with our use of your data. If you need legal advice on this subject, then you will need to consult another firm.