Home » Privacy Policy

Privacy Policy (Last Updated: 23 May 2018)

THM Partners LLP of 25 Watling Street, London EC4M 9BR (we, our or us) is committed to protecting and respecting your privacy.

This privacy policy (together with our Engagement Letter and Terms of Business, if relevant) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.  Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

We are the data controller (ie the company who is responsible for, and controls the processing of, your personal data), and we are registered with the Information Commissioner’s Office (registration number Z1494666).

Key Terms

personal data means information about individuals (including you), and information from which individuals could be identified.

you means any individual whose personal data we process, including clients, client personnel, counterparties, counterparty personnel, other professional advisers, suppliers, supplier personnel and general business contacts.

Click on one of the links below to jump to the listed section.

Changes to our privacy policy
Information we may collect from you
How is your personal data collected?
Purposes for which we will use your personal data
Disclosure of your personal data
Cookies
International Transfers
Security
Data Retention
Third Party Links
Your Rights
Glossary
Contact


1.  Changes to our privacy policy
Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.


2.  Information we may collect from you
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, last name, title, date of birth, nationality, job title and gender.

Contact Data includes postal address, email address and telephone numbers.

Technical Data includes internet protocol (IP) address, browser type and version, and other technology on the devices you use to access this website.

Usage Data includes information about how you use our website and services.

Marketing Data includes your preferences in receiving marketing from us.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, 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.

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.


3.  How is your personal data collected?
We use different methods to collect personal data from and about you, including through:

Direct interactions.  You may give us your Identity Data, Contact Data and Marketing Data when:

  • Corresponding with us by post, phone, email or otherwise;
  • Entering into a contract with us;
  • Filling in forms on our website; and
  • Asking us to provide you with a quote for our services.

Automated technologies or interactions.  As you interact with our website, we may automatically collect Technical Data and Usage Data.  We collect this personal data by using cookies and similar technologies.  Please see our section on Cookies for further details.

Third parties or publicly available sources.  We may receive personal data about you from various third parties as set out below:

  • Identity Data and Contact Data from third parties who would like to introduce us to you, including lawyers, accountants, advisers or financial institutions; and
  • Identity Data and Contact Data from publicly availably sources, such as Companies House and the Electoral Register.

Informing us of changes:  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.

Information about other people:  If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on his / her behalf and has agreed that you can give consent on his / her behalf to the processing of his / her personal data and receive on his / her behalf any data protection notices.

Know Your Client Checks:  For fraud prevention and money laundering purposes, and as required under applicable law, we will need to undertake “Know Your Client” checks, which may include obtaining proof of your identity (eg passport or driver’s licence) and proof of your address (eg utility bill).


4.  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

Lawful basis for processing

To fulfil our obligations, if you are a client or supplier or other individual with a direct contractual relationship with us

Performance of Contract

To contact you if you are involved in a project we are undertaking for a client, whether in your professional or personal capacity

Legitimate Interest and Performance of Contract

To provide professional services to our clients

Legitimate Interest and Performance of Contract

To instruct third parties on behalf of our clients

Legitimate Interest

Where you request information or a quote for services from us

Legitimate Interest

To carry out investigations, risk assessments and client due diligence

Legitimate Interest and Performance of Contract

To keep in touch with you as part of our professional network and let you know about changes to our services or recent news about us

Legitimate Interest

To ensure the effective management and running of our business

Legitimate Interest

To fulfil our compliance and other obligations under relevant legislation or regulation.

Comply with a legal or regulatory obligation

Information we receive from other sources:  We may combine information you give to us with information we collect about you, and may use the combined information for the purposes set out above (depending on the types of information we receive).


5.  Disclosure of your personal data

We may share your personal data with selected third parties, including business partners, suppliers and sub-contractors, for the performance of any contract we enter into with them or you.

We may disclose your personal data to third parties:

  • If our business is acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
  • If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation, or in order to enforce or apply our Engagement Letter, Terms of Business and other agreements; or to protect the rights, property, or safety of our customers, or others;
  • To our professional advisers (legal and regulatory), auditors or other inspecting organisations from time to time (including the FCA, ICAEW and ICAS);
  • To our insurers and insurance brokers; and
  • If we have a legitimate interest to send communications to you (for example newsletters), we may transfer your information to our third party processors for the purposes of sending such communications to you.

We require all third parties to respect the security of your personal data and to treat it in accordance with applicable 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.


6.  Cookies

A cookie is a small text file which is placed onto your computer (or other electronic device) when you access our website.

We use cookies on our website.  Cookies are small files saved to your computer’s hard drive that track, save and store information about your interactions and usage of the website.

This website uses tracking software to monitor its visitors to better understand how they use it.  This software is provided by Google Analytics which uses cookies to track visitor usage.  The software will save a cookie to your computer’s hard drive in order to track and monitor your engagement and usage of the website, but will not store, save or collect personal data.  You can read Google’s privacy policy here for further information http://www.google.com/privacy.html.

If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted.  If you do this, please be aware that you may lose some of the functionality of this website.  For further information about cookies and how to disable them please go to: www.aboutcookies.org or www.allaboutcookies.org.


7.  International Transfers

We do not routinely transfer your personal data outside the European Economic Area (EEA) or a jurisdiction that the European Commission has determined provides adequate protection for personal data.  However, we use certain third party providers for services, such as IT, who may transfer data outside of the EEA or an adequate country.  We will make sure to include in our contracts with such third parties model clauses approved by the European Commission or ensure the party has subscribed to the EU-US Privacy Shield.


8.  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.  However, the transmission of information via the internet is not completely secure.  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.


9.  Data Retention

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, regulatory or reporting requirements.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.


10.  Third Party Links

Our website may, from time to time, contain links to and from the websites of our affiliates.  If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.  Please check these policies before you submit any personal data to these websites.


11.  Your 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.

Complain about our use of your personal data.  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.


12.  Glossary

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.


13.  Contact

Questions, comments and requests regarding this privacy policy are welcome.  Please contact us by:

Email: dataprotection@thmpartners.com

Post: 25 Watling Street, London EC4M 9BR

THM Partners LLP is authorised and regulated by the Financial Conduct Authority.