Privacy Policy
Information You Provide Us
London Belgravia Holdings Limited are
committed to keeping your personal information safe and secure
We take your privacy very
seriously. Please read this privacy policy carefully as it contains important
information on who we are and how and why we collect, store, use and share your
personal data. It also explains your rights in relation to your personal data
and how to contact us or supervisory authorities in the event you have a
complaint.
We collect, use and are
responsible for certain personal data about you. When we do so we are subject
to the UK General Data Protection Regulation (UK GDPR).
Who we are
London Belgravia Holdings Limited is a Company registered in England
& Wales under company number 12279808. Our registered office is Lillibrooke Manor, Ockwells Road,
Maidenhead, Berkshire, England, SL6 3LP. A list of Directors/Partners is
available for inspection at the registered office. The Company is not an SRA-regualted
law practice but has a registration number under number 639352. The SRA Standards
and Regulations set out the regulatory framework imposed on service providers
such as ours. The current edition of the SRA Standards and Regulations is
available on the SRA Website at www.sra.org.uk. London Belgravia Holdings Limited operates
the website www.lbhl.london.
Key terms
It would be helpful to start by explaining some key terms used in this
policy:
We, us, our |
London Belgravia Holdings Limited, and our group companies (National Legal Service
Limited, Movus Law Limited, Centre for Domestic Abuse and Violence CIC, The
Centre for Domestic Violence Ltd) |
Personal data |
Any information relating to an identified or identifiable individual |
Special category personal data |
Personal data revealing racial or ethnic origin, political opinions,
religious beliefs, philosophical beliefs or trade union membership Genetic data Biometric data (where used for identification purposes) Data concerning health, sex life or sexual orientation |
Data subject |
The individual who the personal data relates to |
Who regulates our use of personal
information
London Belgravia Holdings Limited is a data controller and is registered
with the Information Commissioner’s Office with Registration Number ZB484032.
Personal data we
collect about you
The personal data we collect about you depends on the particular
services we provide to you. We will collect and use the following
personal data about you:
• your name and contact information, including email address and telephone number
• information to check and verify your identity, eg your date of birth
• your gender, if you choose to give this to us
• your professional online presence, eg LinkedIn profile
• Information about how you use our website, IT, communication and other systems
We collect and use this personal data for the purposes described in the
section ‘How and why we
use your personal data’ below. If you do not provide personal
data we ask for, it may delay or prevent us from providing services to you.
How your
personal data is collected
We collect most of this personal data directly from you—in person, by
telephone, text or email and/or via our website.
However, we may also collect information:
• from publicly accessible sources;
• from a third party with your consent, eg your provided references
• from cookies on our website—for more information on our use of cookies, please see our cookie policy
• via our IT systems, eg:
– through automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems.
How and why we use your personal
data
Under data protection law, we can only use your personal data if we have
a proper reason, eg:
• where you have given consent;
• to comply with our legal and regulatory obligations;
• for the performance of a contract with you or to take steps at your request before entering into a contract; or
• for our legitimate interests or those of a third party.
A legitimate interest is when we have a business or commercial reason to
use your personal data, so long as this is not overridden by your own rights
and interests. We will carry out an assessment when relying on legitimate
interests, to balance our interests against your own.
The table below explains what we use your personal data for and why.
What we use your
personal data for |
Our reasons |
Conducting checks to identify our customers and verify their identity Other activities necessary to comply with professional,
legal and regulatory obligations that apply to our business, eg under health and safety law
or rules issued by a professional regulator within our group of companies |
To comply with our legal and regulatory obligations |
To enforce legal rights or defend or undertake legal proceedings |
Depending on the circumstances: —to comply with our legal and regulatory obligations; —in other cases, for our legitimate interests, ie to protect our business, interests and rights |
Gathering and providing information required by or relating to audits,
enquiries or investigations by regulatory bodies |
To comply with our legal and regulatory obligations |
Ensuring business policies are adhered to, eg policies covering security and internet use |
For our legitimate interests, ie
to make sure we are following our own internal procedures so we can deliver
the best service to you |
Operational reasons, such as improving efficiency, training and
quality control |
For our legitimate interests , ie to be as efficient as we can so we can deliver the
best service to you at the best price |
Ensuring the confidentiality of commercially sensitive information |
Depending on the circumstances: —for our legitimate interests, ie
to protect trade secrets and other commercially valuable information; —to comply with our legal and regulatory obligations |
Statistical analysis to help us manage our business, eg in relation to customer base, or other
efficiency measures |
For our legitimate interests, ie
to be as efficient as we can so we can deliver the best service to you at the
best price |
Preventing unauthorised access and modifications to systems |
Depending on the circumstances: —for our legitimate interests, ie
to prevent and detect criminal activity that could be damaging for you and/or
us; —to comply with our legal and regulatory obligations |
Protecting the security of systems and data used to provide the
services |
To comply with our legal and regulatory obligations We may also use your personal data to ensure the security of systems
and data to a standard that goes beyond our legal obligations, and in those
cases our reasons are for our legitimate interests, ie to protect systems and data and to prevent and
detect criminal activity that could be damaging for you and/or us |
Updating customer records |
Depending on the circumstances: —to perform our contract with you or to take steps at your request
before entering into a contract; —to comply with our legal and regulatory obligations; —for our legitimate interests, eg
making sure that we can keep in touch with our customers about existing
orders and new products |
Statutory returns |
To comply with our legal and regulatory obligations |
Ensuring safe working practices, staff administration and assessments |
Depending on the circumstances: —to comply with our legal and regulatory obligations; —for our legitimate interests, eg
to make sure we are following our own internal procedures and working
efficiently so we can deliver the best service to you |
Marketing our services to: —existing and former customers; —third parties who have previously expressed an interest in our services; —third parties with whom we have had no previous dealings. |
For our legitimate interests, ie
to promote our business to existing and former customers |
External audits and quality checks, eg for ISO or Investors in People accreditation and
the audit of our accounts to the extent not covered
by ‘activities necessary to comply with legal and regulatory obligations’
above |
Depending on the circumstances: —for our legitimate interests, ie
to maintain our accreditations so we can demonstrate we operate at the
highest standards; —to comply with our legal and regulatory obligations |
To share your personal data with members of our group and third
parties that will or may take control or ownership of some or all of our business (and professional advisors acting on
our or their behalf) in connection with a significant corporate transaction
or restructuring, including a merger, acquisition, asset sale, initial public
offering or in the event of our insolvency In such cases information will be anonymised where possible and only
shared where necessary |
Depending on the circumstances: —to comply with our legal and regulatory obligations; —in other cases, for our legitimate interests, ie to protect, realise or grow the value in our
business and assets |
How and why we use your personal data—in more detail
More details about how we use your personal data and why are set out in the table below.
Purpose |
Processing operation |
Lawful basis relied on under the UK GDPR |
Relevant categories of personal data |
|
Communications with you not related to marketing, including about
changes to our terms or policies or changes to the products or other
important notices (other than those addressed above) |
Addressing and sending communications to you as required by data protection
laws, ie: —the UK GDPR or Data Protection Act 2018; |
Processing is necessary for compliance with a legal obligation to
which we are subject (Article 6(1)(b)) |
—your name, address and contact information, including email address
and telephone number [and company details;] —your account details (username) |
|
Addressing and sending communications to you about changes to our
terms or policies or changes to the products or other important notices |
Our legitimate interests (Article 6(1)(f)), which is to be as
efficient as we can so we can deliver the best service to you |
—your name, address and contact information, including email address
and telephone number —your account details (username) |
|
How and why we use your personal data—Special category personal data
Certain personal data we collect is treated as a special category to
which additional protections apply under data protection law:
•
personal
data revealing racial or ethnic origin
•
biometric
data (when used to uniquely identify an individual)
Where we process special category personal data, we will also ensure we
are permitted to do so under data protection laws, eg:
• we have your explicit consent;
• the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent; or
• the processing is necessary to establish, exercise or defend legal claims.
Cookies
We do use cookies to help provide a website that is informative and
enjoyable to use. Cookies are small files that are found in your computer’s
internet browser and are beneficial. These small files allow our website to
recognise you. You should not be concerned about our use of cookies as our
website does not contain any advertising from other organisations so allowing
us to ensure your privacy is respected. You can apply settings to your computer
to stop it accepting cookies but this may affect your
ability to use the internet and to get the best from it.
Information gained from the use of
our website
By your use of our website, we will be able to get information about
that usage. This allows us to:
- Administer
our website and for internal operations, including troubleshooting, data
analysis, testing, research, statistical and survey purposes;
- Improve
our website to ensure that content is presented in the most effective
manner for you and for your computer;
- As
part of our efforts to keep our website safe and secure;
Where we may store your information
The data that we collect from you will be held in secure servers owned
and managed by the firm. By submitting your personal data, you agree to this
transfer, storing or processing. We will do everything reasonably necessary to
ensure that your data is treated and held securely and in accordance with this
privacy notice.
Marketing
We will use your personal data to send you updates (by email, text
message, telephone or post) about our services,
We have a legitimate interest in using your personal data for marketing
purposes (see above ‘How
and why we use your personal data’). This means we do not
usually need your consent to send you marketing information. If we change our
marketing approach in the future so that consent is needed, we will ask for
this separately and clearly.
You have the right to opt out of receiving marketing communications at
any time by:
• contacting us at [email protected]
• using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts
We may ask you to confirm or update your marketing preferences if you
ask us to provide further services in the
future, or if there are changes in the law, regulation, or the structure of our
business.
We will always treat your personal data with the utmost respect and
never sell it with other organisations outside the LBHL group for
marketing purposes.
Who we share
your personal data with
We routinely share personal data with:
• companies within the LBHL group
• third parties we use to help deliver our services to you, eg payment service providers, warehouses and delivery companies;
• other third parties we use to help us run our business, eg marketing agencies or website hosts;
• third parties approved by you, eg social media sites you choose to link your account to or third party payment providers;
We only
allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your
personal data.
We or the third parties mentioned above occasionally also share personal
data with:
• our external auditors, eg in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations;
• our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;
• law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations;
• other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.
Where your
personal data is held
Personal data may be held at our offices and those of our group companies, third party agencies, service
providers, representatives and agents as described above (see above: ‘Who we share your personal data with’).
Some of these third parties may be based outside the UK. For more information,
including on how we safeguard your personal data when this happens, see below:
‘Transferring your
personal data out of the UK.
How long your
personal data will be kept
We will not keep your personal data for longer than we need it for the
purpose for which it is used. For example, keeping your employment details on
file in relation to an application for employment.
Different retention periods apply for different types of personal data.
Further details on this are available on request.
If you no longer have an account with us or we are no longer providing
services to you, we will delete or anonymise your account data after seven years.
Following the end of the of the relevant retention period, we will
delete or anonymise your personal data.
Your rights
You have the following rights, which you can exercise free of charge:
Access |
The right to be provided with a copy of your personal data |
|
Rectification |
The right to require us to correct any mistakes in your personal data |
|
Erasure (also known as the right to be forgotten) |
The right to require us to delete your personal data—in certain
situations |
|
Restriction of processing |
The right to require us to restrict processing of your personal data
in certain circumstances, eg
if you contest the accuracy of the data |
|
Data portability |
The right to receive the personal data you provided to us, in a
structured, commonly used and machine-readable format and/or transmit that
data to a third party—in certain situations |
|
To object |
The right to object: —at any time to your personal data being processed for direct
marketing (including profiling); —in certain other situations to our continued processing of your
personal data, eg processing carried out for the
purpose of our legitimate interests unless there are compelling legitimate
grounds for the processing to continue or the processing is required for the
establishment, exercise or defence of legal claims |
|
Not to be subject to automated individual decision making |
The right not to be subject to a decision based solely on automated
processing (including profiling) that produces legal effects concerning you
or similarly significantly affects you |
|
The right to withdraw consents |
If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at
any time Withdrawing a consent will not affect the lawfulness of our use of
your personal data in reliance on that consent before it was withdrawn |
|
For more information on each of those rights, including the circumstances
in which they apply, please contact us (see ‘How to contact us’ below) or see the Guidance from the UK Information Commissioner’s Office (ICO)
on individuals’ rights.
If you would like to exercise any of those rights, please:
• email, call or write to us—see below: ‘How to contact us’; and
• provide enough information to identify yourself (eg your full name, address and customer or matter reference number) and any additional identity information we may reasonably request from you;
• let us know what right you want to exercise and the information to which your request relates.
Keeping your
personal data secure
We have appropriate security measures to prevent personal data from
being accidentally lost, or used or accessed
unlawfully. We limit access to your personal data to those who have a genuine
business need to access it. Those processing your personal data will do so only
in an authorised manner and are subject to a duty of confidentiality.
We also have procedures to deal with any suspected data security breach.
We will notify you and any applicable regulator of a suspected data security
breach where we are legally required to do so.
If you want detailed information from Get Safe
Online on how to protect your personal data and other information and your
computers and devices against fraud, identity theft, viruses and many other
online problems, please visit www.getsafeonline.org.
Get Safe Online is supported by HM Government and leading businesses.
How to
complain
Please contact us if you have any queries or concerns about our use of
your personal data (see below ‘How
to contact us’). We hope we will be able to resolve any issues
you may have.
You also have the right to lodge a complaint with:
• the Information Commissioner
The Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone:
0303 123 1113.
Changes to
this privacy policy
This privacy notice was published on 3 January 2023 and last updated on 3
January 2023.
We may change this privacy notice from time to time—when we do we will inform you via our website.
How to
contact us
Individuals
in the UK
You can contact us by post, email or telephone if you have any questions
about this privacy policy or the information we hold about you, to exercise a
right under data protection law or to make a complaint.
Our contact details are shown below:
Our contact details |
Address: St Magnus House, 3 Lower Thames Street, London, EC3R 6HD Email: [email protected] Tel: 020 3601 5051 |
Do you need extra
help?
If you would like this notice in another format (for example
audio, large print, braille) please contact us (see ‘How to contact us’ above).