Privacy policy - Marlborough House Partners LLP

1. BACKGROUND

Marlborough House Partners LLP is an alternative business structure authorised and regulated by the Solicitors Regulation Authority under SRA number 631393 (“MHP” or “us” or “our”).

We care about privacy and data protection and we are committed to protecting your personal information. We also aim at transparency, we want you to know what data we collect about you and how it is used and shared. Please be aware that, whilst we make our best efforts to keep your personal information safe, no website can be completely secure.

The following privacy policy (“Privacy Policy”) relates to our use of any personal information regarding you that we collect and process via our website (“Site”) or any other personal information you provide us in person, via email, telephone, text message, or other means.

In this Privacy Policy, the terms processing, personal data, data controller, data processor, data subject shall have the same meaning as set out in the Data Protection Act 1998 (“DPA”) as amended, extended or re-enacted from time to time and including all subordinate legislation made from time to time under the DPA or as defined by the Regulation of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (the “GDPR”) once applicable and/or any corresponding or equivalent national laws or regulations once in force and applicable (“Applicable Data Protection Laws”).

To learn more about your rights to privacy and data protection, we recommend you visit the Information Commissioner’s Office (“ICO”) website at https://ico.org.uk/

2. KEY TERMS

To help you understand the content of our Privacy Policy we have summarised some key terms:

Data Controller means the individual or organisation that, alone or jointly with others, exercises overall control over how Personal Data is processed and the purposes of such treatment.

Data Processor means any person (other than an employee of the Data Controller) who processes the data on behalf of and under the instruction of the Data Controller.

Communication Methods means email, telephone, notices posted on our Site, or any other communication methods.

Personal Data means data which relates to a living individual who can be identified from such data, or from data and other information which is in the possession of, or is likely to come into the possession of, the Data Controller.

Processing means obtaining, recording or holding data or carrying out any operation in relation to Personal Data.

Third-Party Websites means websites owned and operated by third parties.

3. DATA CONTROLLER

For the purpose of the processing of your Personal Data in connection with your use of our Site or of our services, MHP is a Data Controller.

We are based and operate within the United Kingdom.

We are registered in England and Wales under company number OC395101 and have our registered office at Third Floor, Marlborough House, Victoria Road South, Chelmsford, Essex CM1 1LN. Our main trading address is Third Floor, Marlborough House, Victoria Road South, Chelmsford, Essex CM1 1LN.

If you have any queries regarding our use of your personal data, please contact us at info@marlboroughhousepartners.com.

4. PRIVACY POLICY IN RELATION TO WEBSITE USERS

The terms in this paragraph 4 apply only to users of the Site who are not otherwise using our services.

4.1 LEGAL BASIS FOR PROCESSING

We process your Personal Data on the basis that you have consented to and we have a legitimate interest in such processing. Our legitimate interest includes our commercial interest in offering our services to the public.

4.2 INFORMATION WE COLLECT ABOUT YOU

We log your visits and your usage data when you visit our Site. In particular, we use internet protocol (“IP”) addresses, cookies and similar technologies (e.g., web beacons, pixels, ad tags and device identifiers) to identify you or your device. Please read our Cookies Policy to learn more about how we use cookies and similar technologies and how to opt out.

When you visit or leave our Site, we receive information about your IP address, proxy server, operating system, web browser and add-ons, device identifier and features, and/or ISP or your mobile carrier.

4.3 HOW WE USE YOUR PERSONAL DATA

We use your Personal Data to give you access to our Site and in particular to:

provide you with information about our services;
contact you through any Communication Method about our services, provided that you have previously consented to us contacting you;
produce aggregate insights that do not identify you; and
investigate, respond to and resolve complaints and service issues.

4.4 RECIPIENTS OF YOUR DATA

To provide and develop our Site, we may share your Personal Data with third parties for maintenance, analysis and audit. Third parties will only have access to and use your information as reasonably necessary to perform these tasks on our behalf and they will be bound to non-disclosure obligations and to the terms of this Privacy Policy.

We may have to disclose your Personal Data if it is reasonably necessary to: (i) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (ii) investigate and defend ourselves against any third-party claims or allegations; and (iii) protect the security or integrity of our services.

We will attempt to notify you about legal demands for your Personal Data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

We may share your Personal Data as part of a sale, merger or change in control, or in preparation for any of these events. Any other entity which buys MHP or part of our business will have the right to continue to use your data, but only in the manner set out in this Privacy Policy.

4.5 DATA RETENTION

We will normally keep your Personal Data for as long as it is necessary to provide you with access to our Site or services and in any case for a maximum of 3 months from the first collection of your Personal Data.

4.6 CROSS-BORDER DATA TRANSFERS

We do not transfer, store or process your Personal Data at destinations outside the European Economic Area (“EEA”).

5. PRIVACY POLICY IN RELATION TO USERS OF OUR SERVICES

The terms in this paragraph 5 apply only to users of our services.

5.1 LEGAL BASIS FOR PROCESSING

LEGITIMATE INTEREST

We process Personal Data of users of our services (“Clients”) on the basis that we have a legitimate interest in such processing that includes our commercial interest in providing you with our services.

CONSENT AND PERFORMANCE OF A CONTRACT

Furthermore, we may process Personal Data of Clients on the basis that: (i) they have consented to such processing; and/or (ii) it is necessary for the entry into, or performance of, a contract or in order to take steps at their request prior to the entry into a contract.

5.2 INFORMATION WE HOLD

UPON REGISTRATION

When you choose to use our services, we collect the following Personal Data: your name, your contact details, your email address, your date of birth, your passport details and your current address.

PAYMENT

In order to process the payment of an invoice for our services, we may collect: bank details and the billing address.

ADDITIONAL INFORMATION

Depending on your requirements and circumstances, we may need to collect further Personal Data about you or about other individuals connected to your matter.

WEBSITE USE

We log your visits, use of our services and your usage data when you visit our Site or otherwise use our services. We use log-ins, IP addresses, cookies and similar technologies (e.g., web beacons, pixels, ad tags and device identifiers) to log your use and identify you or your device. Please read our Cookies Policy to learn more about how we use cookies and similar technologies and how to opt out.

5.3 HOW WE USE YOUR PERSONAL DATA

We use Personal Data of Clients to provide them with our services and in particular:

for administrative purposes;
to correspond with Clients about their matter(s) through any Communication Methods;
to contact Clients via any Communication Methods about the availability of our services, security, other service-related issues, reminders, and suggestions;
to produce aggregate insights that do not identify any individual Client; and
to investigate, respond to and resolve complaints and service issues.

Please be aware that as long as you are using our services you cannot opt out of receiving essential service messages from us, including security and legal notices.

5.4 RECIPIENTS OF YOUR DATA

COMPANIES HOUSE and HMRC

We may share your name, DOB, address and some other Personal Data with Companies House and/or HMRC whenever necessary to perform our obligations to you.

CLOUD-BASED SYSTEMS

We have adopted cloud-based systems and may share your personal data with the operators of these systems, provided that they guarantee appropriate protection of Personal Data and do not operate or share Personal Data outside the EEA. Please feel free to contact us to learn more about our cloud-based systems.

ADDITIONAL DISCLOSURES

To provide our services, we may also share your Personal Data with third parties. Third parties will only have access to and use your information as reasonably necessary to perform these tasks on our behalf and they will be bound to non-disclosure obligations and to the terms of this Privacy Policy.

We may have to disclose your Personal Data if it is reasonably necessary to: (i) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (ii) enforce our agreements with you; (iii) investigate and defend ourselves against any third-party claims or allegations; or (iv) protect the security or integrity of our services.

We may also share your Personal Data as part of a sale, merger or change in control, or in preparation for any of these events. Any other entity which buys MHP or part of our business will have the right to continue to use your data, but only in the manner set out in this Privacy Policy.

5.5 DATA RETENTION

Unless you have agreed for us to retain your Personal Data for a longer period, we will keep your Personal Data only for as long as it is necessary to provide you with our services.

We may need to retain part of your Personal Data even after termination of this agreement with you, if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse or enforce our agreements with you.

In particular, in order to be able to defend ourselves from future claims, we may need to retain some of your personal data for up to 6 years after the termination of our engagement with you. Please contact us at info@marlboroughhousepartners.com if you require more information.

5.6 CROSS-BORDER DATA TRANSFERS

We do not transfer, store or process your Personal Data at destinations outside the EEA.

Even if it is necessary to perform our obligations to you, we will always ask for your consent before transferring your Personal Data outside the EEA.

6. GENERAL

6.1 CHANGES TO THIS PRIVACY POLICY

As we are committed to constantly improving our services, we may change the selection of data and the way we process it. We reserve the right to change or adapt this Privacy Policy from time to time. In case of any material change to this Privacy Policy, we will update the version available on our Site as soon as reasonably possible.

6.2 LINKING TO OTHER WEBSITES

For your information and convenience only, the Site may contain hyperlinks to Third-Party Websites. MHP has no control over and does not endorse any content or services displayed, contained or related to those Third-Party Websites. We make no warranties or representations, express or implied, about Third-Party Websites or any content, products, material or services contained, displayed or related to them. If you decide to access any Third-Party Websites and make use of the information contained on them or to enter into any contract for the supply of goods or services from such third party, you do so entirely at your own risk. We accept no liability for damage or loss, however caused in the connection with the use of or reliance on any information, material, products or services contained on or accessed through any such Third-Parties Websites.

6.3 THIRD-PARTY ADVERTISERS

We do not share your Personal Data with any third-party advertisers or ad networks.

6.4 MARKETING

We do not send you marketing communications unless you have opted-in to receiving marketing communications.

To change your marketing references, you may also email us at: info@marlboroughhousepartners.com.

6.5 SECURITY

We implement a number of security safeguards designed to protect your data, such as HTTPS. We regularly monitor our systems for possible vulnerabilities and attacks. However, we cannot warrant the security of any information that you send us. There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

6.6 YOUR RIGHTS

RIGHT OF ACCESS

We offer you access to the Personal Data we hold about you. Please be aware that the purpose of an access request is to give you the opportunity to confirm the accuracy of Personal Data we are holding about you, the lawfulness of our processing and to allow you to exercise your rights under Applicable Data Protection Laws if necessary.

We reserve the right to reject manifestly unfounded (e.g. made for other, non-data protection purposes) or excessive requests.

To have access to the Personal Data we store about you, please contact us at: info@marlboroughhousepartners.com.

RIGHT TO WITHDRAW CONSENT

Please be aware that, if you have given us consent to process your Personal Data for the purposes detailed in this Privacy Policy, you can always change your mind and withdraw your consent by contacting us at: info@marlboroughhousepartners.com.

In order to process your request, we may ask you to send us a copy of two forms of identification (such as passport, driving licence, birth certificate, bank statement, utility bills).

RIGHT TO LODGE A COMPLAINT

You have the right to lodge a complaint about our processing of your Personal Data and/or our handling of your complaints to ICO or the appropriate data protection authority if you reside outside the United Kingdom.

FURTHER RIGHTS

You also have the followings rights: (i) right to rectification of personal data; (ii) right to erasure of personal data; (iii) right to restriction of the processing of personal data; (iv) right to object to processing of personal data; and (v) right to data portability.

To learn more about your rights please visit ICO’s website at https://ico.org.uk/