Purpose of this privacy policy

This privacy policy aims to give you information on how Shears Law collects and processes your personal data. 

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 policy together with any other data protection or privacy notice that 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 personal data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

Shears Law are authorised and regulated by the Solicitors Regulation Authority (the SRA) under registration number 598069.

Richard Shears is the controller and responsible for your personal data. We are registered with the Information Commissioner’s Office under registration number ZA012025.

Contact details

If you have any questions about this privacy policy or our privacy practices, including any requests to exercise your legal rights, please contact Richard Shears using the details set out below:

-  Our address: 19 High Street, Wicklewood, Norfolk NR18 9QE

-  Telephone: 0800 020 9495

-  Email: rds@shearslaw.co.uk

-  Website contact us page: https://www.shearslaw.co.uk/contact.

Complaints

You have the right to make a complaint about our handling of your personal data, 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 policy and your duty to inform us of changes

We keep our privacy policy under regular review. This policy was last updated on 28 May 2021. 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 site, and information that we may post on our site or via our social media accounts, may include links to third-party websites, plug-ins and applications, for your convenience and information. Clicking on those links or enabling those connections means you may leave our site or our social media accounts and may allow third parties to collect or share data about you. 

We do not control these third-party websites, social media accounts or apps and are not responsible, or liable, for how they process your personal data or for their privacy policies. For example, they may send their own cookies to users, collect data or solicit personal data from you. When you leave our site or social media account, we encourage you to read the privacy policy of every website, app and social media account that you use or visit.

When you contact us through our site, our social media accounts, communicate with us or visit our premises, you may provide us with personal data about you.

Personal data 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 for different purposes, which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, title, date of birth, gender and job title. The precise data collected will depend on whether you are an individual or a representative of a corporate entity or other organisation.
• Contact Data includes billing address, residential address, registered/trading address, email address and telephone numbers. The precise data collected will depend on whether you are an individual or a representative of a corporate entity or other organisation.
• Financial Data includes bank account and payment card details.
• Image Data includes individual images or general location images in which you might be visible.
• Matter Data includes any data generated by Shears Law or our clients, counter-parties or third parties in respect of any matter meaning any transaction, dispute or other situation in relation to which we are providing advice. This includes details about payments to and from you, personal data included in your communications with us and other details of services we have provided to you.
• Transaction Data includes details about payments to and from you and other details of products and 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. 
• Usage Data includes information about how you use our website, products and services. 
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Client Survey Data this includes queries or complaints, records of support requests, your responses to any market research we may send you, feedback and survey responses.

 

We may 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.

We do not collect any 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. 

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, or we are processing your personal data to fulfil a request you have made, 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 services) or we may not be able to otherwise comply with your request. In this case, we may have to cancel a service you have with us but we will use reasonable efforts to notify you if this is the case at the time. 

We use different methods to collect data from and about you including through:

Direct interaction. You may give us your Identity Data, Contact Data, Financial Data, Matter Data, Client Survey Data and Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

- ask us to supply our services;

- subscribe to our newsletter or publications; 

- request marketing to be sent to you;

- enter a competition, promotion or survey; or

- give us feedback or contact us. 

It is entirely up to you what personal data you provide, although if you withhold any relevant information our advice may be inadequate or inappropriate, or we may even have to decline to advise or continue providing our advice. However, if there is any indication of money laundering or terrorism financing by anyone, we may have to ask you for certain information and we will not be able to do any more work until you provide it. Your failure to provide it may trigger a report to the authorities. We will tell you when this is the case if we can, although the law may prevent us from doing so.

Automated technologies or interactions. As you interact with our site, we will 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 will receive personal data about you from various third parties and public sources as set out below in the followng sections entitled "How we use your personal data" and "Who do we share your personal data with". These include your organisation or persons associated with your organisation.

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 the contract we are about to enter into or have entered into with 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.

- Where we need to comply with a legal obligation.

Please refer to the Glossary at the end of this policy, to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data. We have set out below your rights in relation to marketing received from us (where we may have relied on your consent in some situations).

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 that legal basis has been relied on to process your personal data.

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 more specific details about the legal basis we are relying on to process your personal data, where more than one legal basis has been set out in the table below.

Purpose/Activity	Category of data	Legal basis for processing (including basis of legitimate interest and legal obligation)
COMPLIANCE Registering new clients and contacts / conducting know your client checks / SRA obligations
To register a new client Data obtained from you, third parties and official sources (e.g. where appropriate, details of company directorships and shareholdings from Companies House). Completing our file opening procedures, including avoiding conflicts of interest (i.e. between your interests and those of our other clients)	Identity Data Contact Data	Performance of Contract Legitimate Interest (to manage our business properly) Legal Obligation (SRA Standards and Regulations)
Credit Checking To obtain information from credit reference agencies, or credit checking services, about your ability to pay our charges, and then collecting and processing those charges	Identity Data Contact Data Financial Data	Legitimate Interest (to ensure we get paid promptly)
Reporting to the SRA and other regulators	Identity Data Contact Data Financial Data Matter Data	Legal Obligation (SRA Standards and Regulations)
Reporting to the National Crime Agency and other authorities Keeping records of your identity and affairs, assessing the likelihood that money laundering or terrorism financing might be taking place, and notifying the appropriate authorities if necessary.	Identity Data Contact Data Financial Data Matter Data	Legitimate Interest (to manage our business properly) Legal Obligation (if applicable, complying with our legal obligations under The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017)
Reporting to and sharing data with insurers and brokers	Identity Data Contact Data Financial Data Matter Data	Performance of Contract Legal Obligation (SRA Standards and Regulations)
PROVISION OF LEGAL SERVICES
To liaise with new contacts in relation to any quote or enquiries about our legal services	Identity Data Contact Data Matter Data	Performance of Contract (data collection necessary to take steps at your request prior to entering into a contract) Legitimate Interest (provision of legal services)
To provide our client with legal services	Identity Data Contact Data Matter Data	Performance of Contract Legitimate Interest (provision of legal services to client)
Correspondence with clients All correspondence, including sending you information in accordance with the SRA’s requirements.	Identity Data Contact Data Financial Data Matter Data	Performance of Contract Legitimate Interest (provision of legal services) Legal Obligation (SRA Standards and Regulations, when sending information required by the SRA)
To manage our relationship with our client	Identity Data Contact Data Financial Data Transaction Data Matter Data	Performance of Contract Legitimate Interest (provision of legal services and/or management of our relationship)
If you are an individual who is not our client but is connected to any matter on which we are advising, we may collect your personal data to communicate with you, your colleagues, representatives or in connection with your organisation or our client matters.	Identity Data Contact Data Financial Data Matter Data	Necessary for our legitimate interests and those of our clients to hold information about connected individuals when advising our client, and to communicate with you on behalf of our clients
Storing client records	Identity Data Contact Data Financial Data Matter Data	Performance of Contract Legitimate Interest (administering and managing our business properly)
FINANCE & BUSINESS ADMINISTRATION Billing clients; paying suppliers; bookkeeping; preparation of accounts; VAT returns; complaints handling and managing our business
Managing payments from and to clients	Identity Data Contact Data Financial Data Transaction Data Matter Data	Performance of Contract Legitimate Interest (to manage payments from and to our clients)
Collect and recover charges owed to us	Identity Data Contact Data Financial Data Transaction Data Matter Data	Legitimate Interest (to recover charges owed to us)
Managing payments to suppliers	Identity Data Contact Data Financial Data Matter Data	Performance of Contract Legitimate Interest (paying suppliers and managing our business properly)
Bookkeeping and preparation of accounts Maintaining records and effective accounting procedures, includes reasonable provision of non-confidential matter data to third party accountant as required.	Identity Data Contact Data Financial Data Matter Data	Legal obligation (SRA Standards and Regulations)  Legitimate Interest (administering and managing our business properly)
Filing with HMRC and any queries	Identity Data Contact Data Financial Data Matter Data	Legal Obligation (various primary and secondary tax legislation)
Obtaining insurances and liaising with insurers and brokers Obtaining and maintaining required insurances, includes reasonable provision of non-confidential matter data to third party insurers and brokers as required.	Identity Data Contact Data Financial Data Matter Data (Non-Confidential)	Legal Obligation (obtaining professional indemnity insurance and processing claims under the policy, this being necessary for complying with our legal obligations under the SRA Indemnity Insurance Rules 2013) Legitimate Interest (administering and managing the business properly and in obtaining and benefitting from this insurance cover)
Conducting strategic business planning about our services and our clients.	Identity Data Contact Data Financial Data Matter Data Client Service Data	Legitimate Interest (strategic business planning and maintaining quality standards of the practice)
To enable third party organisations to conduct audit or quality checks on our practice including those for the purposes of the Lexcel quality standard of the Law Society	Identity Data Contact Data Financial Data Matter Data Client Service Data	Legitimate Interest (maintaining quality standards of the practice)
To administer and protect our business (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity Data Contact Data Technical Data	Legitimate Interest (administering and protecting the business, provision of IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
Destruction of client files, personnel records, supplier information	Identity Data Contact Data Financial Data Matter Data	Legal Obligation (GDPR and Data Protection Act 2018)
Complaints Handling  Dealing properly and fairly with complaints. Includes provision of information to our third-party advisors in relation to those complaints our regulators where relevant, our insurance brokers and insurers.	Identity Data Contact Data Financial Data Matter Data Client Service Data	Performance of Contract Legal Obligation (under the SRA Standards and Regulations for solicitors) Legitimate Interest (to manage our business properly, maintain our relationships with our clients and other third parties and comply with our insurance obligations)
Defence against Claims Handling claims against the business. Includes provision of information in relation to our third-party advisors in relation to those claims, our insurance brokers and insurers.	Identity Data Contact Data Financial Data Matter Data Client Service Data	Legitimate Interest (to manage our business properly, maintain our relationships with our clients and other third parties and comply with our insurance obligations)
To notify you of changes to this policy	Identity Data Contact Data	Legal Obligation (to notify you of changes to this policy is a legal obligation under the GDPR)
To notify you of changes to any applicable terms of business	Identity Data Contact Data	Performance of Contract Legitimate Interest (managing and maintaining our relationship with you)
Sale or restructuring of the business  If we sell part or all of our business, or restructure our business, then we may disclose appropriate personal data about you as necessary for that purpose provided, we have in place appropriate confidentiality restrictions, which we have a legitimate interest to do.	Identity Data Contact Data Financial Data Matter Data Client Service Data	Legitimate Interest (in restructuring or selling the business. If our business, or part of it, should ever be put up for sale, or we re-structure our business, we may allow potential buyers or transferees, to have access to your personal data and matter files after they have signed confidentiality agreements which restrict their use of it to that transaction)
PROCUREMENT
If you or your organisation is a supplier, for agreeing our terms and managing our relationship with you	Identity Data Contact Data Financial Data	Performance of Contract Legitimate Interest (agreeing terms and managing our relationships with our suppliers)
MARKETING
To administer and maintain our website (including system maintenance, support and hosting of data)	Identity Data Contact Data Technical Data Usage Data Image Data	Legitimate Interest (administering and maintaining our website and services)
To use data analytics information provided by third parties (such as Google Analytics) to improve our website, services, marketing, client relationships and experiences	Technical Data Usage Data	Legitimate Interest (to define types of clients for our services, to improve and update our website, to develop our business and services and to inform our marketing strategy)
To complete legal directory submissions	Identity Data Contact Data Financial Data Matter Data Client Service Data	Legitimate Interest (to seek industry recognition, to promote and bench mark our business)
To market to clients and potential clients To deliver relevant website content, deliver marketing information to you and to measure or understand the effectiveness of the marketing we serve to you. To make suggestions and recommendations to you about goods or services that may be of interest to you	Identity Data Contact Data Technical Data Client Service Data Matter Data Marketing & Communications Data Image Data Usage Data	Legitimate Interest (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
Maintaining our social media accounts, including collecting information, communicating and marketing with individuals via those platforms. Where you interact with us via our social media accounts, we will receive information from those social media platforms about who you are, what action you took (such as liking, sharing or commenting on us or our content), any communications or content that you send to us or share with us via that platform, and when you interacted with us. We will use this information to interact with you via the relevant platform, or to contact you directly if requested.	Identity Data Contact Data Client Service Data Matter Data Marketing & Communications Data Usage Data	Legitimate Interest (to define types of customers for our products and services, to keep our website and social media accounts updated and relevant, to develop our business and to inform our marketing strategy) Please note that where you interact with social media functions on our website, you may provide information to those social media platforms about you, and where you have linked from. You should check the privacy policies of those platforms to understand how they process such data
We use an email marketing management platform. That platform provides information to us which helps us understand the effectiveness of an email campaign and plan future email campaigns. For example, it will tell us about whether you opened the email, what you clicked on, the email delivery status and geographic location.	Identity Data Contact Data Matter Data Client Service Data Marketing & Communications Data Usage Data	Legitimate Interest (to develop our products/services and grow our business while ensuring we do so in a compliant manner)
To enable you to partake in a competition or complete a survey	Identity Data Contact Data Matter Data Client Service Data Marketing & Communications Data Usage Data	Performance of Contract Legitimate Interest (to study how customers use our products/services, to develop them and grow our business)

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 would like to understand more about any of our purposes or, 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.

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.

Automated Decision-Making

We do not make any decisions which could have a legal effect, or other significant effect on you, based solely on automated processing of your personal data.

Important information about our marketing

We hope that you enjoy and value our newsletter and updates, and our marketing material generally.  We may send you this information by various means including, email, text message, post, telephone, or social media. We respect your right to choose what marketing messages you receive and we strive to provide you with choices regarding certain personal data uses, particularly around marketing. 

We may use your data as set out in the table above 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 and you have not opted out of receiving that marketing.

We do not share your personal data with any third party for them to contact you for their own marketing purposes.

Opting out

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or unsubscribe from our social media accounts or 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, 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 our cookies policy.

We may share your personal data with the parties set out below for the purposes set out in the table above “Purposes for which we will use your personal data”.

- Third Parties as set out in the Glossary below.

- Specific third parties listed in the table “Purposes for which we will use your personal data” 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 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.

We will not intentionally transfer your personal data outside the UK without ensuring appropriate safeguards are in place.

Whenever we transfer your personal data out of the UK, 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 UK government. 
• Where we use certain service providers, we may use specific contracts approved by the UK government which give personal data the same protection it has in the UK. 

 

Please note that we have no control over the routes emails take, and even emails exchanged between two people in the UK could appear on equipment in countries outside the UK, where they may not be protected by strong privacy or data protection laws. You will probably not consider this an issue, but if you have any concerns please raise them with us and we will make alternative arrangements.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK. 

Data Security is a priority for us. To help keep your personal data confidential, 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. These include: 

- “Cyber Essentials” certification which helps protect us against the most common cyber attacks

- “Lexcel” accreditation

- Our site uses a Secure Socket Layer certificate to protect data passing through it 

- A security policy, designed to protect data integrity and ensure proper levels of information security.

We have also put into 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.

Unfortunately, the transmission of information via the internet is not completely secure; information can be intercepted, lost, redirected, changed and read by other people. If you need to send us personal data securely then please contact us to discuss the best way to do this.  

Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site or via the social media accounts that we operate; any transmission is at your own risk. 

If you would like to know more about our data security measures please contact us.

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.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

Under certain circumstances, you have rights under data protection laws in relation to your personal data which we process as a controller. The key rights are set out below and you can find out more about these rights in the Glossary: 

- 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 could 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 could 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. 

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

THIRD PARTIES

- Service providers acting as processors who provide the following services: compliance advice and file reviews; IT and system administration services; case and content management; cloud storage and email; accounting and invoicing; storage; archiving; shredding; payment services (which are operated by our bank); web analytics; search and social media information and optimisation services.

- Professional advisers acting as processors, controllers or joint controllers including lawyers, barristers, accountants, bookkeepers, bankers, auditors, insurers and brokers who provide consultancy, banking, legal, insurance and accounting services.

- The Law Society of England and Wales for professional and Lexcel accreditation purposes.

- HM Revenue & Customs, Solicitors Regulation Authority, National Crime Agency, Legal Ombudsman and other regulators and authorities acting as processors, controllers or joint controllers (such as law enforcement bodies, government agencies, courts and other third parties) who require reporting of processing activities in certain circumstances or where we think it is necessary to comply with applicable laws or regulations, or to exercise, establish or defend our legal rights.

YOUR LEGAL RIGHTS IN RELATION TO YOUR PERSONAL DATA

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: 

- If you want us to establish the data's accuracy.

- Where our use of the data is unlawful but you do not want us to erase it.

- 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.

- 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.