Privacy and Cookies Policy

Turner Parkinson LLP: TP Deals Privacy and Cookies Policy (this “Policy”)

Introduction

We are Turner Parkinson, a business law firm based in Manchester. Turner Parkinson is a  trading name of Knights Professional Services Limited which is a Limited Company registered in England and Wales. Our registered office is The Brampton, Newcastle-under-Lyme, Staffordshire ST5 0QW.  Unless identified as non-regulated, all work carried out by us is authorised and regulated by the Solicitors' Regulation Authority of England and Wales under SRA ID number 620595.

This Policy is our privacy and cookies policy for our website, www.tpdeals.co.uk (the “Website”). In this Policy, we refer to Turner Parkinson LLP as “we”, “us” and “our”.

We respect your privacy and are committed to protecting your personal data. This Policy sets out how we look after your personal data when you visit the Website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

We may update this Policy from time to time. If we do, we will post a new version on the Website. You should check this page occasionally to ensure you are happy with any changes. We may also notify you of changes to the Policy by email if you have asked us to keep in touch with you by email.

This Policy was most recently updated on 24 May 2018.

1) Background

Why do we have this Policy?

This Policy is intended to tell you how we collect and process your personal data when you use the Website. This includes any data you may provide through the Website when you contact us in any way, such as when you submit an enquiry, or when you sign up to receive a newsletter or other communications from us.

You should read this Policy with any other privacy notice that we may give to you from time to time when we are collecting or processing personal data about you. Those privacy notices will ensure you are aware of how and why we are using your personal data, such as when you agree to be our client so that we can provide legal services to you. This Policy supplements the other privacy notices; it is not intended to override them.

We are a data controller

Turner Parkinson LLP is the data controller for any personal data that you provide through the Website. We are responsible for your personal data.

We have appointed a data protection partner, who is responsible for data protection compliance within our business, and for overseeing questions in relation to this Policy. If you have any questions about this Policy, or if you would like to exercise your legal rights under paragraph 12 below, please contact the data privacy manager using the details set out below:

Email address: dataprotection@tp.co.uk 

Postal address: Turner Parkinson, Hollins Chambers, 64a Bridge Street, Manchester, M3 3BA

If we provide you with legal services

This Policy applies to personal data we collect through the Website only. If you instruct us in respect of legal services, we will enter into a separate contract with you on the basis of our terms of business, and you will become our client. For information about our use of personal data provided to us by our clients, please see our terms of business, which will be provided to you at the commencement of any legal matter on which we act for you.

Making sure the information we hold about you is correct

It is important that the personal data we hold about you is accurate and current. Please get in touch if you think the personal data we hold about you needs to be updated during your relationship with us.

Third party information and links on the Website

The Website sometimes includes links to websites, plug-ins and applications owned or controlled by third parties. If you click on those links or enable those connections, third parties may be able to collect or share data about you, and they are not within are control. We are not responsible for their privacy statements. When you leave the Website, you should read the privacy notice of every other website or application that you visit.

2) 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, last name and username or similar identifier.
  • Contact Data includes email address and telephone numbers.
  • 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 the Website.
  • Profile Data includes your username and password, your interests, preferences and feedback.
  • Usage Data includes information about how you use the Website and the information available through it.
  • Communications Data includes your preferences in receiving marketing from us 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 Policy.

We do not collect any Special Categories of Personal Data about you through the Website (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 to provide you with information about our services (or, for example, a particular business), 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 provide you with information or perform the contract we have or are trying to enter into with you. In this case, we may have to cancel the contract and may not be able to provide certain information to you, but we will notify you if this is the case at the time.

3) 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 Communication Data by filling in forms or by corresponding with us through the Website or by post, phone, email or otherwise. This includes personal data you provide when you:
    • request information from us;
    • contact us for any reason;
    • register for an account on the Website;
    • subscribe to our service or publications;
    • request communications to be sent to you; or
    • give us feedback.
  • Automated technologies or interactions. As you interact with the Website, we may automatically collect Technical and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see paragraph 6 below for more information on our use of cookies.
  • 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:
      • (a) analytics providers such as Google based outside the EU;
      • (b) search information providers based inside the EU.
    • Contact Data from providers of technical services, such as Lead Forensics based inside the EU.
    • Identity and Contact Data from publicly availably sources such as Companies House based inside the EU.

4) How we use your personal data

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 or regulatory obligation.

See paragraph 13 to find out more about the types of lawful basis that we will rely on to process your personal data.

We do not usually rely on consent as a legal basis for processing your personal data. If, for any reason, we do rely on consent to process your personal data, you have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

The table below explains the ways in which we process your personal data, and the legal bases we rely on to do so. Where necessary, we have also identified our legitimate interests.

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 would like more details about the specific legal ground on which we are relying 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 register you for an account on the Website

(a) Identity

(b) Contact

(c) Profile

Performance of a contract with you

To manage our relationship with you which will include:

(a) Notifying you about changes to this Policy or our terms

(b) Providing you with information and documentation when you ask for it

(c) Contacting you when you have asked us to contact you

(a) Identity

(b) Contact

(c) Communications

(d) Profile

(a) Necessary to comply with a legal obligation

(b) Performance of a contract with you

(c) Necessary for our legitimate interests (to keep our records updated, and direct marketing)

To administer and protect our business and the Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) 

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant Website content to you and measure the effectiveness of that content

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Communications

(f) Technical

Necessary for our legitimate interests (to define types of customers for our products and services, to study how users use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve the Website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to keep the Website updated and relevant, to develop our business and to inform our marketing strategy)

To use IP address tracking technology to identify businesses visiting the Website and the specific Webpages that are being accessed.

(a) Technical

(b) Usage

Necessary for our legitimate interests (to keep the Website updated and relevant, to develop our business, to inform our marketing strategy, and to contact relevant businesses to discuss ways in which we may be able to provide services to them).

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

Necessary for our legitimate interests (to develop our products/services 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 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.

5) Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:

Communications of interest

We may use your Identity, Contact, Technical, Communications, Profile and Usage 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 services may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or received legal services from us, 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 third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the Website and checking or unchecking relevant boxes to adjust your marketing preferences, or by following the opt-out links on any marketing message sent to you 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 instructing us in respect of legal services, or other transactions.

6) Cookies

The Website uses cookies. Cookies are tiny text files which identify your computer to our server as a unique user when you visit certain pages on the Website and they are stored by your Internet browser on your computer's hard drive. Cookies can be used to recognise your Internet Protocol address, saving you time while you are on the Website. 

We only use cookies for your convenience in using the Website and not for obtaining or using any other information about you (for example targeted advertising). Your browser can be set to not accept cookies, but this would restrict your use of the Website. 

If you want to find out more information about cookies, go to http://www.allaboutcookies.org or to find out about removing them from your browser, go to http://www.allaboutcookies.org/manage-cookies/index.html.

Please note that we collect data from the Website about use of the Website using a web analysis tool which uses cookies that are (able to be) used to generate pseudonyms for a user’s profile. This means that use cookies (which may be stored on your computer after you leave the Website) can store information about your visit.

The Website uses the following cookies:

Name

Expiration date

Purpose

__utma

2 years

Google Analytics

__utmb

30 minutes

Google Analytics

__utmc

Session

Google Analytics

__utmz

6 months

Google Analytics

Google Analytics allows us to recognise and count the number of visitors to the Website and to see how visitors move around the Website when they are using it. This helps us to improve the way the Website works, for example by ensuring that users are finding what they are looking for easily.

7) 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 paragraph 13 below.
  • External Third Parties as set out in paragraph 13 below.
  • 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 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.

8) International transfers

We do not transfer your personal data outside the European Economic Area.

9) 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.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Website; any such transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to try to prevent unauthorised access

10) How long we use your 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.

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 paragraph 12 below for further information.

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

11) Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

  • 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.

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.

Your right to make a complaint to the ICO

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

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 our corporate group acting as joint controllers or processors and who are based the UK and provide IT and system administration services and undertake leadership reporting.

External Third Parties

  • Service providers acting as processors based in the UK who provide IT and system administration services.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.