Privacy policy

This is Furley Page’s Privacy Policy which sets out how we handle information.

We respect your privacy and are committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.

1. Purpose of this Privacy Policy

This Privacy Policy aims to give you information on how we collect and process your personal data, including any data you may provide through our website when you contact us, sign up to our mailing list, instruct us or use our services.

It is important that you read this Privacy Policy so that you are fully aware of how and why we use your data.

2. Controller

Furley Page LLP (referred to as we, us or our) is the controller and responsible for your personal data.

Furley Page is a limited liability partnership registered in England and Wales with registration number OC317755 and is authorised and regulated by the Solicitors Regulation Authority.

We have appointed a Data Protection Officer who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, these should be made in writing and marked for the attention of the Data Protection Officer and sent to our registered office at 39 St Margaret’s Street, Canterbury, Kent, CT1 2TX or emailed to us at dpo@furleypage.co.uk

3. Changes to the Privacy Policy and your duty to inform us of changes

We keep this privacy policy under review and may change it from time to time.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes.

4. Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the Privacy Policy of every website you visit.

5.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:

  1. Identity Data: this includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender;
  2. Contact Data: this includes postal and email addresses and telephone numbers;
  3. Financial Data: this includes bank account and payment details;
  4. Transaction Data: this includes details about payments to and from you and other details of the services you purchase from us;
  5. Technical Data: this 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;
  6. Profile Data: this includes your username and password, your preferences and feedback responses;
  7. Usage Data: this includes information about how you use our website, products and services; and
  8. Marketing and Communications Data: this 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 Privacy Policy.

In certain limited circumstances we may collect 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) and information about criminal convictions and offences. We will only process special categories of personal data where you are looking to or have instructed us to provide you with legal services and where it is necessary for us to process those special categories of personal data to give effect to those instructions and to provide you with legal advice.

6. If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you.

7. How is your personal data collected?

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

  1. Direct interactions: You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    1. contact us;
    2. instruct us to provide you with legal services;
    3. subscribe to our publications;
    4. request marketing material; or
    5. provide us with feedback or agree to recommend us.
  2. Automated technologies or interactions: As you interact with our website, we may 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. Please see our Cookie Policy for further details.
  3. Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
    1. Technical Data from:
      1. analytics providers such as Google (based outside the EU) and Hotjar;
      2. advertising networks such as Google ads tracking; and
      3. search information providers such as Infinity call tracking and Mailchimp tracking.
    2. Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside the EU.
    3. Identity and Contact Data from data brokers or aggregators based inside the EU.
    4. Identity and Contact Data from publicly availably sources based inside the EU.

8. 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:

  1. Where we need to perform the contract we are about to enter into or have entered into with you where processing your personal data 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.
  2. Where processing your personal data is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Legitimate interests mean the interests of our business in conducting and managing our business to enable us to give you the best service 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).
  3. Where it is necessary for us to process your personal data to comply with a legal or regulatory obligation that we are subject to. Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.

9. Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new client (a) Identity
(b) Contact
(c) Financial
Performance of a contract with you
To process your instructions and to provide you with legal services including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or Privacy Policy
(b) Asking you to leave a review or to provide feedback
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests
To administer and protect our business and our 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
(b) Necessary to comply with a legal obligation
To deliver relevant website content to you (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for our legitimate interests
To use data analytics to improve our website and user experiences (a) Technical
(b) Usage
Necessary for our legitimate interests
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

 

10. Marketing

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

We may use your Identity, Contact, Technical, Usage and Profile Data to send you information that we think may be of interest to you.

You may receive marketing communications from us if:

  1. you have requested information from us; or
  2. used our services; or
  3. if you provided us with your details;
  4. or registered with us to receive marketing material;

and, in each case, you have not opted out of receiving that marketing.

11. Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside Furley Page for marketing purposes.

12. Opting out

You can ask us to stop sending you marketing material at any time by writing to us at our registered office, by email to dpo@furleypage.co.uk or by following the opt-out links on any marketing message sent to you.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of an instruction to us for the provision of legal services.

13. 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 Cookie Policy.

14. 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 at dpo@furleypage.co.uk.

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 or where we need to comply with a legal or regulatory obligation where this is required or permitted by law.

15. 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 9 above:

  1. Third Parties acting as processors or joint controllers where you are looking to or have instructed us to provide you with legal services and where it is necessary for us to share your personal data to give effect to those instructions and to provide you with legal advice;
  2. Service providers acting as processors or joint controllers based in England and Wales who provide archiving, file storage and data erasure or destruction services, credit references and search agencies, identity verification services and IT and system administration services;
  3. Professional advisers acting as processors or joint controllers including accountants, lawyers, bankers, financial advisors, auditors and insurers based in England and Wales who provide consultancy, banking, financial, legal, insurance and accounting services;
  4. 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;
  5. 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 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.

16. International transfers

We do not transfer your personal data outside the UK.

17. 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.

18. Data retention – How long will you use my 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. By law we have to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for at least six years after they cease being clients for tax purposes.

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.

In some circumstances you can ask us to delete your data. Please see the heading ‘Request erasure of your personal data‘ below for further information.

19. Your legal rights

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

  1. Request access to your personal data
    Commonly known as a “data subject access request” a request to access your personal data enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  2. Request correction of your personal data
    A request to correct the personal data that we hold about you 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.
  3. Request erasure of your personal data
    A request to erase your personal data 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, 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 for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  4. Object to processing of your personal data
    You may object to Furley Page processing 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.
  5. Request restriction of processing your personal data
    A request to restrict the processing of your personal data enables you to ask us to suspend the processing of your personal data in the following scenarios:

    1. if you want us to establish the data’s accuracy;
    2. where our use of the data is unlawful but you do not want us to erase it;
    3. 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
    4. you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  6. Request transfer of your personal data
    You may 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 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.
  7. Right to withdraw consent
    You may withdraw your consent to Furley Page processing your personal data 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 services to you. We will advise you if this is the case at the time you withdraw your consent.
  8. Right to Complain to the Information Commissioner
    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 (ico.org.uk). We would, however, appreciate the chance to deal with any concerns you may have before you approach the ICO so would recommend that you contact us in the first instance.

If you wish to exercise any of your legal rights as set out above, this should be done in writing and marked for the attention of the Data Protection Officer and sent to our registered office at Furley Page LLP, 39 St Margaret’s Street, Canterbury, Kent, CT1 2TX or emailed to us at dpo@furleypage.co.uk.

20. 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, excessive or vexatious. Alternatively, we may refuse to comply with your request in these circumstances.

21. 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.

22. 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.

 

This Privacy Policy was last updated on 8 January 2021.

Historic versions can be obtained by contacting us.