Privacy policy

Last updated: 17 April 2018

Introduction 

Club Vita LLP is committed to protecting and respecting your privacy. Under data protection laws, we are the data controller in relation to your personal information. This means we are responsible for deciding what information to collect about you and how it is used. Our contact details are set out in the Contacting Us (section 8) of this privacy notice. 

This notice explains what personal information we collect about you, how and why we use it, who we disclose it to, and how we protect it. 

It applies to you if you use our website, sign up for events, subscribe to our publications or contact us with an enquiry using the forms on our website or by email. It also applies to you if we have a professional or business relationship or connection with you. 

Our website is directed to, and for use by, our clients, prospective clients and professional and business contacts in the United Kingdom. It does not concern the provision of scheme membership data through the ‘Members Area’ of this website. 

What are the data protection laws? 

The Data Protection Act 1998 contains most of the rules about how personal information should be collected and processed. It is being replaced on 25 May 2018 by the EU General Data Protection Regulation (GDPR). Other rules exist which govern things like email direct marketing. This privacy notice takes account of all of the rules, including GDPR. We will keep it under review – please see Changes to this privacy notice (section 10). 

What is personal information?

Personal information broadly means information about a living individual who can be identified from that information directly, or indirectly (for example if it is combined with other available information).

Content

  1. What personal information do we collect?
  2. Using your personal information
  3. What is the lawful basis for processing?
  4. Sharing your personal information with others
  5. How we protect your personal information
  6. How long we keep your personal information
  7. Your rights
  8. Contacting us
  9. Contacting the Information Commissioner’s Office
  10. Changes to this privacy notice

1. What personal information do we collect?

We will collect the following information about you:

  • Visitors to our website. We use Google Analytics and Click Dimensions to collect information about visitors to our website. This information won’t be used to identify you unless you submit your contact details via the website, where we may then connect your prior activity on our website with your personal information.
  • People who use our services (for example registering for events or downloading publications) or contact us with an enquiry. We’ll collect the information you submit via our website or when you contact us, for example your name, contact details, details about the service you’re interested in or your enquiry.
  • Business contacts. We’ll collect your contact details, information about your work or personal circumstances and your interests, where you disclose them to anyone who works for us in a professional or business setting, for example at networking events. We’ll also collect information from social media that is available publicly or if you connect with anyone who works for us.
  • Clients, prospective clients and related persons. We’ll collect information about the identity of clients and prospective clients and (where relevant) shareholders, beneficial owners, management, directors, officers and trustees and other related persons for verification and anti-money laundering purposes. This information will be collected from you or online sources or both.

We will always try to keep the amount of personal information we collect to the minimum needed.

We use cookies on our website – please read our cookies policy to find out more.

2. Using your personal information

We use your personal information for the following purposes:

  • Providing website features. We’ll use information we collect to help ensure that content from our site is presented in the most effective manner for you and for your computer, allow you to participate in interactive features of our website, and monitor how our website is used, in order to improve it.
  • Providing our services or responding to your enquiry. We use the information you provide the service you’ve requested, for example to process your registration for an event, so that we can contact you about the event you have registered for, or to send you a link to, or copy of the publication that you’ve requested. If you send us a general enquiry, we’ll forward it to the relevant department who will use your information to respond to you about your enquiry.
  • Direct marketing. If you are a professional or business contact, client or prospective client, we’ll use your business contact details to send you direct marketing communications which you have subscribed to or which we feel may be relevant and of interest you as well as information about events, thought leadership and topical updates. You can update your preferences or unsubscribe from our communications at any time. To do so, simply:
    • get in touch with us via our website or the contact details below.
    • visit our preference centre and confirm your preferences, or
    • click the “update your preferences” or “unsubscribe” link in the communication that you’ve received from us, or

We may also contact you by post or phone, unless you ask us not to.

Identification checks (clients, prospective clients and related persons). We are obliged to verify the identity of prospective and (in some circumstances) existing clients. This involves checking the identity and good standing of clients and related persons.

3. What is the lawful basis for processing?

In general, we do not require your consent to process your personal information because the processing is necessary:

  • in order to provide you with the information or services that you’ve requested, or
  • in order to respond to your enquiry, submitted via the website or by email, or
  • for our legitimate interests, which are to develop and diversify our business and to provide us with insight into the types of people who use our services (this basis applies to business-to-business direct marketing in particular), or
  • in order to comply with the law.

However you do have the right to object to how we process your personal information, or ask us to restrict processing.

We do not generally collect “sensitive personal data” or “special categories of data” where the rules about how we process it are stricter.

If you object to or ask us to restrict the processing of your personal information, this won’t affect the lawfulness of the processing we’ve already carried out.

Please see the Your rights (section 7) for more details.

4. Sharing your personal information with others

Sometimes we need to share your personal information with others. We’ll only do this where necessary and we’ll take steps to ensure they keep the information secure and confidential and use it only for the agreed purposes.

We may share your personal information with the following:

  • with any member of our group, for the purposes of providing information or services and developing our business relationship with you,
  • our service providers, for example those providing support, maintenance and troubleshooting services for our IT services and platforms or who assist in maintaining the security and performance of our websites, so that we can run our business,
  • regulators (including the Financial Conduct Authority), ombudsmen, dispute resolution bodies, government bodies or the courts, where we are under a legal obligation to do so, or to protect our rights or property, or the safety of our people, clients or others, so that we can meet our legal obligations.

Some of these may be located outside the European Economic Area, where data protection laws are different. However we will ensure that adequate safeguards are in place (for example, robust contracts) to make sure your personal information is protected.

5. How we protect your personal information

We employ up to date technologies and systems to protect your personal information from unauthorised disclosure or damage or misuse.  We ensure that our staff receive regulation training about information security and data protection. We meet the ISO27001:2013 standard for information security management systems.

We regularly review all our systems, policies and technologies to ensure that these continue to work effectively to protect your personal information.

6. How long we keep your personal information

We will keep your personal information for as long as we are using it for the purposes explained in this notice.

When we no longer need it, we will archive your personal information after a certain period (usually 7 years), and then delete it permanently after an additional period (usually 13 years).

We set these periods according to the time limits on legal claims. This is for our protection and yours.

We may in certain circumstances need to hold your personal information for longer, for example in relation to a legal dispute or because of regulatory requirements.

7. Your rights

You have a number of rights under data protection laws. These are:

  • to request access your personal information,
  • to request that your personal information corrected if it is out of date, inaccurate or incomplete,
  • to request that your personal information is deleted or removed from our records and systems,
  • to make a complaint to the Information Commissioner’s Office.

You also have the right:

  • to withdraw your consent to the processing of your personal information (where we need your consent to process your personal information),
  • to object to or restrict the processing of your personal information (where we don’t need your consent to process your personal information),
  • to obtain an electronic file of your personal information or have it transferred to another data controller in limited circumstances.

How do I exercise my rights?

If you would like to make a request to access or correct your personal information, or to exercise any of your other rights, you can contact us at any time using the details set out in Contacting Us (section 8).

We will respond to any request received from you within one month from the day we receive your request.

Please note that some of your rights are restricted, and apply only in certain circumstances. For example, we may refuse to delete your personal information whilst we need it for a valid purpose, including to defend any potential legal claims. We will set out in our response our reasons if we are unable to meet your request.

To find out how to make a complaint to the Information Commissioner’s Office, see Contacting the Information Commissioner’s Office.

8. Contacting Us

You can email: enquiries@clubvita.co.uk. You can also write to us at: Club Vita LLP, One London Wall, London, EC2Y 5EA.

If you have any queries about how we use your personal information you can contact the Data Protection Officer through any of the following means:

By Post: Club Vita LLP, Exchange Place One, 1 Semple Street, Edinburgh, EH3 8BL

By email: dataprotection@clubvita.co.uk

By phone: 0131 656 5000

9. Contacting the Information Commissioner’s Office

The Information Commissioner’s Office (ICO) is the UK's independent body set up to uphold information rights.  You can find out more about the ICO on its website.

The ICO can be contacted on 0303 123 1113, by using the email form on its website, or by writing to:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

10. Changes to this privacy notice

This privacy notice is current as at April 2018. We may make changes from time to time and you should regularly check for updates.

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