Privacy policy

1. Introduction

1.1 We are committed to safeguarding the privacy of our website visitors and service users.

1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.

1.3 We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.

1.4 In this policy, “we”, “us” and “our” refer to EP Partners Ltd. See Section 17 for further information.

2. How we use your personal data

2.1 In this Section 2 we have set out:

• (a) the general categories of personal data that we may process;

• (b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;

• (c) the purposes for which we may process personal data; and

• (d) the legal bases of the processing.

2.2 We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

2.3 We may process information that you post for publication on our website or through our services (“publication data”). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

2.4 We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant services to you. The legal basis for this processing is consent.

2.5 We may process information relating to our customer relationships, including customer contact information (“customer relationship data”). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is consent.

2.6 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.

2.7 We may process information contained in or relating to any communication that you send to us (“communication data”). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The communication data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely communications with our website visitors and service users and the proper administration of our website and business.

2.8 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

2.9 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

2.10 Please do not supply any other person’s personal data to us, unless we prompt you to do so.

3. Providing your personal data to others

3.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

3.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

3.3 Your personal data held in our website database will be stored on the servers of our hosting services providers.

3.4 We may disclose your personal data to our suppliers or subcontractors insofar as reasonably necessary.

3.5 We may disclose your enquiry data to one or more of those selected third-party suppliers of goods and services identified on our website for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party’s use of your personal data.

3.6 In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4. Retaining and deleting personal data

4.1 This Section 4 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

4.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

4.3 We will retain your personal data as follows:

• (a) usage data will be retained for a maximum period of 3 years following that date;

• (b) account data will be retained for a maximum period of 1 year following that date;

• (c) publication data will be retained for a minimum period of 1 year following the date when the relevant publication ceases to be published on our website or through our services, and for a maximum period of 3 years following that date;

• (d) enquiry data will be retained for a maximum period of 3 years following that date;

• (e) customer relationship data will be retained for a minimum period of 1 year following the termination of the relevant customer relationship, and for a maximum period of 3 years following that date;

• (f) communication data will be retained for a maximum period of 3 years following that date.

4.4 Notwithstanding the other provisions of this Section 4, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

5. Security of personal data

5.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.

6. Your rights

6.1 In this Section 6, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

6.2 Your principal rights under data protection law are:

• (a) the right to access – you can ask for copies of your personal data;

• (b) the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;

• (c) the right to erasure – you can ask us to erase your personal data;

• (d) the right to restrict processing – you can ask us to restrict the processing of your personal data;

• (e) the right to object to processing – you can object to the processing of your personal data;

• (f) the right to data portability – you can ask that we transfer your personal data to another organisation or to you;

• (g) the right to complain to a supervisory authority – you can complain about our processing of your personal data; and

• (h) the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

6.3–6.12 (retain full text — numbering correct)

7. Third-party websites

7.1 Our website includes hyperlinks to, and details of, third-party websites.

7.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.

8. Personal data of children

8.1 Our website and services are targeted at persons over the age of 16.

8.2 If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.

9. Updating information

9.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.