1.Important information and who we are
The Website is not intended for children and we do not knowingly collect data relating to children.
For the purposes of the General Data Protection Regulation (EU) 2016/679 (“GDPR”), RBG Holdings is the controller and responsible for your personal data.
Registration with the Information Commissioner’s Office (“ICO”)
RBG Holdings is registered as a fee payer at the Information Commissioner’s Office with registration number is: ZA365637
Data protection manager
Robert Parker, CFO
- RBG Holdings plc, 9-13 St. Andrew Street, London EC4A 3AF
- +44 (0) 207 955 0880
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). Should you have any concerns about the handling of your data or privacy we would welcome the opportunity to address such concerns and give due consideration to any complaints submitted directly to us before any contact is made to the ICO.
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.
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).
Depending on the nature of our relationship with you or your use of the Website or our services, 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, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data
includes billing address, delivery address, email address and telephone numbers.
- Financial Data
includes bank account and payment card details.
- 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.
- Profile Data
includes your interests, preferences, feedback and survey responses.
- Usage Data
includes information about how you use this Website, products and services.
- Marketing and Communications Data
includes your preferences in receiving marketing from us and our third parties and your communication preferences.
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 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 legal services). In this case, we may have to cancel your engagement with us but we will notify you in advance.
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 personal data by completing forms (physical or digital) or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you subscribe to our services or to our marketing communications, request information to be sent to you, provide us feedback, or enter into a contract with us.
- Automated technologies or interactions.
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.
Generally we do not rely on consent as a legal basis for processing your personal data other than to send you our marketing communications. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below 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. Where applicable we have identified what our legitimate interests are in relation to the processing of your 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 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 client||(a) Identity|
|Performance of a contract with you|
|To process and deliver legal services to you, including:|
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(c) taking instructions, preparing and delivering advice
(e) Marketing and Communications
|(a) Performance of a contract with you|
(b) Necessary for our legitimate interests (to recover debts due to us)
(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 keep our records updated and to study how customers use our products/services)
|To administer and protect our business and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity|
|(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 use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical|
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
We strive to give you control over the processing of your data and provide you with choices regarding its use, particularly around marketing.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think may be of interest to you. This is how we decide which marketing communications we will send to you.
You will receive marketing communications from us if you have requested information from us, or if you provided us with your details at promotional event or similar networking occasion. In each case, you will only receive marketing communications if you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside the RBG Holdings plc group of companies for marketing purposes.
You can ask us or third parties to stop sending you marketing communications at any time.
Where you opt out of receiving marketing communications, this will not apply to personal data provided to us as a result of your working relationship with us.
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 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 be required to process your personal data without your knowledge or consent, in compliance with the above rules, where it is a legal obligation to do so.
5. Disclosures of your personal data
We may have to share your personal data with External Third Parties (defined in the Glossary below) for the purposes set out in the table in paragraph 4 above.
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.
6. International transfers
7. 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 will be required to use or access your personal data in order to perform their functions. They will only process your personal data on our instructions and they are subject to a strict 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.
8. Data retention
How long will you store my personal data for?
We will only retain your personal data for as long as necessary to fulfill 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.
By law we are required to keep certain information about our clients (including Contact, Identity, Financial and Transaction Data, but also in relation to your business matters) for minimum periods of time. In most cases, files held in our storage will normally be deleted after 7 years. For more information on our legal obligations to retain and store client data, please contact our Data Protection Manager as described above.
In some circumstances you can ask us to delete your data: see Request Erasure 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.
Please contact our Data Protection Manager if you would like more information on the retention periods for different categories of personal data.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
- 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
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 in such circumstances we may refuse to comply with your request.
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.
Legitimate Interest means the interest 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). 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.
External Third Parties
- Service providers acting as processors based in the United Kingdom, such as IT, business administration or marketing analytics services.
- Professional advisers acting as processors or joint controllers including lawyers, accountants, financial service providers, auditors, insurers and other third party consultants.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who may require reporting of processing activities in certain circumstances.
- Other third parties such as market researchers, fraud prevention agencies, price comparison sites.
YOUR LEGAL RIGHTS
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: (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.