Hello and welcome to our privacy policy.  The Legal Strategist Limited (trading as Laura Brunnen) (the “Company”, “LB”, “our”, “us” and/or “we”) respects your privacy and is committed to protecting your personal data. 

As a business based in the UK dealing mainly with UK based businesses we are primarily required to comply with the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) (“UK GDPR”) and the Data Protection Act 2018 (“DPA 2018”). We also comply with the General Regulation of the European Parliament and the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“EU GDPR”).

In this policy, you will find out how we take care of your personal data when you visit www.laurabrunnen.com (“website”) , email or text us or speak to us - in person, virtually, or electronically over Facebook (Laura Brunnen The Legal Strategist, LegalEASE™ with Laura Brunnen and/or Laura Brunnen), LinkedIn (Laura Brunnen), Instagram (@Iamlaurabrunnen) and any other social media platform.  You can also find out about your privacy rights and how the law protects you.

LB is a business to business legal consulting and education business.  Neither this website nor the services provided by LB are intended for children under the age of 18 or for “consumers” (as defined in the Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013 and the Consumer Rights Act 2015) and we do not knowingly collect data relating to children or consumers.

By continuing to use this website and/or interact with us, you confirm that you:

Are older than 18 

AND

are accessing this site and/or interacting and engaging with LB in the course of your trade, business, craft or profession.

Accept this Privacy Policy and that you agree to comply with it.

If you do NOT agree, you must not use or access our site or engage with us in any way.

The Highlights

Your personal data is valuable and belongs to you. Whilst third parties - such as LB - are allowed under certain circumstances to collect and use your personal data, you can in many circumstances tell us not to use it and/or to erase it from our systems. This is subject to a few exceptions which are discussed below at “4. Your Privacy rights and Choices”

1.

IMPORTANT INFORMATION and WHO WE ARE

2.

PERSONAL DATA COLLECTION: WHAT, WHEN AND WHY

3.

WHO WE SHARE YOUR PERSONAL DATA WITH

4.

YOUR PRIVACY RIGHTS AND CHOICES

5.

HOW WE HANDLE YOUR PERSONAL DATA

1. IMPORTANT INFORMATION AND WHO WE ARE

1.1 Purpose of this privacy policy

This privacy policy explains how LB collects and processes your personal data through your use of this website and/or other interactions and engagement with LB or its directors and employees (whether as a client or otherwise).   

Data Controller

LB is registered as a data controller at the UK Information Commissioner’s Office under number ZB088150. 

This means we are responsible for your personal data and determine how and why it is used.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact us at:

The Legal Strategist Limited
71-75 Shelton Street,
Covent Garden
London
WC2H 9JQ

Registered number: 13275690

[email protected]

1.2 Your right to complain

If you are unhappy with how we deal with your personal data you can make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk).

Please do let us address your concerns first and email us at [email protected].

1.3 Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 28 June 2021.

It is important that the personal data we hold about you is accurate and current so do drop us an email with any changes at [email protected] (subject line “Personal data update”).

1.4 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.

2. PERSONAL DATA COLLECTION: WHAT, WHEN AND WHY

“Personal data” 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).

2.1 What personal data we collect

When you engage with us, we collect the following categories of personal data:

Identity and Contact Data

Includes first name, last name, username or similar identifier, job title and other information in your email signature, address, email address and telephone number

Financial Data

Includes bank account and payment card details

Transaction Data

Includes details of products and services purchased or received 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 and Usage Data

Includes your username and password, purchases made, your interests, preferences, feedback and survey responses, information about how you use our site, products and services

Communications Data

Includes data in all communications and interactions, when you email, text or speak to us or join our events - in person,  virtually, or electronically over Facebook, Instagram or LinkedIn, or other social media platforms.  

This includes photographs, audio and/or video recordings (we will notify you beforehand and you can choose whether to participate)

Social Media Data

Includes name, profile picture and other personal information you may share on a social media platform such as Facebook, Instagram or LinkedIn (subject to your privacy settings)

Marketing Data

Includes your preferences in receiving marketing from us and our third parties and your communication preferences

Business Data

Includes any personal data that relates to the business that engages with us or is embedded into business documents and/or contracts that you may ask us to review and advise on

2.2 Other data

 

Aggregated Data

We collect and use “Aggregated Data” such as statistical or demographic data and this is not considered personal data in law.

 We may combine or connect Aggregated Data with your personal data and will treat that combined data as personal data which will be used in accordance with this privacy policy.

Special Categories of Personal Data

We do not collect, control or process details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, your health, or genetic and biometric data.

We do not collect, control or process details about criminal convictions and offences.

2.3 If you don’t 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 don’t provide it when asked, 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 services). 

In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time. 

2.4 Lawful basis for processing personal data

There are 6 lawful grounds for legitimate processing of personal data, but LB generally relies on 3 of them:

Your Consent

You have provided clear and express consent for us to process your personal data. 

We will use the data for that specific purpose only.

We usually do not rely on consent to process your personal data, but if we want to send you marketing messages by email, text or social media, we will ask for your permission first.

You can withdraw this permission at any time just by:

contacting us at
[email protected] 

OR

clicking “unsubscribe” in a marketing email

Our Legitimate Interests

In order to protect our legitimate interests (or those of a third party) in conducting and managing our business, we sometimes need to use your personal data.  

We can only rely on this purpose if it doesn’t override your rights and interests.

Our legitimate interests include: 

Providing our service and running the LB business

Marketing the LB business (including through responding to messages and holding events)

Improving the quality of our service, marketing and the overall LB experience

Targeting our marketing ads and reviewing marketing analytics

Enhancing security of our data, systems and website

Learning how you use our website

To Perform our Contract

If you are a client or wish to become one, we need to process your data in order to:

Provide the LB services and products under the terms of our contract with you

Provide customer support

Collect payment for services and products

From time to time we may also need to collect and retain your personal data to comply with a legal obligation that we are subject to.

2.5 Personal data collection: when, what, why

Below is an overview of when LB collects personal data, what we collect and why, and the lawful ground(s) that we rely on. 

Not every lawful ground will apply in every circumstance.  For example if you complete a form  when we are providing you with a service we could be relying on Contract as the lawful basis.  On the other hand, if you complete a form in order to receive free resources, then we would be relying on Consent. 

WHEN WE COLLECT DATA

WHAT DATA WE COLLECT

WHY WE COLLECT DATA

LAWFUL  GROUND(S)

You complete a form

 

Identity and Contact Data
Marketing Data

Social Media Data

 

Client onboarding
Customer support
Improving LB experience

Marketing

Provision of LB services

Consent
Contract 

Legitimate Interests

You communicate with us by post, phone, email, online (including on social media) or otherwise

Business Data

Communications Data

Identity and Contact Data 

Social Media Data

Transaction Data

Client onboarding
Customer support
Improving LB experience

Marketing

Provision of LB services

Running the LB business

Consent
Contract

Legitimate Interests

You download free resources

Identity and Contact Data
Profile and Usage Data

Marketing Data

Technical Data

Transaction Data

Identity and Contact Data
Profile and Usage Data

Marketing Data

Technical Data

Transaction Data

Consent

Legitimate Interests

You purchase or apply for our services on behalf of your business

Business Data

Communications Data

Financial Data
Identity and Contact Data

Profile and Usage Data
Transaction Data

Transaction Data

Client Onboarding
Processing payments
Provision of LB services
Running the LB business

Consent

Contract

Legitimate Interest

You create an account on our website

Business Data

Communications Data

Financial Data
Identity and Contact Data
Marketing Data

Profile and Usage Data
Technical Data
Transaction Data

Client Onboarding

Provision of LB services

Consent
Contract

Legitimate Interests

You request marketing to be sent to you

Business Data
Communications Data
Identity and Contact Data

Marketing Data
Profile and Usage Data

Transaction Data

Consent
Contract

Legitimate Interests

Improving LB experience
Marketing

Consent

Legitimate Interests

You enter a competition, promotion or survey

Identity and Contact Data

Transaction Data
Profile and Usage Data

Marketing Data

Improving LB experience
Marketing

Consent

Legitimate Interests

You give us feedback or contact us

Communications Data
Identity and Contact Data

Transaction Data
Profile and Usage Data

Marketing Data

Customer support
Improving LB experience
Marketing
Provision of LB services

Consent
Contract

Legitimate Interests

You attend an event (virtual or live)

Communications Data
Identity and Contact Data

Transaction Data
Profile and Usage Data

Marketing Data

Marketing
Provision of LB services

Consent
Contract

Legitimate Interests

You interact with our website

Technical Data
See our cookie policy for more information

Client Onboarding
Customer support
Improving LB experience
Marketing
Provision of LB services
Website and systems security

Consent

Legitimate Interests

You supply goods or services to LB

Business Data Communications Data
Identity and Contact Data

Transaction Data
Profile and Usage Data

Marketing Data

Improving LB experience

Provision of LB services
Running the LB business

Consent

Legitimate Interests

Most of the data we collect is provided directly by you.  However, we do also obtain data from 3rd party suppliers (such as Paypal and Stripe) and publicly available sources (such as Companies House, the Electoral roll and websites).

2.6 Marketing 

To provide you with choices regarding certain personal data uses (particularly around marketing and advertising) we have established the following personal data control mechanisms:

Promotional offers from us

We may use your personal data to form a view on what services, products and offers we think may be of interest..

You will receive marketing communications from us if:

you have requested information, downloaded resources or purchased services from us 

AND 

you have not opted out of receiving that marketing.

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.

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

Opting out

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing email OR by contacting us at any time. 

Where you opt out, this will not apply to personal data provided to us as a result of a purchase or other transaction.

Third-party marketing

We do not sell or provide your personal data to third parties for marketing purposes.

No knowledge or consent

We may process your personal data without your knowledge or consent, in compliance with the above rules if required or allowed by law.

“Personal data” 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).

2.1 What personal data we collect

When you engage with us, we collect the following categories of personal data:

Identity and Contact Data

Includes first name, last name, username or similar identifier, job title and other information in your email signature, address, email address and telephone number

Financial Data

Includes bank account and payment card details

Transaction Data

Includes details of products and services purchased or received 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 and Usage Data

Includes your username and password, purchases made, your interests, preferences, feedback and survey responses, information about how you use our site, products and services

Communications Data

Includes data in all communications and interactions, when you email, text or speak to us or join our events - in person,  virtually, or electronically over Facebook, Instagram or LinkedIn, or other social media platforms.  

This includes photographs, audio and/or video recordings (we will notify you beforehand and you can choose whether to participate)

Social Media Data

Includes name, profile picture and other personal information you may share on a social media platform such as Facebook, Instagram or LinkedIn (subject to your privacy settings)

Marketing Data

Includes your preferences in receiving marketing from us and our third parties and your communication preferences

Business Data

Includes any personal data that relates to the business that engages with us or is embedded into business documents and/or contracts that you may ask us to review and advise on

2.2 Other data

 

Aggregated Data

We collect and use “Aggregated Data” such as statistical or demographic data and this is not considered personal data in law.

 We may combine or connect Aggregated Data with your personal data and will treat that combined data as personal data which will be used in accordance with this privacy policy.

Special Categories of Personal Data

We do not collect, control or process details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, your health, or genetic and biometric data.

We do not collect, control or process details about criminal convictions and offences.

2.3 If you don’t 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 don’t provide it when asked, 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 services). 

In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time. 

2.4 Lawful basis for processing personal data

There are 6 lawful grounds for legitimate processing of personal data, but LB generally relies on 3 of them:

Your Consent

You have provided clear and express consent for us to process your personal data. 

We will use the data for that specific purpose only.

We usually do not rely on consent to process your personal data, but if we want to send you marketing messages by email, text or social media, we will ask for your permission first.

You can withdraw this permission at any time just by:

contacting us at
[email protected] 

OR

clicking “unsubscribe” in a marketing email

Our Legitimate Interests

In order to protect our legitimate interests (or those of a third party) in conducting and managing our business, we sometimes need to use your personal data.  

We can only rely on this purpose if it doesn’t override your rights and interests.

Our legitimate interests include: 

Providing our service and running the LB business

Marketing the LB business (including through responding to messages and holding events)

Improving the quality of our service, marketing and the overall LB experience

Targeting our marketing ads and reviewing marketing analytics

Enhancing security of our data, systems and website

Learning how you use our website

To Perform our Contract

If you are a client or wish to become one, we need to process your data in order to:

Provide the LB services and products under the terms of our contract with you

Provide customer support

Collect payment for services and products

From time to time we may also need to collect and retain your personal data to comply with a legal obligation that we are subject to.

2.5 Personal data collection: when, what, why

Below is an overview of when LB collects personal data, what we collect and why, and the lawful ground(s) that we rely on. 

Not every lawful ground will apply in every circumstance.  For example if you complete a form  when we are providing you with a service we could be relying on Contract as the lawful basis.  On the other hand, if you complete a form in order to receive free resources, then we would be relying on Consent. 

1. You complete a form: we collect Identity and Contact Data, Marketing Data, Social Media Data for the purposes of Client onboarding, Customer support , Improving LB experience, Marketing and Provision of LB services.  Our lawful grounds are Consent, Contract and Legitimate Interests.

2. You communicate with us by post, phone, email, online (including on social media) or otherwise:  we collect Business Data, Communications Data, Identity and Contact Data, Social Media Data and Transaction Data for the purposes of Client onboarding, Customer support , Improving LB experience, Marketing, Provision of LB services and Running the LB business.  Our lawful grounds are Consent, Contract and Legitimate Interests.

3. You download free resources: we collect Identity and Contact Data, Profile and Usage Data, Marketing Data, Technical Data and Transaction Data for the purposes of Customer support , Improving LB experience and Marketing.  Our lawful grounds are Consent and Legitimate Interests.

4. You purchase or apply for our services on behalf of your business: we collect Business Data, Communications Data, Financial Data, Identity and Contact Data, Profile and Usage Data and Transaction Data for the purposes of Client onboarding, Processing payments, Provision of LB services and Running the LB business.  Our lawful grounds are Consent, Contract and Legitimate Interests.

5. You create an account on our website:  we collect Business Data, Communications Data, Financial Data,  Identity and Contact Data, Marketing Data, Profile and Usage Data, Technical Data and Transaction Data for the purposes of Client onboarding and Provision of LB services,  Our lawful grounds are Consent, Contract and Legitimate Interests.

6. You request marketing to be sent to you: we collect Business Data, Communications Data, Identity and Contact Data, Marketing Data, Profile and Usage Data  and Transaction Data for the purposes of Improving LB experience and Marketing.  Our lawful grounds are Consent and Legitimate Interests.

7. You enter a competition, promotion or survey: we collect Identity and Contact Data,Marketing Data, Profile and Usage Data and Transaction Data for the purposes of Improving LB experience and Marketing.  Our lawful grounds are Consent and Legitimate Interests.

8. You give us feedback or contact us: we collect Communications Data, Identity and Contact Data, Marketing Data, Profile and Usage Data and Transaction Data  for the purposes of Customer support , Improving LB experience, Marketing and Provision of LB services. Our lawful grounds are Consent, Contract and Legitimate Interests.

9. You attend an event (virtual or live): we collect Communications Data, Identity and Contact Data, Marketing Data, Profile and Usage Data and Transaction Data for the purposes of Marketing and Provision of LB services.  Our lawful grounds are Consent and Legitimate Interests.]

10. You subscribe to our service or marketing comms: we collect Communications Data, Identity and Contact Data, Marketing Data, Profile and Usage Data and Transaction Data for the purposes of Improving LB experience and Marketing and Provision of LB services.  Our lawful grounds are Consent and Legitimate Interests.

11. You interact with our website: we collect Technical Data (see our cookie policy for more information) for the purposes of Client onboarding, Customer support , Improving LB experience, Marketing, Provision of LB services and Website and systems security.   Our lawful grounds are Consent and Legitimate Interests.

12. You supply goods or services to LB: we collect Business Data, Communications Data, Identity and Contact Data, Marketing Data, Profile and Usage Data and Transaction Data for the purposes of Improving LB experience, Provision of LB services and Running the LB business.  Our lawful grounds are Consent and Legitimate Interests.

Most of the data we collect is provided directly by you.  However, we do also obtain data from 3rd party suppliers (such as Paypal and Stripe) and publicly available sources (such as Companies House, the Electoral roll and websites).

Most of the data we collect is provided directly by you.  However, we do also obtain data from 3rd party suppliers (such as Paypal and Stripe) and publicly available sources (such as Companies House, the Electoral roll and websites).

2.6 Marketing 

To provide you with choices regarding certain personal data uses (particularly around marketing and advertising) we have established the following personal data control mechanisms:

Promotional offers from us

We may use your personal data to form a view on what services, products and offers we think may be of interest..

You will receive marketing communications from us if:

you have requested information, downloaded resources or purchased services from us 

AND 

you have not opted out of receiving that marketing.

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.

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

Opting out

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing email OR by contacting us at any time. 

Where you opt out, this will not apply to personal data provided to us as a result of a purchase or other transaction.

Third-party marketing

We do not sell or provide your personal data to third parties for marketing purposes.

No knowledge or consent

We may process your personal data without your knowledge or consent, in compliance with the above rules if required or allowed by law.

Client onboarding
Customer support
Improving LB experience

Marketing

Provision of LB services

3. WHO WE SHARE YOUR PERSONAL DATA WITH

We may share your personal data with the parties set out below for the purposes set out in table 2.5 Personal data collection: when, why, what and on what lawful grounds. 

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.

External third parties

Cloud service providers acting as processors who provide data storage, IT and system administration services

Email providers

Payment processing providers who provide secure payment processing services (note your payment card details are not shared with us by the processors)

Advertising and marketing professionals and agencies

Professional advisers to LB (eg accountants, business/compliance/ IT consultants)

Event hosts and venues (in person or virtual) 

Social media platforms

HM Revenue & Customs and other authorities (acting as processors or joint controllers) based in the United Kingdom who require reporting of processing activities in certain circumstances

Any Purchasers of LB

We may choose to sell, transfer or merge parts of the LB 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.

4. YOUR PRIVACY RIGHTS AND CHOICES

4.1 Your rights

Under certain circumstances, data protection laws give you rights over your personal data.  If you wish to exercise any of these rights please contact us at [email protected] 

Request access to your personal data

Request correction of your personal data that we hold

Request erasure of your personal data

Object to processing

Request restriction of processing of your personal data

Request the transfer of your personal data to you or to a third party

Withdraw consent at any time
where we are relying on consent to process your personal data.

4.2 Other terms

No fee usually required

You will not usually have to pay a fee to exercise your rights.

We may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. 

Alternatively, we could 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 could 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.

5. HOW WE HANDLE YOUR PERSONAL DATA

5.1 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 individuals or businesses 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 use data processors to process personal data for us. We only do so if they comply with the UK GDPR and the EU GDPR and have adequate technical measures to protect your personal data.  The transmission and exchange of information is carried out at your own risk. We cannot guarantee the security of any information that you transmit to us, or receive from us; however, we take measures in order to safeguard against unauthorised disclosures by taking actions such as encrypting data with strong cryptography before transmitting it over a public network like the internet.  Although there are no guarantees when sending personal data online, we strive for maximum protection.

Security measures include:

Email

Data is encrypted at all steps.

Email messages are stored on a secure server network in encrypted format and are transmitted in encrypted format between those servers and user devices.

Documents

Server side: We store documents on cloud-based servers which use two-factor authentication, 256-bit SSL/TLS encryption for data in transit and 128-bit AES encryption for data at rest. 


Client side: to further protect data we utilise “zero knowledge” AES-256 bit encryption software to encrypt documents before we upload them to the cloud server.

CRM

We use a cloud based platform which is hosted within world-class, SOC 2 accredited data centers.

Data in transit is encrypted using secure TLS cryptographic protocols. Data is encrypted at rest where possible.

Payment software and processors

Our payment solution software provider uses a secure server.

All supplied sensitive/credit information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into PayPal and Stripe’s databases (only to be accessible by those authorised with special access rights to such systems, and are required to keep the information confidential)

During and after a transaction, none of your private data (e.g. credit card numbers) is transmitted to nor stored on our payment solution provider’s servers.

We have processes 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.

5.2 International transfers of data 

Many of our external third-party providers are based outside of the UK and the EEA.  If they are located in a country that has not been deemed to have the same standard of data protection as the UK and EEA, we make sure that our agreements with them protect your privacy by including the EU Standard Contractual Clauses (which set out measures for how those third parties must deal with personal data).  

Following the end of the transition period for the UK’s exit from the EU, the UK Information Commissioner’s Office plans to consult on and publish new UK Standard Contractual Clauses in 2021.  We will review our agreements with third-party providers once these are released.

5.3 Retention of your data 

How long will you use my personal data for?

We will only keep your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.  

Once we no longer need to keep your personal data it will be deleted or anonymised.

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