I respect your privacy and are determined to protect your personal data. The purpose of this privacy notice is to inform you as to how I look after your personal data when you visit my website (regardless of where you visit it from). I’ll also tell you about your privacy rights and how the data protection law protects you.

1. WHO I AM AND IMPORTANT INFORMATION
2. THE PERSONAL DATA I COLLECT ABOUT YOU
3. HOW I COLLECT YOUR PERSONAL DATA
4. HOW I USE YOUR PERSONAL DATA
5. WHO I SHARE YOUR PERSONAL DATA WITH
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. CHANGES TO THIS NOTICE AND YOUR DUTY TO INFORM ME OF CHANGES
11. QUERIES, REQUESTS OR CONCERNS
12. WHO I AM AND IMPORTANT INFORMATION 

What is the purpose of this privacy notice?

This privacy notice aims to give you information on how I collect and process your personal data through your use of this website, including any data you may provide through this website when you complete an enquiry form

This website is not intended for children and I do not knowingly collect data relating to children.

You must read this privacy notice together with any other privacy notice I may provide on specific occasions when I am collecting or processing personal data about you so that you are fully aware of how and why I am using your data. This privacy notice supplements the other notices and is not intended to override them.

Data controller(s)

Sanjai Ahitan is the controller and responsible for your personal data.
My contact details are Tees Barrage Way, Stockton-on-Tees, TS17 6QA.For all data matters please contact me.

Third-party links outside of our control

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. I do not control these third-party websites and am not responsible for their privacy statements. 

When you leave my website, I encourage you to read the privacy notice of every website you visit.

2. THE PERSONAL DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioners Office.

I may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• Identity Dataincludes FIRST NAME/LAST NAME
• Contact Dataincludes EMAIL ADDRESS/ TELEPHONE NUMBERS

I 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, I MAY AGGREGATE YOUR USAGE DATA TO CALCULATE THE PERCENTAGE OF USERS ACCESSING A SPECIFIC WEBSITE FEATURE. HOWEVER, IF I 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 NOTICE.

I 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 I collect any information about criminal convictions and offences.

If you fail to provide personal data 

Where I need to collect your personal data by law, or under the terms of a contract I have with you and you fail to provide that data when requested, I may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, I may have to cancel a product or service you have with us but I will notify you if this is the case at the time.

3. HOW WE COLLECT YOUR PERSONAL DATA 

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

• Directly.You may give us your [IDENTITY AND CONTACT DATA] by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:·        
• Send an enquiry

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:

• Performance of Contract this 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.

• Legitimate Interestthis means the interest of our business in conducting and managing our business to enable me to give you the best service and the most secure experience. I make sure I consider and balance any potential impact on you (both positive and negative) and your rights before I process your personal data for our legitimate interests. I do not use your personal data for activities where our interests are overridden by the impact on you (unless I have your consent or are otherwise required or permitted to by law). You can obtain further information about how I assess our legitimate interests against any potential impact on you in respect of specific activities by contacting me.

• Comply with a legal or regulatory obligationthis means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

GENERALLY I DO NOT RELY ON CONSENT AS A LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA OTHER THAN IN RELATION TO SENDING THIRD PARTY DIRECT MARKETING COMMUNICATIONS TO YOU VIA EMAIL OR TEXT MESSAGE. YOU HAVE THE RIGHT TO WITHDRAW CONSENT TO MARKETING AT ANY TIME BY CONTACTING ME.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

I have set out below, in a table format, a description of all the ways I plan to use your personal data, with the legal bases I rely on to do so. 

Note that I 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 me if you need details about the specific legal ground I am 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 customer

(a) Identity

(b) Contact

Performance of a contract with you

Marketing

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

[I HAVE ESTABLISHED THE FOLLOWING PERSONAL DATA CONTROL MECHANISMS]:

Promotional offers from me

I may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how I decide which products, services and offers may be relevant for you.

You will receive marketing communications from me if you have requested information from us or purchased goods or services from us [OR IF YOU PROVIDED US WITH YOUR DETAILS WHEN YOU ENTERED A COMPETITION OR REGISTERED FOR A PROMOTION] and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

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

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting me.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of A SERVICE.

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 my cookie policy.

Change of purpose

I will only use your personal data for the purposes for which we collected it, unless I 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 me.

If I need to use your personal data for an unrelated purpose, I will notify you and I will explain the legal basis which allows us to do so.

Please note that I may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. WHO WE SHARE YOUR PERSONAL DATA WITH

I may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• Providers ACTING AS PROCESSORS based IN THE UNITED KINGDOM who provide IT, MARKETING AND SYSTEM ADMINISTRATION SERVICES.
• Professional advisers including lawyers, bankers, auditors and insurers based IN THE UNITED KINGDOM who provide CONSULTANCY, LEGAL, AND ACCOUNTING SERVICES.
• HM Revenue & Customs, regulators and other authorities based IN THE UNITED KINGDOM WHO REQUIRE REPORTING OF PROCESSING ACTIVITIES IN CERTAIN CIRCUMSTANCES.
• Third parties to whom i may choose to sell, transfer, or merge parts of my business or our assets. Alternatively, I 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 notice.

I require all third parties to respect the security of your personal data and to treat it in accordance with the law. I 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

MANY OF OUR EXTERNAL THIRD PARTIES ARE BASED OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA) SO THEIR PROCESSING OF YOUR PERSONAL DATA WILL INVOLVE A TRANSFER OF DATA OUTSIDE THE EEA.

WHENEVER WE TRANSFER YOUR PERSONAL DATA OUT OF THE EEA, WE ENSURE A SIMILAR DEGREE OF PROTECTION IS AFFORDED TO IT BY IMPLEMENTING SAFEGUARDS:

• Following best practices and guidance provided from third parties to 
  protect your data.

PLEASE CONTACT ME IF YOU WANT FURTHER INFORMATION ON THE SPECIFIC MECHANISM USED BY US WHEN TRANSFERRING YOUR PERSONAL DATA OUT OF THE EEA.

7. DATA SECURITY

I 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, I 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.

I 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

I will only retain your personal data for as long as necessary to fulfil the purposes I collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, I 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 I process your personal data and whether I can achieve those purposes through other means, and the applicable legal requirements.

OR

By law I have to keep basic information about our customers (INCLUDING CONTACT, IDENTITY, FINANCIAL AND TRANSACTION DATA) FOR [SIX] YEARS AFTER THEY CEASE BEING CUSTOMERS FOR [TAX] PURPOSES.]

In some circumstances you can ask me to delete your data: see Your legal rights below for further information.

In some circumstances I may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case I may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data: 

• The right to request a copy of the personal data which I hold about you;
• The right to request that I correct any personal data if it is found to be inaccurate or out of date;
• The right to request your personal data is erased where it is no longer necessary to retain such data;
• The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data; 
• The right to request that I provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), where applicable i.e. where our processing is based on consent or is necessary for the performance of MY contract with you or where I process your data by automated means); 
• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
• The right to object to my processing of personal data, where applicable i.e. where processing is based on our legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct marketing or processing for the purposes of scientific/historical research and statistics). 

If you wish to exercise any of the rights set out above, please contact me.

No fee required – with some exceptions

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, I may charge a reasonable admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, i may refuse to comply with your request in these circumstances.

What we may need from you

I 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. I may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

I try to respond to all legitimate requests within one month. Occasionally it may take me longer than a month if your request is particularly complex or you have made a number of requests. In this case, I will notify you and keep you updated.

10. CHANGES TO THIS NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

THIS VERSION WAS LAST UPDATED ON 28 March 2019.

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

11. QUERIES, REQUESTS OR CONCERNS

To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact me.

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Officeon 03031231113 or via email https://ico.org.uk/global/contact-us/email/or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England, UK.

Markel Law owns the copyright in this document.  You must not use this document in any way that infringes the intellectual property rights in it.  You may download and print this document which you may then use, copy or reproduce for your own internal non-profit making purposes. However, under no circumstances are you permitted to use, copy or reproduce this document with a view to profit or gain.  In addition, you must not sell or distribute this document to third parties who are not members of your organisation, whether for monetary payment or otherwise.

This document is intended to serve as general guidance only and does not constitute legal advice. The application and impact of laws can vary widely based on the specific facts involved. This document should not be used as a substitute for consultation with professional legal or other competent advisers. Before making any decision or taking any action, you should consult a Markel Law professional.

In no circumstances will Markel Law LLP, or any company within the Markel Group be liable for any decision made or action taken in reliance on the information contained within this document or for any consequential, special or similar damages, even if advised of the possibility of such damages.