PRIVACY POLICY – VERO LAW LIMITED

Welcome to the Vero Law’s privacy policy (“Privacy Policy”).

Vero Law respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and use our services, and tells you about your privacy rights and how the law protects you.

Who We Are

This Privacy Policy applies to the website of and services provided by Vero Law Limited (Company Number: SC534310) with its registered office at 11/6 Comely Bank Road, Edinburgh, EH4 1DR (“Vero Law”, “we”, “us”, or “our”).

Vero Law is a data controller for some personal data and a data processor for others.  We are responsible for this website and the provision of our services and the personal data provided or collected in connection with our website and services.

Data Controller:   Vero Law collects and uses personal data to operate our website and to deliver services, as well as to provide you with information about our services.  In these circumstances, we are a data controller.

Data Processor:   When we provide our services, it may be necessary or useful for you to provide certain personal data to us. For example, the personal data of customers, staff, suppliers, etc.  In these circumstances, you are the controller of the data and we are your data processor. You must therefore ensure you are lawfully permitted to transfer such personal data to us. We will only use the data to provide the services or as necessary to comply with applicable laws.

Persona Data We Collect

We may collect, use, store and transfer different kinds of personal data which we have grouped together as follows:

• Identity data: includes first name, last name, title and social media accounts.
• Contact data: includes email address and telephone numbers.
• Technical data: includes information about use of our website, internet protocol (“IP”) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology used to access websites.
• Profile data: includes preferences, feedback and survey responses.
• Marketing and communications data: includes preferences in receiving marketing from us and communication preferences.

We may also collect, use and share aggregated data such as statistical or demographic data (“Aggregated Data”). Aggregated Data may be derived from your personal data but is not considered personal data by law as this data does not directly or indirectly reveal your identity. However, if we 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 Policy.

We do not collect Special Categories of Personal Data (such as race, ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about health, and information about criminal convictions and offences).

How is Personal Data Collected?

We use different methods to collect data including through:

• Direct interactions: you may give us details such as name, email address and other contact details in person, or by filling in forms on our website or by corresponding with us by post, phone, email, social media and/or otherwise. This includes personal data provided when you:
• request our services;
• meet with or contact one of our staff;
• are introduced to one of our staff by another contact;
• participate in an event which we have attended or organised;
• contact us via our website;
• subscribe to our publications or newsletters;
• request information about our services or other information or for materials to be sent to you;
• respond to a survey; and/or
• make a complaint or give us some feedback.

Automated Technologies or Interactions

If you interact with our website, we may automatically collect technical data about equipment, IP address, browsing actions and patterns. We collect this data by using cookies and other similar technologies. We may also receive technical data if you visit other websites employing our cookies. Please see our cookie policy for further details.

We may receive personal data from various third parties such as technical data from analytics providers and/or search information providers.

How we use your Personal Data

We will use personal data in the following circumstances:

• where we need to provide the services to you (i.e. because we are contractually obliged to do so);
• where it is in our legitimate interests to do so (or those of a third party) and your interests and fundamental rights do not override those interests; and/or
• where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing personal data other than in relation to sending useful information and marketing communications to you via telephone and/or email. You have the right to withdraw consent to us contacting you like this at any time by responding to the person that contacts you and/or by contacting us via the details given below.

We have set out below the ways we use personal data and the legal basis for doing so. We have also identified what our legitimate interest is, where appropriate.

We may process personal data for more than one lawful ground depending on the specific purpose for which we are using data. Please contact us if you want further details about the specific legal ground we are relying on to process your personal data.

Where we need to collect personal data by law, or under the terms of a contract and you do not provide that data when requested, we may not be able to perform the contract. In this case, we may have to cancel a service you have with us but we will notify you of this at the time.

Newsletters and Marketing Communications

You may receive newsletters, legal updates, news and information about our services and/or other marketing communications from us if you have requested such information from us, purchased our services or if you provided us with your details when you contacted or registered with us unless you told us you did not want to receive such information.

We may also contact you via surveys to conduct research about your opinion of our services.

We do not give or provide in any other way our customer lists to third parties.

Opt-Out or Unsubscribe

We respect your privacy. You may, at any time opt-out of receiving certain types or all communications from us by contacting us (as set out below) or selecting the “unsubscribe” option in any e-communication from us.

Cookies

Our website uses cookies and similar technologies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and allows us to improve our website.

You can set your browser to refuse all or some browser cookies. For more information about the cookies we use, please see our cookie policy.

Third-Party Links and Services

Our website may include links to third-party websites and/or plug-ins. 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 or services and are not responsible for their privacy practices or privacy statements. When you leave our website, we encourage you to read the privacy policy of any new website you visit if this a concern for you.

How we may share personal data

We may have to share personal data with third parties as per below for the purposes set out in the table above:

• Service providers who perform services and functions on our behalf in connection with the operation of our business such as software and application service providers, third parties who host, store and manage data or provide programming or technical support, etc.
• Professional advisers including our accountants, insurers and brokers, etc.
• Analytics partners to analyse website traffic and understand customer needs and trends.
• Marketing service providers to help us to communicate with you.
• If we are required to do so by law, or if we believe that such action is necessary to: (a) fulfil a government, or regulatory authority request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, our websites or customers.
• Those to whom we may sell, transfer, or merge parts of our business with, or where we acquire other businesses or merge with them. If such a change happens then any new owners may use your personal data in the same way as set out in this policy.

We require third parties to respect the security and confidentiality of personal data and to treat it in accordance with the law. We do not allow third-party service providers to use personal data for their own purposes and only permit them to process personal data for specified purposes and in accordance with our instructions.

Disclosure of Personal Data

We will disclose personal information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to:

• comply with legislation or legal process served on us;
• protect and defend our rights and/or property; and
• to protect personal safety.

International Transfers

Our third-party service providers may be based outside the European Economic Area (“EEA”), and when they are, their processing of personal data will involve a transfer of data outside the EEA.

Whenever we transfer personal data out of the EEA or UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

Personal Data – Security

We have put in place appropriate security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

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.

Records Management/Data Retention

We will retain personal data for as long as necessary to fulfil 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 personal data, the purposes for which we process personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

For example, if you are a client, we will generally keep your personal data for the longer of: (a) six years from the date of the last interaction with you; or (b) until the applicable statutory limitations period has expired.

We regularly review the personal data we hold taking into account the lawful purpose for which we hold it and any data that is deemed no-longer relevant or required is deleted where it is practicable to do so.

Personal Data – Your Rights

You have the right to:

• Request access to your personal data (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 processing it lawfully.
• 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 rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. It is unlikely, but 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 the 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.

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 unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

Confirmation of Your Identity

We may need to request specific information from you to help us confirm your identity and ensure your right to access 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 does not have a 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 as soon as reasonably practicable and at least within one month. Occasionally it may take us longer 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.

Contact Details

If you would like to contact us to discuss this Privacy Policy or any other data protection related queries, please send an email to: hello@verolaw.co.uk.