- Important information and who we are
- The data we collect about you
- How is your personal data collected?
- How we use your personal data
- Disclosures of your personal data
- International transfers
- Data security
- Data retention
- Your legal rights
Welcome to the VLAW LIMITED’s privacy notice.
VLAW LIMITED respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
1.IMPORTANT INFORMATION AND WHO WE ARE
VLAW Limited, trading as Valemus Law or Virtual Law, is a company incorporated in England and Wales under company number 5342299 and whose registered office is located at 2ndFloor, 9 Savoy Street, London, WC2E 7EG. A list of the directors of VLAW Limited is available for inspection at its registered office. VLAW Limited is a recognised body and is authorised and regulated by the Solicitors Regulation Authority (SRA No. 462361), whose rules can be downloaded at www.sra.org.uk.
Important Contact Details:
Registered Office: 2nd Floor, 9 Savoy Street, London, WC2E 7EG
Telephone: +44 (0)330 100 0320
Managing Director and COFA: Oliver Brice
Supervisory Director and COLP: James Hilsdon
Data Controller: Oliver Brice
VLAW Limited takes data privacy seriously. Our data protection policy follows EU guidelines and has been updated in accordance with the new General Data Protection Regulation (“GDPR”) which applies across the European Union and comes into force on 25th May 2018. This statement explains how we may collect and process information about:
- visitors to our website
- people who use our services, e.g. clients
- applicants and lawyers currently working with us
1.1 PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how we collect and processes your personal data through your use of this website, including any data you may provide through this website when you ask for one or more of our lawyers to contact you, sign up to our newsletter or request further information on our niche practice areas or specific lawyers within those practice areas. This website is not intended for children and we do not knowingly collect data relating to children.
This privacy notice also states what happens to the data we collect for our client due diligence procedures, which are required by our regulatory body, the Solicitors Regulation Authority and to satisfy other regulatory obligations that we have. This information is never collected through our website. However, we are including this information in this document as we are aware that many of our clients will use the website as a reference point when obtaining information on our data collection processes.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
1.2 CONTACT POINT
Oliver Brice is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this policy, how we use your data or if you wish to exercise any of your legal rights under the GDPR then please contact Oliver Brice by email at firstname.lastname@example.org.
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). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact Oliver Brice in the first instance and we will address any issues or concerns that you may have.
1.3 CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
The data protection law in the UK will change on 25 May 2018. Although this privacy notice sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests (for example, a request for the transfer of your personal data) until our systems are ready for some of these changes.
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.
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 notice of every website you visit.
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).
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, title, date of birth and residential address. This data is not collected via our websites; it will however be requested for due diligence purposes.
- Contact Data includes billing address, email address and telephone numbers. Only some of this data is collected through our websites – in particular when you make an enquiry to one of our lawyers or to head office via our website.
- Financial Data includes bank account details. This data is NEVER collected through our website, however, you may exchange these details with us via email.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us. This data is NEVER collected through our website, however, you may exchange these details with us via email.
- 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 email, your contact preferences, feedback and survey responses.
- Usage Data includes information about how you use our website and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences. We never share your data with third parties for third party marketing purposes.
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) unless this information is strictly required to provide legal advisory services to you which require such information, for example, our Immigration Law or Employment Law practices might require such information from time to time in order for us to be able to properly advise you. This information is never collected via our websites, and nor is it utilised in any form except in order to advise you.
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 legal advice). In this case, we may have to cancel the legal service you have with us but we will notify you if this is the case at the time.
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 identity, contact and/or financial data by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- You complete our engagement process to become a client
- You subscribe to our publications;
- You request marketing to be sent to you;
- You give us some feedback;
- During matters of legal procedure for and on behalf of you, our client.
- Contact forms on our website. By completing these forms this will result in your name, email address and message being emailed to us. This information is kept private and will not, under any circumstance, be forwarded to third parties without expressed permission from the individual concerned. Your contact information will be stored within our email system so that we are able to respond to you. Please note that we cannot guarantee the privacy of personal information you transmit over the web or that may be collectible in transit by others.
- Third parties or publicly available sources. We may receive personal data about you from various third parties including:
- Third party referrers of business or other third parties with whom we are engaged to provide services indirectly to their clients
- Technical Data from the following parties:
- (a) analytics providers such as Google;
- (b) advertising networks; and
- (c) information providers.
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside and outside the EU.
- Identity data from third party anti-money laundering information providers to comply with our anti-money laundering procedures when you become a client.
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 provide legal advice to you under the terms of the engagement letter 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 in relation to direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time. If you wish to do so then please contact Oliver Brice by email at email@example.com.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, 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. We have also identified what our legitimate interests are where appropriate.
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 Oliver Brice (by email at firstname.lastname@example.org) 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 new client||(a) Identity
(c) Date of Birth
|To carry out due diligence procedures and in performance of a contract with you|
|To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e)Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
|To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(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 deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|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)|
|To make suggestions and recommendations to you about services that may be of interest to you||(a) Identity
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
PROMOTIONAL OFFERS FROM US
We 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.
You will receive marketing communications from us if you have requested information from us from us and you have not opted out of receiving that marketing.
You can ask us stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or please contact Oliver Brice (by email at email@example.com) at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of you engaging us to provide legal advice and services.
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 Oliver Brice by email at firstname.lastname@example.org.
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 process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We 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.
- Internal Third Parties as set out in the Glossary.
- External Third Parties as set out in the Glossary.
- Third parties to whom we may choose to sell, transfer, or merge parts of our 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 notice.
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
We do not transfer your personal data outside the European Economic Area (EEA) unless is strictly required in order to provide legal advisory services we have agreed to provide under the terms of our engagement. For example, where you have requested us to take legal advice in a country outside the EEA or asked us to file a trademark in a country outside the EEA.
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 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.
The IT system that we use is a cloud based system operated by a company called DPS Software Limited (“DPS”). DPS is ISO27001 accredited which is the international standard that describes best practice for an ISMS (information security management system) and deploys next generation firewalls which include ATP, IDS & IPS, SSL Interception.
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 USE MY PERSONAL DATA FOR?
By law we have to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for six years after they cease being clients for tax other legally binding requirements. After this period of time we are legally obliged to delete all data records we have for you unless we continue to work for you. If we continue to work for you for a period of two or more years it is our firm policy to request your personal details in order that we may show we have the most up-to-date data available. This is a legal requirement and all older records will be destroyed.
In some circumstances you can ask us to delete your data: see [Request erasure] below for further information.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You can:
- 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.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact Oliver Brice by email at email@example.com.
NO FEES REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights).
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/product 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 Oliver Brice by email at firstname.lastname@example.org.
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.
INTERNAL THIRD PARTIES
Other lawyers who are employees of us.
EXTERNAL THIRD PARTIES
- Our lawyers who are engaged on a consultancy basis.
- Marketing service providers based in the UK.
- Service providers based in the UK who provide IT and system administration services, such as DPS.
- Professional advisers, acting as processors or joint controllers, including lawyers, bankers, auditors and insurers based in the UK who provide legal, consultancy, banking, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities, acting as processors or joint controllers, based in the United Kingdom who require reporting of processing activities in certain circumstances.
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.
If you wish to exercise any of the rights set out above, please contact Oliver Brice by email at email@example.com.