1. Introduction
1.1. We are committed to safeguarding the data and privacy of anyone that contacts us or visits our website; in this policy we explain how we will treat your personal information.
1.2. Horwich Farrelly Limited is registered as a data controller with the Information Commissioner’s Office, registration number ZB043355.
1.3. Please note that telephone calls may be recorded for quality control, training purposes and fact verification.
2. Collecting personal information
2.1. We may collect, store and use the following kinds of personal information:
(a) information provided or collected as an integral part of the conduct and delivery of the services we provide (in accordance with our Client Privacy Policy);
(b) information about your computer and about your visits to and use of this website (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths);
(c) information that you provide to us when registering with our website (including name and job title, contact information including email address, demographic information such as postcode, preferences and interests, other information relevant to customer surveys and/or offers);
(d) information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (including name and job title, contact information including email address, demographic information such as postcode, preferences and interests);
(e) information that you post to our website for publication on the internet; and
(f) information contained in or relating to any communication that you have with us or send through our website (including the communication content and metadata associated with the communication).
2.2. Before you disclose to us the personal information of another person, you must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with this policy.
3. Using personal information
3.1. Personal information submitted to us through our website will be used for the purposes specified in this policy or on the relevant pages of the website.
3.2. We may use your personal information to:
(a) enable us to deliver our services (in accordance with our Client Privacy Policy);
(b) deal with enquiries and complaints made by or about you;
(c) administer our website and business;
(d) enable your use of the services available on our website;
(e) send you our email newsletters and alerts, if you have requested them (you can inform us at any time if you no longer require them);
(f) send you marketing communications relating to our business which we think may be of interest to you, by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications);
(f) keep our website secure and prevent fraud; and
(g) verify compliance with the terms and conditions governing the use of our website.
3.3. If you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the licence you grant to us.
3.4. Your privacy settings can be used to limit the publication of your information on our website, and can be adjusted using privacy controls on the website.
3.5. We will not, without your express consent, supply your personal information to any third party for the purpose of their or any other third party’s direct marketing.
4. Disclosing personal information
4.1. We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this policy.
4.2. We may disclose your personal information:
(a) to the extent that we are required to do so by law;
(b) in connection with any ongoing or prospective legal proceedings;
(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
(d) to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
4.3. Except as provided in this policy and our Client Privacy Policy, we will not provide your personal information to third parties.
5. International data transfers
5.1. Personal information that you publish on our website or submit for publication on our website may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.
5.2. You expressly agree to the transfers of personal information described in this Section 5.
6. Retaining personal information
6.1. This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.
6.2. Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3. Notwithstanding the other provisions of this Section 6, we will retain documents (including electronic documents) containing personal data:
(a) to the extent that we are required to do so by law;
(b) if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
7. Security of personal information
7.1. We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
7.2. We will store all the personal information you provide securely.
7.3. You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
7.4. You are responsible for keeping the password you use for accessing our website confidential; we will not ask you for your password (except when you log in to our website).
8. Amendments
8.1. We may update this policy from time to time by publishing a new version on our website.
8.2. You should check this page occasionally to ensure you are happy with any changes to this policy.
9. Your rights
9.1. You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:
(a) the payment of the fee set out in the current data protection legislation; and
(b) the supply of appropriate evidence of your identity.
9.2. We may withhold personal information that you request to the extent permitted by law.
9.3. You may instruct us at any time not to process your personal information for marketing purposes.
9.4. In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
10. Third party websites
10.1. Our website includes hyperlinks to, and details of, third party websites.
10.2. We have no control over, and are not responsible for, the privacy policies and practices of third parties.
11. Updating information
11.1. Please let us know if the personal information that we hold about you needs to be corrected or updated.
12. Our cookies
12.1. We use cookies for:
(a) analytical purposes (see 13 below); and
(b) to record opt in / opt out status with regard to the information collected via the cookies used on our website.
13. Analytics cookies
13.1. We use Google Analytics to analyse the use of our website.
13.2. Our analytics service provider generates statistical and other information about website use by means of cookies (of the form_ga*).
13.3. The information generated relating to our website is used to create reports about the use of our website.
13.4. Our analytics service provider’s privacy policy is available at: http://www.google.com/policies/privacy/.
