Effective from 29 July 2019
The purpose of this Policy notice is to inform you how we look after your personal data when you visit our website, your privacy rights and how the data protection law protects you.
CBH is the data controller and responsible for your personal data. Please see the final paragraph below to find out how to contact us.
Under the General Data Protection Regulation (‘GDPR’) we must describe how we collect and use personal data about you and we do so below.
CBH operates the www.cbh.co.uk website (‘the Site’) and we set out below our policies that govern how we collect, use and disclose any personal data we gather whilst you are on the Site.
The topics covered in this Policy are as follows:
- What type of information we hold
- How we collect the personal data
- How we use your personal data
- How long we retain your personal data
- Why and when might we share your data
- Which third parties can share your data
- Transferring data outside the European Economic Area (‘EEA’)
What type of information we hold
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.
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/last name/title.
- Contact Data includes address/email address/telephone numbers.
We 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, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. 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 notice.
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). Nor do we collect any information about criminal convictions and offences.
How we collect the data
We 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 us a message by filling out the Contact Form
- Subscribe to our Weekly E-Newsletter mailing list;
- Subscribe to our Quarterly Tax Newsletter mailing list;
- Subscribe to our monthly updates on Tax Information in Infozone.
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 Interest: this means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the 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 our data manager.
- Comply with a legal or regulatory obligation this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Generally we 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 us – SEE BELOW.
How long we retain your personal data
We will only retain your 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 your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for tax purposes.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Why and when we may share your data
We may have to share your personal data with the parties set out below:
External Third Parties Service
- Providers acting as processors based in the UK and overseas who provide IT and system admin. services.
- Professional advisers including lawyers, bankers, auditors and insurers based who provide consultancy, banking, legal, 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.
- 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.
Purposes for which we may use your data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, with the legal bases we rely on to do so.
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 the Data Protection Manager 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 customer||(a) Identity (b) Contact||Performance of a contract with you|
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. This is how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside the Cameron Baum Hollander group of companies for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us when using this website.
Transferring data outside the European Economic Area (EEA)
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
You have the right of free access to your personal data and if you would like a copy, please contact our Data Protection Manager (see below). If you find that anything is inaccurate, we will take steps to correct it quickly.
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 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.
CBH takes reasonable steps to allow any User to correct, amend, delete or limit the use of your Personal Data,
If you are dissatisfied at any stage and wish to make a complaint about CBH, you can contact the Information Commissioner’s Office (‘ICO’), at any time; details are on their website, www.ico.org.uk/make-a-complaint, or you can write to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England, UK or call them on 03031231113.
Security of your data
We are committed to ensuring all information we hold about you is secure and we have put in place appropriate physical, electronic and managerial procedures and security measures to prevent your personal data from being lost, used or accessed in an unauthorised way.
We will only share your personal data with the relevant authorities should we be required to do so under the Proceeds of Crime Act 2002, The Money Laundering Regulations 2017, the Criminal Finances Act 2017 and under common law. To do otherwise is against the law and we would not be able to act for you without doing so.
Our service is not addressed to anyone below the age of 13 (‘children’ and we do not knowingly collect personally identifiable information from any Children. If we become aware we have inadvertently collected personal data form Children, we take steps to remove that from our data.
Changes to this Policy
If and when we make changes to this Policy, it will be provided via this website, www.cbh.co.uk and we will email you in advance prior to the change becoming effective.
Whom to contact if I have questions or require information?
CBH is known as the Data Controller, which means we decide how and what data we hold about you and we have appointed Geoffrey Hollander as the Data Protection Manager, whom you can contact by:
- Writing to at 88 Crawford Street London W1H 2EJ
- Emailing to firstname.lastname@example.org or
- Calling on 020 7724 8824
about any questions you may have about this Policy or how we use your personal data.