(effective 18 May 2018)
Who are we
Beargraft LTD is a private limited company trading as Alpha Collections incorporated in England and Wales and is a ‘controller’ under the General Data Protection Regulation 2016/679 (“GDPR”).
Whose data do we hold?
We may hold data about the following people:
- Employees and workers
- Customers and clients
- Suppliers and service providers
- Advisers, consultants and other professional experts
- Other professionals such as other solicitors, barristers, accountants, surveyors
- Complainants and enquirers
What data will we collect?
We will only collect information that is relevant to the matter that we are dealing with. In particular we may collect the following information from you which is defined as ‘personal data’:
- Personal details, including identity data and contact details
- Family, lifestyle and social circumstances
- Financial details
- Business activities of the person whose details we are processing
We may collect the following information from you when you view our website:
- Your IP Address, browsing actions and patterns
- Technical data such as 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 our website (click here to see our Cookies Policy for more information)
We may also collect information that is referred to as being in a ‘special category’. This could include:
- Physical or mental health details
- Racial or ethnic origin
- Religious beliefs or other beliefs of a similar nature
- Criminal convictions
- Sexual orientation
When we collection your personal information
We may collect personal data about you at various stages, such as:
- When you or your organisation seek our legal services
- When you or your organisation make an enquiry (including, without limitation, in person, over email or over the telephone)
- When you attend a seminar or other event we may organise, or sign up to receive communications from us
- When you or your organisation provide services to us, or otherwise offer to do so
Basis for processing
The basis on which we process your personal data is one or more of the following:
- It is necessary for the performance of our contract with you
- It is necessary for us to comply with a legal obligation
- It is in our legitimate interests to do so
- You have given us your consent (this can be withdrawn at any time on request by sending an email to email@example.com
How will we use your data?
We may use your information for the following purposes:
- Promotion of our goods and services
- Provision of education and training to customers and clients
- Maintaining accounts and records
- Supporting and managing staff
- Managing and administering your or your organisation’s business relationship with us, including processing payments, accounting, auditing, billing and collection or support services
- Complying with our legal and regulatory obligations (such as record keeping obligations) and for insurance purposes
- Communicating with you through appropriate channels to keep you up to date on the latest developments, announcements, and other information about our services, products and technologies as well as events and projects we may organise
- For any purpose related and/or ancillary to any of the above or any other purpose for which your personal data was provided to us
Who will we share your information with?
Under our Code of Conduct there are very strict rules about who we can share your information with and this will normally be limited to other people who will assist with your matter. This may include:
- Medical Experts
- Private investigators
- Healthcare professionals, social and welfare organisations
- Courts and tribunals
Where you authorise, us we may also disclose your information to your family, associates or representatives and we may also disclose your information to debt collection agencies if you do not pay our bills.
How long will we keep your information for?
We will normally keep your information throughout the period of time that we do work for you and afterwards for such period as we are required to do by law and also by the regulations and insurance requirements that apply to us. Usually this will be for a period of six years after we conclude the work we have carried out for you, but may be for a longer period in certain specific cases (including in particular in relation to real estate transactions where we will keep your information for a period of twelve years after we conclude the work we have carried out for you or for an even longer period where we have acted in connection to your will).
Transfers to third countries
- We may from time to time transfer your personal data to a country outside of the EEA.
- Normally this will be necessary for the performance of your contract with us or for the exercise or defence of legal claims on your behalf.
- Sometimes we may transfer for other reasons and we will ensure that appropriate safeguards are in place at all times. Such safeguards may include:
- The country to which we send your personal data is approved by the European Commission as providing an adequate level of protection for personal data;
- the transfer is to a recipient in the USA who has registered under the EU/US Privacy Shield;
- the recipient has entered into European Commission standard contractual clauses with us; or
- you have explicitly consented to the transfer of your personal data outside of the EEA
- We take appropriate technical and organisational measures to keep your personal data confidential and secure, in accordance with our internal policies and procedures regarding storage of, access to and disclosure of personal data.
- We may keep your personal data in our electronic systems, in the systems of our contractors, or in paper files.
- In the event of a personal data breach we have in place procedures to ensure that the effects of such a breach are minimised and shall liaise with the ICO and with you as appropriate.
Wht rights do you have?
You have the following rights under the GDPR:
- Right to be informed
- Right of access
- Right to rectification
- Right to erasure
- Right to restriction of processing
- Right to data portability
- Right to object
- Rights concerning automated decision-making and profiling
- You have a right to see the information we hold about you
- To access this you need to provide a request by email to firstname.lastname@example.org together with proof of identity
- We will usually process your request free of charge and within 30 days however we reserve the right to charge a reasonable administration fee and to extend the period of time by a further two months if the request is manifestly unfounded or vexatious and/or is very complex
Right to erasure
- You have a right to ask us to erase your personal data in certain cases (details may be found in Article 17 of the GDPR)
- We will deal with your request free of charge and within 30 days but reserve the right to refuse to erase information that we are required to retain by law or regulation, or that is required to exercise or defend legal claims
- To exercise your right to erasure please contact us by email to email@example.com together with proof of identity
Who can you complain to?
- If you are unhappy about how we are using your information or how we have responded to your request then initially you should contact firstname.lastname@example.org
- If your complaint remains unresolved then you can contact the Information Commissioner’s Office (ico.org.uk)