Why should you read this document?
During the course of dealing with us, we will ask you to provide us with detailed personal information relating to your existing circumstances, your financial situation and, in some cases, your health and family health history (Your Personal Data). This document is important as it allows us to explain to you what we will need to do with Your Personal Data, and the various rights you have in relation to your Personal Data.
Please be aware that if we are advising your Company or business entity we will be collecting and processing the Personal Data of the directors, shareholders and key employees within your business. As our client you should make sure that when you pass any Personal Data to us that the individual:
• is aware that this Personal Data has been passed to Conatus;
• consents to Personal Data being sent to Conatus; and
• Is made aware of this privacy notice and how Conatus will use and store their personal data.
What do we mean by “Your Personal Data”?
Your Personal Data means any information that describes or relates to your personal circumstances. Your Personal Data may identify you directly, for example your name, address, date or birth, National Insurance number. Your Personal Data may also identify you indirectly, for example, your employment situation, your physical and mental health history, or any other information that could be associated with your cultural or social identity.
Depending on your relationship with us (for instance, whether you are a client or professional contact), we collect, use, store and transfer some or all of the following Personal Data:
• Title, names, date of birth, gender, nationality, civil/marital status, contact details, addresses and documents that are necessary to verify your identity
• all of the Personal Data that you may give to us in connection with the advice and services we provide to you, including details about your income and tax affairs, financial and employment affairs, family details, property ownership, personal and business affairs, medical and health information, details about your business and business transactions
• Bank account details, tax information, loans and credit commitments, personal credit history, sources of income and expenditure, family circumstances and details of dependents
• Any pre-existing funding products and the terms and conditions relating to these
• details of services we provide to you
• Marketing and Communications Data including your preferences in receiving marketing from us and your communication preferences
• If you are viewing this on our website then we may have collected your Technical Data including (IP) address, your login data, browser type and version, location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
We may also hold personal data, including some sensitive data on behalf of your employees, shareholders and/or directors. We hold this data with the same security and protection as yours and your Directors. It is your responsibility however, to make your employees aware that this data has been passed to us.
The basis upon which Conatus will deal with Your Personal Data
When we speak with you about your business support / funding requirements or bookkeeping services requirements we do so on the basis that both parties are entering a contract for the supply of services.
In order to perform that contract, and to provide the services you require, we use Your Personal Data for the purposes and in the ways detailed below.
In the course of handling Your Personal Data, we will:
• Record and store Your Personal Data in our paper files, mobile devices and on our computer systems (email, hard drives, and cloud facilities)
• Submit Your Personal Data to third parties as necessary to provide our services to you and with your consent as explained below
• Use Your Personal Data to communicate with you
• Use Your Personal Data as is necessary to provide the services you have instructed us to or are proposing to ask us to provide and to fulfil our contract with you
• Use Your Personal Data to meet legal, regulatory and compliance requirements including identity checks and any reports to crime or fraud prevention agencies.
• Use Your Personal Data to gather management information to form statistical and trend analysis
• Process your Personal Data to manage our relationship with you including to notify you of changes to our terms and conditions, manage payment of fees and to collect and recover money owed to us.
• Use data analytics to administer and improve and develop our website, services and customer relationships.
• Contact you about our products and services which we think might be of interest to you (where we have the appropriate permissions to do so)
• Use Your Personal Data 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
In the course of initial discussions with you or when the contract between us has come to an end for whatever reason, we have the right to use Your Personal Data provided it is in our legitimate business interest to do so and your rights are not affected. For example, we may need to respond to requests from mortgage lenders, insurance providers and our Compliance Service Provider relating to the advice we have given to you, or to make contact with you to seek feedback on the service you received.
On occasion, we will use Your Personal Data for contractual responsibilities we may owe our regulator The Financial Conduct Authority, or for wider compliance with any legal or regulatory obligation to which we might be subject. In such circumstances, we would be processing Your Personal Data in order to meet a legal, compliance or other regulatory obligation to which we are subject.
If you fail to provide personal data
Where we need to collect Personal Data by law, or under the terms of the agreement to provide services 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 with services). In this case, we may have to cancel the contract you have with us, but we will notify you if this is the case at the time.
How do we collect Your Personal Data?
We will collect and record Your Personal Data from a variety of sources, but mainly directly from you and from your other advisers. You will usually provide information during the course of our engagement with you and your business. You will provide information to us verbally and in writing, including email.
We may also obtain some information from third parties, for example, credit checks, information from your employer, company directors, accountant, bank, creditors, existing lenders and searches of information in the public domain such as Companies House.
We may also collect, store and use information about your health, including any medical condition, health and sickness records, and medical records and reports, as part of providing services to you, which is particularly sensitive data. We will use your sensitive data in the same way as Your Personal Data generally, as set out in this Privacy Notice. We will only use this information to provide our Services to you.
Sharing Your Personal Data
From time to time Your Personal Data will be shared with:
• Mortgage lenders/Finance lenders and insurance providers;
• HM Revenue & Customs and other authorities and regulatory bodies;
• Third parties who we believe will be able to assist us with providing our services to you, or who are able to support your needs as identified. These third parties will include but not be limited to, professional advisers, Compliance Advisers, HR advisers, providers of legal or administrative services, specialist tax and accountancy services, surveyors, valuers, restructuring specialists (in each case where we believe this to be required due to your particular circumstances). We will discuss with the nominated representative from our client before doing this;
• Our service providers who provide IT services to us or store documents for us and other similar services;
• our professional advisers, including but not limited to our lawyers, bankers, insurance brokers and debt collection agencies;
• The Financial Conduct Authority or other equivalent legislative and governing body who we are regulated by.
In each case, your Personal Data will only be shared for the purposes set out in this customer privacy notice, i.e. to progress your business needs enquiry, to provide you with our professional services and for our legitimate business needs.
The provision of this information to a third party is essential in allowing us to progress any enquiry or application made on your behalf and to deal with any additional questions or administrative issues that may be raised. We rely on your consent to pass your Personal Data to third parties.
Please note that this sharing of Your Personal Data does not entitle such third parties to send you marketing or promotional messages.
We do not envisage that the performance by us of our service will involve Your Personal Data being transferred outside of the European Economic Area. In the event we transfer your Personal Data outside of the EEA we will ensure that a similar level of protection is given to it.
In the event we choose to sell or merge all or any part of our business we may share your Personal Data with such party. The new owners may use your Personal Data in the same way as set out in this privacy notice.
Security and retention of Your Personal Data
Your privacy is important to us and we will keep Your Personal Data secure in accordance with our legal responsibilities. We will take reasonable steps to safeguard Your Personal Data against it being accessed unlawfully or maliciously by a third party.
We also expect you to take reasonable steps to safeguard your own privacy when transferring information to us, such as not sending confidential information over unprotected email, ensuring email attachments are password protected or encrypted and only using secure methods of postage when original documentation is being sent to us.
We will hold your Personal Data for as long as is necessary for the relevant activity or until you request that we delete it, including for the purposes of satisfying any legal, accounting, or reporting requirements. Any requests to delete or destroy Personal Data will be complied with to the extent required by law.
Your rights in relation to Your Personal Data
• request copies of Your Personal Data that is under our control
• ask us to further explain how we use Your Personal Data
• ask us to correct, delete or require us to restrict or stop using Your Personal Data (details as to the extent to which we can do this will be provided at the time of any such request)
• ask us to send an electronic copy of Your Personal Data to another organisation should you wish
• change the basis of any consent you may have provided to enable us to market to you in the future (including withdrawing any consent in its entirety)
How to make contact with Conatus in relation to the use of Your Personal Data
If you have any questions or comments about this document, or wish to make contact in order to exercise any of your rights set out within it please contact:
Beth Ward by email: firstname.lastname@example.org, by phone on: 01473 851587 or by post at the following address: Conatus Bookkeeping Limited, 30 Mallard House Business centre, The Street, Little Bealings, Woodbridge, Suffolk, IP13 6LT.
If we feel we have a legal right not to deal with your request, or to action, it in different way to how you have requested, we will inform you of this at the time.
You should also make contact with us as soon as possible on you becoming aware of any unauthorised disclosure of Your Personal Data, so that we may investigate and fulfil our own regulatory obligations.
If you have any concerns or complaints as to how we have handled Your Personal Data you may lodge a complaint with the UK’s data protection regulator, the ICO, who can be contacted through their website at https://ico.org.uk/global/contact-us/ or by writing to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
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