Privacy Policy

Introduction

Phoenix Financial PR Limited (‘Phoenix’) is committed to protecting your Privacy.

This Privacy Policy details the way in which we protect your personal data when you visit our website and how we may use your personal data; it tells you about your Privacy rights and how the law protects you.

Please also use the Definitions to understand the meaning of some of the terms used in this Privacy Policy.

 

  1. IMPORTANT INFORMATION AND WHO WE ARE

 

PURPOSE OF THIS PRIVACY POLICY

This Privacy Policy aims to give you information as to how Phoenix collects and processes your personal data through (i) your use of this website and (ii) more generally, including any data you may provide, through this website or other means.

It is important that you read this Privacy Policy so that you are fully aware of how and why we are using your data.

 

CONTROLLER

This Privacy Policy is issued on behalf of Phoenix and all references to ‘we’, ‘us’ or ‘our’ in this Privacy Policy are references to Phoenix.  Phoenix is the Data Controller in relation to any personal data collected from our website or when you procure consultancy services from us.

We have appointed a Data Privacy Manager, who is responsible for overseeing questions in relation to this Privacy Policy.  If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the Data Privacy Manager using the details set out below.

 

CONTACT DETAILS

Our full details are:

Full name of legal entity: Phoenix Financial PR Limited

Data privacy manager: Gordon Puckey

Email address: gordon@phoenixfinancialpr.co.uk

Postal address: Bramford House, Ship Lane, Bramford, Suffolk IP8 4AN

Telephone number: 07799 767468

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 us in the first instance.

 

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

The data protection laws pertaining to the UK changed with effect from 25 May 2018.

We will amend this Privacy Policy from time to time to ensure it remains up-to-date and accurately reflects how and why we use your personal data.  It is important that the personal data we hold about you is accurate and current, so please do keep us informed if your personal data changes during your relationship with us.  The latest iteration of our Privacy Policy will always be posted on our website.

 

THIRD-PARTY LINKS

This website may from time to time 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 endorse or 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 Policy of every website you visit.

 

  1. 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 as follows:

 

  • Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender;
  • Contact Data includes billing address, delivery address, email address and telephone numbers;
  • Financial Data includes banking details of clients, suppliers and agents for the making of payments by us and to us in relation to the services we provide;
  • Transaction Data includes details of services you have purchased from us;
  • Technical Data includes internet protocol (IP) address, 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;
  • Usage Data includes information about how you use our website and services.

 

We may also collect, use and share Aggregated Data, likely to be obtained by Google Analytics.  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 Policy.

 

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 seeking to enter with you (for example, to provide you with our services).  In this case we may have to cancel a service you have with us, but we will notify you at the time if this is the case.

 

  1. 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 and Contact Data by filling in hard copy or online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • contract to receive our services;
    • request marketing material be sent to you;
    • give us your business card.
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns.  We collect this personal data by using cookies and other similar technologies.  We may also receive Technical Data about you if you visit other websites employing our cookies.  Please see our Cookies Policy for further details.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources, as set out below.
  • Technical Data from the following parties:
    • analytics providers such as Google Analytics;
    • media database providers such as Roxhill Media;
    • social media sites such as Facebook, Twitter and LinkedIn;
    • publicly availably sources such as Companies House and the Electoral Register.

 

  1. 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 deliver the terms of the contract we are about to enter into, or have entered into, with you or to perform other legal obligations;
  • 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.

 

In general, we do not rely on consent as a legal basis for processing your personal data.  You have the right to withdraw consent to marketing at any time by contacting us.

 

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of the ways we may 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 us 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

 

To process and deliver services and/or perform contractual obligations for you, including collecting and recovering money owed to us

 

(a) Identity

(b) Contact

(c) Financial

(c) Transaction

(d) Marketing and Communications

 

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover due to us)

 

To manage our relationship with you which will include notifying you about changes to our terms or Privacy Policy

 

 

(a) Identity

(b) Contact

(c) Profile

(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 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

(b) Contact

(c) Technical

 

(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)

(b) Necessary to comply with a legal obligation

(c) Necessary to resolve disputes

 

To use data analytics to improve our website, services, marketing, customer relationships and experiences; provide audit record for consent

 

(a) Technical

(b) Usage

 

Necessary for our legitimate interests (to define types of customers for our 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

(b) Contact

(c) Technical

(d) Usage

(e) Profile

 

Necessary for our legitimate interests (to develop our services and grow our business)

 

 

COOKIES

Phoenix Financial PR uses cookies on the http://www.phoenixfinancialpr.co.uk/ website (the ‘Service’).  By using the Service, you consent to the use of cookies.

Our Cookies Policy explains what cookies are, how we use cookies, how third-parties we may partner with may use cookies on the Service, your choices regarding cookies and further information about cookies.

Please see our Cookies Policy for further information.

 

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 us.

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.

 

  1. DISCLOSURES OF YOUR PERSONAL DATA

 

We will not disclose your personal information to any other party other than in accordance with this Privacy Policy.  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, furthermore if we are legally required by law to disclose your personal information, or to further fraud protection and reduce the risk of fraud.

 

  • Internal Third Parties as set out in the Definitions;
  • External Third Parties as set out in the Definitions;
  • Third-party sub-contractors who provide services for us and/or help to provide services to you. In the event we use sub-contractors who have access to your personal data, we ensure that there are strict contractual terms in place to ensure that they only process personal data to the extent that we instruct them to do so in writing and there are suitably worded confidentiality and data protection clauses in all such contracts;
  • 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 Policy.  We will advise you of any such change.

 

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.

 

  1. DATA SECURITY

 

We and our third-party hosting partners 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.

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.

 

  1. DATA RETENTION

 

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will 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.

Under English law we will normally have to keep basic information about our customers and contracts (including Contact, Identity and Transaction Data) for six years after they cease being customers.  Thereafter, we will generally either destroy or return personal data to the client.

In some circumstances you can ask us to delete your data: see the section below entitled ‘Your Legal Rights’ for further information.

We may also 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.

 

  1. YOUR LEGAL RIGHTS

 

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

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. 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 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 us.

A modest fee will be payable.  We will charge a higher fee if your request is clearly unfounded, repetitive or excessive.  Alternatively, we may refuse to comply with your request in these circumstances.

 

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 numerous requests.  In this case, we will notify you and keep you updated.

 

  1. DEFINITIONS

 

LAWFUL BASIS

 

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service 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 us.

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.

 

THIRD PARTIES

 

EXTERNAL THIRD PARTIES

  • Service providers acting as processors who provide IT and system administration services;
  • Suppliers and consultants helping Phoenix to satisfy legal and/or contractual obligations to you;
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services;
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.

 

  1. CONTACTING US

If you have any queries regarding this Privacy Policy, please do not hesitate to contact us.