Introduction

P A Finlay is committed to protecting your privacy. This Privacy Notice explains how P A Finlay use any personal information that we may collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe.

We know that there’s a lot of information here, but we want you to be fully informed about your rights, and how we use your data. 

Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this Privacy Notice. We may change this Privacy Notice by updating this page. We’ll notify you of any significant changes, but you’re welcome to come back and check it whenever you wish.

Topics:

1. When do we collect your information and what information do we collect?

2. Reasons for collecting personal information

3. Use of your information

4. Sharing your information

5. How long do we keep your information?

6. Recording calls

7. Your Rights

8. Cookies

9. Where we store your personal data

10. How to contact us

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1. When do we collect your information and what information do we collect?

 

We collect your information:
 

• When you visit any of our websites or portals.

• When you engage with us on social media.

• When you contact us with queries or complaints, or to report a problem with our website.

• When you ask one of our partners to email you information about a product or service.

• When you enter prize draws or competitions, or complete any surveys we send you.

• When you book an appointment with us or book to attend an event e.g. conference.

• When you comment on or review our products and services.

• When you fill in any forms.

• When you permit a third party to share with us the information they hold about you.
   

We collect data from publicly-available sources (such as Companies House) where the information is made public as a matter of law.

We will collect and process the following information about you:
 

• Information you give us. This may include your name, gender, address, e-mail address and phone number, financial and credit card information, personal description and photograph.

• Information we collect about you. With regard to each of your visits to our website we will automatically collect the following information:

• Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

• Information about your visit, including the full Uniform Resource Locators (URL), to, through and from our website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.

• Information we receive from other sources. This is information we receive about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data if we intend to share that data internally and combine it with data collected on this website. We will also have told you for what purpose we will share and combine your data. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment services, advertising networks, analytics providers, credit reference agencies). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.

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2. Reasons for collecting Personal Information

The type of information that we collect is limited to that which is necessary.

• To Deal with your Enquiries

For online or telephone enquiries, we will generally require basic information such as your name and contact details in order to be able to deal with your enquiry.

• Training and Quality Purposes

Telephone calls made to certain telephone numbers within the Group may be recorded for training and quality purposes. See also section 6 (Recording Calls) below.

• Website Registration

To register online to receive, for example, email alerts or access to certain documentation, we will require certain basic information from you together with confirmation of the alerts or documentation that you wish to receive.

• Business Purposes

When you enter into a business relationship with us, the information that we will require will be of a more detailed nature and may include your business address and contact details. We will need this information to ensure that we provide the requested services to you, and for general administrative purposes (e.g. managing your account and obtaining credit checks).

Any contract we have with you will be governed either by: (i) the applicable standard T&Cs; or (ii) bespoke contractual documentation agreed with our customers.

•​ Research

We may hold your personal details for research purposes, but in this case, we will never make your personal details available to other companies for marketing purposes other than for the marketing of the Group’s products and services or where you have requested us to do so.

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3. Use of your information

We use information held about you in the following ways:

Information you give to us. We will use this information:

• to carry out our obligations arising from any contracts entered into between us and to provide you with the information and services that you request from us;

• to provide you with information about other services we offer that are similar to those that you have already purchased or enquired about;

• to provide you with information about services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about services similar to those which were the subject of a previous sale or negotiations of a sale to you;

• to notify you about changes to our services;

• to ensure our website content is presented in the most effective manner for you and your computer.

Information we collect about you. We will use this information:

• to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

• to improve our website to ensure that content is presented in the most effective manner for you and for your computer;

• as part of our efforts to keep our website safe and secure;

• to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;

• to make suggestions and recommendations to you and other users of our website about products or services that may interest you or them.

Information we receive from other sources. We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above.

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4. Sharing your Information

We sometimes share your personal data with trusted third parties, including:

• Any member of our Group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

• Carefully selected third parties including:

• business partners, suppliers and sub-contractors for the performance of any contract we enter into with you;

• technology companies who support our website and other online systems (for example, our software development partner, MMT Digital);

• advertisers and advertising networks that require the data to select and serve relevant adverts to you and others.  We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users;

• marketing companies who help us manage our electronic communications with you to show you products that might interest you while you’re browsing the internet. See our Cookies Policy for further details;

• analytics and search engine providers that assist us in the improvement and optimisation of our website;

• data insight companies to ensure your details are up to date and accurate; and

• credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.

We may disclose your personal information to third parties for their own purposes in very specific circumstances, including:

• With your consent, given at the time you supply your personal data, we may pass that data to a third party for their direct marketing purposes.

• If we decide to expand, reduce or sell any company in the Group or substantially all of its assets, in which case personal data regarding our customers will be transferred to the new owner, under the terms of this Privacy Notice.

• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation; or to protect the rights, of any Group company, our customers, or others. This includes exchanging information with other organisations for the purposes of fraud protection and credit risk reduction.

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5. How long do we keep your information

Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected. At the end of that retention period, your data will either be deleted completely or anonymised (e.g. by aggregating it with other data so that it can be used in a non-identifiable way for business planning).

In certain cases, the law requires us to keep personal data for a specific period (e.g. a minimum of forty years in the case of COSHH records).

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6. Recording Calls

We may record calls for training and quality purposes. Where your call is to be recorded, you will be informed of this at the beginning of the call. We will not use the information that we collect from you for any purposes other than for training and monitoring the quality of the information that we provide to you during the call.

Call recordings are stored securely and access to such recordings is limited to certain personnel only. Recorded calls will be saved for no longer than is necessary.
 

7. Your Rights

You have the right to request:

• Access to the personal data we hold about you, free of charge in most cases.

• The correction of your personal data when incorrect, out of date or incomplete.

• That we stop using your personal data for direct marketing (either through specific channels, or all channels).

• Review of any decision made based solely on automatic processing of your data (i.e. where no human has yet reviewed the outcome and criteria for the decision).

To ask for your information to be amended, please update your online account, or contact your account manager or our Data Protection Officer.

If we choose not to action your request we will explain to you the reasons for our refusal.

Your right to withdraw consent

Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.

Where we rely on our legitimate interest

Where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must comply unless we believe we have a legitimate overriding reason to continue processing your personal data.

Direct marketing

You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.

Checking your identity

To protect your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.

Partner websites

Our website may contain links to and from the websites of our partner networks, Affinity scheme partners, advertisers and affiliates.  Please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.  You should check these policies before you submit any personal data to these websites.

Complaints

If you wish to raise a complaint on how we have handled your personal data, you can contact our Data Protection Officer who will investigate the matter.

If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to the Information Commissioner’s Office (ICO).

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8. Cookies

Our website uses cookies to distinguish you from other website users. This helps us to provide you with a good browsing experience. For detailed information on the cookies we use and the purposes for which we use them, see our Cookie policy

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9. Where we store your personal data

The data that we collect from you will not be transferred to or stored at a destination outside the European Economic Area ("EEA"). We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Notice.

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where you have chosen a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

 

10. How to contact us

We hope this Privacy Notice has been helpful in terms of how we use your personal data and your rights in relation to such personal data. If you have any questions or wish to make a complaint, please contact our Data Protection Officer:

• Email us at compliance@pafinlay.com

• Write to us at Data Protection Officer, Angel House, 6 Rowse Close, London, E15 2HX

This Privacy Notice was last updated on 21 May 2018.