Last updated: 22 February 2019
Tweedysmith Limited (“we”, “our”, “us”) are committed to protecting and respecting your privacy. We are a company established in England with a registered office at c/o Legalinx Limited, 1 Fetter Lane, London EC4A 1BR and for the purpose of data protection law, we are the data controller.
This policy sets out the basis on which we will process any personal data or usage information we collect from you, or that you provide to us, in connection with your use of our website at www.tweedysmith.com (the “Website”).
Data protection law says that the personal data we hold about you must be:
Information you give us. You may provide information by contacting us via our Website or email, telephone, instant chat, social media or otherwise, signing up for our newsletters or alerts or by creating an account with us.
We will use your information in the following ways in order to exercise or fulfil our legal or contractual rights and obligations or to pursue our legitimate interests:
Technical usage information. When you visit the Website, we automatically collect the information sent to us by your computer, mobile phone, or other access device. This information includes:
As it is in our legitimate interests to process your data to provide effective services and useful content to you we collect this information in order to:
Marketing. We may collect your name and contact details (such as your email address, phone number or address) in order to send you information about our products and services which you might be interested in.
You always have the right to “opt out” of receiving our marketing. You can exercise the right at any time by contacting us. If we send you any marketing emails, we will always provide an unsubscribe option to allow you to opt out of any further marketing emails. If you “opt-out” of our marketing materials you will be added to our suppression list to ensure we do not accidentally send you further marketing. We may still need to contact you for administrative or operational purposes, but we will make sure that those communications don’t include direct marketing. Where you unsubscribe from any postal marketing, you may initially still receive some content which has already been printed or sent, but we will remove you from any future campaigns.
If you are an existing customer or are acting in a professional capacity as part of a company or LLP we use your contact details as necessary for our legitimate interests in marketing to you and maintaining a list of potential customers.
If you are not an existing customer, and are not acting in a professional capacity as part of a company or LLP, we will only contact you for marketing purposes with your consent (whether we have collected your details directly from you, or through a third party).
We never share your name or contact details with third parties for marketing purposes unless we have your “opt-in” consent to share your details with a specific third party for them to send you marketing. We do use third party service providers to send out our marketing, but we only allow them to use that information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
We retain your details on our marketing list until you “opt-out” at which point we add you to our suppression list. We keep that suppression list indefinitely to comply with our legal obligations to ensure we don’t accidentally send you any more marketing.
Information we receive from third parties. We may receive information about you from the following sources:
We share your information with selected recipients. These categories of recipients include:
We will share your information with law enforcement agencies, public authorities or other organisations if legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:
We will also disclose your information to third parties:
Unfortunately, the transmission of information via the internet or email is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your information transmitted through the Website or over email; any transmission is at your own risk. Once we have received your information, we will take appropriate technical and organisational measures to safeguard your personal data against loss, theft and unauthorised use, access or modification.
Where we share your information with our third-party service providers, they are required to take appropriate security measures to protect your personal information. Where third parties process your personal information on our behalf as “data processors” they must do so only on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where necessary.
We will, from time to time, host links to and from the websites of our affiliates or third parties. If you follow a link to any of these websites, these websites will have their own privacy policies and we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to those websites.
Where your personal data relates to a contract, we will keep it for period of up to six years after the date of the order to enable us to deal with any after sales enquiries or claims and as required for tax purposes.
Payment information which is collected by our payment card processing provider is retained for a period of up to six years after the date of the order.
Any other personal data which does not relate to a particular order will be kept for a period of up to six years. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
Our registered office is in London, England and our main data centre is located in England. However, where required to perform our contract with you or for our wider business purposes, the information that we hold about you may be transferred to, and stored at, a destination outside the UK and the EU. It may also be processed by staff operating outside the UK and EU who work for us or for one of our service providers.
Some countries or organisations outside of the UK and the EU which we may transfer your information to will have an “adequacy decision” in place, meaning the EU considers them to have an adequate data protection regime in place. These are set out on the European Commission website: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.
If we transfer data to countries or organisations outside of the UK and the EU which the EU does not consider to have an adequate data protection regime in place, we will ensure that appropriate safeguards (for example, model clauses approved by the EU or a data protection authority) are put in place where required. To obtain more details of these safeguards, please contact us.
Data protection law gives you a number of rights when it comes to personal information we hold about you. The key rights are set out below. More information about your rights can be obtained from the Information Commissioner’s Office (ICO). Under certain circumstances, by law you have the right to:
Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it (for instance, we may need to continue using your personal data to comply with our legal obligations). You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Object to processing of your personal information 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 us using your information on this basis and we do not have a compelling legitimate basis for doing so which overrides your rights, interests and freedoms (for instance, we may need it to defend a legal claim). You also have the right to object where we are processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party where you provided it to us and we are using it based on your consent, or to carry out a contract with you, and we process it using automated means.
Withdraw consent. In the limited circumstances where we are relying on your consent (as opposed to the other bases set out above) to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another compelling legitimate interest in doing so.
Lodge a complaint. If you think that we are using your information in a way which breaches data protection law, you have the right to lodge a complaint with your national data protection supervisory authority (if you are in the UK, this will be the ICO).
No fee usually required. You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you. We may need to request specific information from you to help us understand the nature of your request, to confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Timescale. Please consider your request responsibly before submitting it. We will respond to your request as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we will let you know.
Any changes we will make to this policy in the future will be posted on this page and, where we consider necessary, notified to you by e-mail. Please check back frequently to see any updates or changes to this policy.
Questions, comments and requests regarding this policy are welcomed and should be addressed to our Data Compliance Officer at Tweedysmith Limited, c/o Legalinx Limited, 1 Fetter Lane, London EC4A 1BR .
Our Website is operated by Tweedysmith Limited (“we”, “our”, “us”). We are registered in England under company number 10991915 and have our registered office at c/o Legalinx Limited, 1 Fetter Lane, London EC4A 1BR.
Access to our Website is permitted on a temporary basis, and we reserve the right to withdraw or amend the service we provide on our Website without notice (see below). We will not be liable if for any reason our Website is unavailable at any time or for any period.
From time to time, we may restrict access to some parts of our Website, or our entire Website, to users who have registered with us.
You are responsible for making all arrangements necessary for you to have access to our Website.
Our Website is directed to people residing in the United Kingdom. We do not represent that content available on or through our Website is appropriate for use or available in other locations. We may accept orders for delivery to locations outside of the United Kingdom subject to customs, legal, regulatory and practical restrictions. If you access our Website from outside of the United Kingdom or place orders for delivery to locations outside of the United Kingdom, you will be responsible for compliance with local laws if and to the extent that they apply.
We are the owner or the licensee of all intellectual property rights in our Website, and in the material published on it. Those works are protected by copyright laws and treaties around the world. All such rights are reserved.
You may only use our Website for lawful purposes and you may not use it in a way that infringes the rights of anyone else or that restricts or inhibits anyone else’s enjoyment of our Website.
You must not, without our prior written consent, copy, reproduce, crawl, frame, republish, download, print, post, distribute, re-post, broadcast, record, transmit, edit, communicate to the public, link to, deep-link into, or distribute in any way the web pages or materials on our Website other than solely for your own personal use.
Our status (and that of any identified contributors) as the authors of material on our Website must always be acknowledged.
You must not use our Website or any part of the materials on our Website for commercial purposes without obtaining a licence to do so from us or our licensors.
Commentary and other materials posted on our Website are not intended to amount to advice on which reliance should be placed. We therefore disclaim all liability and responsibility arising from any reliance placed on such materials by any visitor to our Website, or by anyone who may be informed of any of its contents.
We aim to update our Website regularly, and may change the content at any time. If the need arises, we may suspend access to our Website, or close it indefinitely. Any of the material on our Website may be out of date at any given time, and we are under no obligation to update such material.
Our liability in connection with any product purchased through our Website is limited in accordance with the provisions set out in our Terms of Sale.
Whilst we take reasonable care in relation to our Website, the material displayed on our Website is provided without any guarantees, conditions or warranties as to its accuracy. To the extent permitted by law, we expressly exclude all conditions, warranties and other terms which might otherwise be implied by statute, common law or the law of equity.
Except where required by law, we accept no liability for any loss of income or revenue, loss of business, loss of profits or contracts, loss of anticipated savings, loss of data, waste of management or office time or for any indirect or consequential loss or damage of any kind however arising and whether caused by tort (including negligence), breach of contract or otherwise, even if foreseeable or for any and all and damages, losses or causes of action arising, by reason of or in connection with your use of our Website.
We do not exclude or limit in any way our liability to you where it would be unlawful to do so. This includes our liability for death or personal injury arising from our negligence, and our liability for fraudulent misrepresentation or misrepresentation.
You must not misuse our Website by knowingly introducing viruses, trojans, worms, logic bombs or other material which is malicious or technologically harmful. You must not attempt to gain unauthorised access to our Website, the server on which our Website is stored or any server, computer or database connected to our Website. You must not attack our Website via a denial-of-service attack or a distributed denial-of service attack. In the event of a breach of these obligations, your right to use our Website will cease immediately.
We will not be liable for any loss or damage caused by a distributed denial-of-service attack, viruses or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to your use of our Website or to your downloading of any material posted on it, or on any website linked to it.
You may link to our home page, provided you do so in a way that is fair and legal and does not damage our reputation or take advantage of it, but you must not establish a link in such a way as to suggest any form of association, approval or endorsement on our part where none exists.
You must not establish a link from any website that is not owned by you.
Our Website must not be framed on any other site, nor may you create a link to any part of our Website other than the home page. We reserve the right to withdraw linking permission without notice.
Where our Website contains links to other sites and resources provided by third parties, these links are provided for your information only. We have no control over the contents of those sites or resources, and accept no responsibility for them or for any loss or damage that may arise from your use of them.
TWEEDYSMITH is a registered trade mark of Tweedysmith Limited.