HAROLD BELL INFIELDS & CO
DATA PROTECTION PRIVACY NOTICE

 
  1. The business of Harold Bell Infields & Co of Devon House, 174 Kingston Road  Ewell  Surrey  KT19 0SD  is registered with the Information Commissioner’s Office (“ICO”) under number Z7389061
  2. If you have any questions about this privacy notice (“Notice”), please contact us by email.
  3. Harold Bell Infields & Co will process your and third parties’ personal data, as further explained below, in the course of providing you with associated services [including access to our website and online features] (“Services”).
  4. We will let you know by posting on our website or otherwise, if we make any changes to this Notice from time to time. Your continued use of the Services after notifying such changes will amount to your acknowledgement of the amended Notice.
  5. PLEASE NOTE: You shall and you hereby agree to indemnify Harold Bell Infields & Co and its affiliates and their officers, employees, agents and subcontractors (each an “Indemnified Party”) from and against any claims, losses, demands, actions, liabilities, fines, penalties, reasonable expenses, damages and settlement amounts (including reasonable legal fees and costs) incurred by any Indemnified Party arising out of or in connection with any breach by you of the warranties included in paragraph 8.
  What is Personal Data?
  1. Personal data” means any information relating to an identified or identifiable natural person, known as ‘data subject’, who can be identified directly or indirectly; it may include name, address, email address, phone number, IP address, location data, cookies and similar information. It may also include “special categories of personal data” such as racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a data subject, data concerning health or data concerning a natural person's sex life or sexual orientation.
  2. Harold Bell Infields & Co may process personal data and special categories of personal data which you provide in connection with the Services about yourself and other data subjects, e.g. individuals whose details are included in any materials provided by you to Harold Bell Infields & Co. Harold Bell Infields & Co  may obtain information about you and other data subjects from third party service providers, such as due diligence platforms. If you use our online Services, Harold Bell Infields & Co  may collect information about your devices including clickstream data.
  3. The provision of certain personal data is mandatory in order for Harold Bell Infields & Co to comply with mandatory client due diligence requirements and consequently to provide the Services. You warrant on a continuous basis that such personal data is accurate, complete and up to date. Failure to comply may result in documents being rejected by the relevant certification authorities, held invalid in the destination country or other difficulty to successfully completing the Services.
 
  1. In relation to personal data of data subjects you warrant to Harold Bell Infields & Co on a continuous basis that:
  How do we use your personal data?  
  1. Harold Bell Infields & Co will only process personal data, in accordance with applicable law, for the following purposes:
The legal basis for our processing of personal data for the purposes described above will typically include:   Cookie policy What exactly are cookies?
  1. In order to collect the information including personal data as described in this Notice, we may use cookies and similar technology on our website. A cookie is a small piece of information which is sent to your browser and stored on your computer’s hard drive, mobile phone or other device. You can set your browser to notify you when you receive a cookie. This enables you to decide if you want to accept it or not. However, some of the Services offered through our website may not function properly if your cookies are disabled.
  2. Cookies can be first party or third party cookies.
  The cookies placed on our website
  1. We use the following cookies on our website:
 
  1. We may combine information from these types of cookies and technologies with information about you from other sources.
Cookie consent and opting out
  1. We assume that you are happy for us to place cookies on your device. Most Internet browsers automatically accept cookies. However, if you, or another user of your device, wish to withdraw your consent at any time, you have the ability to accept or decline cookies by modifying your browser setting. If you choose to decline cookies, you may not be able to fully experience the interactive features of our website, our platforms and Services.
  2. When you arrive on our website a pop-up message will appear asking for your consent to place advertising cookies on your device.  In order to provide your consent, please click ‘I understand’. Once your consent has been provided, this message will not appear again when you revisit.  If you, or another user of your device, wish to withdraw your consent at any time, you can do so by altering your browser settings otherwise we will assume that you are happy to receive cookies from our website. For more information please visit allaboutcookies.org and http://www.youronlinechoices.com/uk/.
  Disclosure of personal data
  1. There are circumstances where Harold Bell Infields & Co may wish to disclose or is compelled to disclose your personal data to third parties. These scenarios include disclosure to:
  International transfer of your personal data
  1. We may transfer your personal data to a third party in countries outside the country in which it was originally collected for further processing in accordance with the purposes set out above. In particular, your personal data may be transferred to foreign organisations such as foreign Embassies located in the UK or abroad. Such organisations will process personal data in accordance with the laws to which they are subject and international treaties over which Harold Bell Infields & Co has no control.
  2. If Harold Bell Infields & Co transfers personal data to private organisations abroad, such as subcontractors, it will, as required by applicable law, ensure that your privacy rights are adequately protected by appropriate technical, organisation, contractual or other lawful means. You may contact us for a copy of such safeguards in these circumstances.
Retention of personal data
  1. Your personal data will be retained for as long as is reasonably necessary for the purposes listed above or as required by the law. For example, the Practice Rules require that that ………………… in the public form shall be preserved permanently. Records of acts not in public form shall be preserved for a minimum period of 12 years. Please contact us for further details of applicable retention periods. Personal data may for reasons of security and convenience be stored on remote data facilities but in an encrypted form.
  2. [We may keep an anonymized form of your personal data, which will no longer refer to you, for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so.]
Security of personal data
  1. Harold Bell Infields & Co will implement technical and organisational security measures in order to prevent unauthorised access to your personal data.
  2. However, please be aware that the transmission of information via the internet is never completely secure. Whilst we can do our best to keep our own systems secure, we do not have full control over all processes involved in, for example, your use of our website or sending confidential materials to us via email, and we cannot therefore guarantee the security of your information transmitted to us on the web.
Data subject rights
  1. Data subjects have numerous rights in relation to their personal data. For further information about your data protection rights please visit the ICO website.