Privacy Policy

This policy has been updated as of December 2019 and will continue to be updated and improved.

Our Privacy Policy explains in detail the types of personal data we may collect about you. It also explains how we’ll store and handle that data and keep it safe.

WHO ARE WE?

References in this Privacy Policy to “Witten Law Ltd.”, “we”, “us” or “our” mean Witten Law, Ltd. of Blackwell House, Guildhall Yard, London, EC2V 5AE

We are a law firm regulated by the Solicitors Regulation Authority under SRA number: 656660.

We control the ways your personal data are collected and the purposes for which your personal data are used by Witten Law Ltd. and are the “data controller” for the purposes of the EU General Data Protection Regulation (GDPR).

You may enquire on the data we hold on you at any time by contacting info@wittenltd.com and request that such data be removed.

WHO IS THIS POLICY FOR?

We may keep personal data in order to provide you with the level of service you require from us. This includes but is not limited to clients, suppliers, social media engagers.

WHEN DO WE COLLECT YOUR PERSONAL DATA?

We may collect personal data from you in the following ways:

• When you make an online purchase on our website
• When you contact us by email or by phone enquiring about our services.
• When you engage with us on social media.
• When you contact us by any means with queries, complaints, etc.
• When you email any email with an @wittenltd.com domain name (e.g. info@wittenltd.com).
• When you complete any surveys, we send you.
• When you comment on or review our services.
• When you've given a third-party permission to share with us information, they hold about you.
• When you visit Witten Law, Ltd. the entry door and staircase have CCTV systems operating for the security of all visitors and staff.

WHAT PERSONAL DATA DO WE COLLECT?

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, outlined in the following ways:

• Identity Data including first name, last name, title, your image when you provide photograph ID.
• Contact Data including billing address, delivery address, email address, telephone numbers. We will also collect your social media username, if you interact with us through those channels.
• Financial Data including bank account.
• Transaction Data including details about payments to and from you and other details of products you have purchased from us.
• Data including legal service purchases made by you, feedback and survey responses.
• Marketing and Communications Data includes your preferences in receiving marketing from us including the newsletter/blogs.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. Unless it is specifically related to a case we have been entrusted and this information is a necessity.

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

HOW AND WHY DO 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 ways:

• Where we need to perform the contract, we are about to enter into or have entered into with you.
• 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.

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

• Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message.
• Examples of how we use information held about you include:

• To respond to your queries, enquiries, communication to enable us to provide the service to you, requests and complaints. Handling the information, you send enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
• To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.
• If we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. We aim to protect the individuals we interact with from criminal activities.
• To send you relevant communications by email or post in relation to updates and services. We'll do this on the basis of our legitimate business interest. You are free to opt out of hearing from us by email or post at any time.
• To comply with our contractual or legal obligations to share data with law enforcement.
• To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you.
• To build a picture of who you are and your interests, and to inform our business decisions, we'll combine data captured by Walker Rose Solicitors, third parties and data from publicly available lists. We'll do this on the basis of our legitimate business interest.

WHO DO WE SHARE YOUR PERSONAL DATA WITH?

We may have to share your personal data with the parties set out below for the purposes outlined in 'How and why we use your personal data’.

Examples of the kind of third parties we work with are:

• IT companies who support our website and other business systems.
• Barristers and barrister chambers who are instructed to assist on your case.
• Any experts instructed on your case such as doctors, accountants, surveyors.
• Operational companies such as couriers and third-party delivery programs that assist with courier delivery.
• For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.
• We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.

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.

In order to protect your privacy we will:

• Only provide the information necessary to perform their specific services
• Only use their data for the exact purpose we specify in our contract with them
• Work closely with them to ensure their privacy is respected and protected at all times

Sharing your data with third parties for their own purposes:

• We do not share your data with any third parties except with your permission and for the purpose for which it was originally provided.
• Competition entrants have the opportunity to opt in to receive third party
• We do not trade, sell or otherwise circulate your data for commercial purposes.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies see our cookie policy.

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.

HOW DO WE PROTECT YOUR DATA?

The security of your personal data is very important to us and we are committed to treating it with the utmost care, taking all appropriate steps to protect it.

• We 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. Access to your personal data is password-protected, and sensitive data (such as payment card information) is secured and tokenised to ensure it is protected.
• We secure access to all transactional areas of our websites and apps using 'https' technology.
• We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.
• 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.

HOW LONG DO WE KEEP YOUR DATA?

We will not retain your personal data for longer than necessary for the purposes set out in this Policy. Different retention periods apply for different types of data, however the longest we will normally hold any personal data is 6 years.

HOW DO WE USE ADVERTISING?

We use Google AdWords software for remarketing purposes. This helps us reach people who previously visited our website and match the right people with the right message.

• We use Google AdWords to advertise based on past visits to wittenltd.com
• Third-party vendors, including Google, use cookies to serve ads based on past visits to wittenltd.com
• We don’t collect or store your personal information (e.g. your name or address) so this information can’t be used to identify who you are.

What rights do you have regarding your personal data?

You have rights under data protection laws in relation to your personal data.
You have the right to:

• 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. 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). You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have legitimate grounds to process your information which override your rights.
• 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.
• 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.

If you wish to exercise any of the rights set out above, please contact info@wittenltd.com.

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

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

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 a number of requests. In this case, we will notify you and keep you updated.