What is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

What Are My Rights?

Under the GDPR, you have the following rights, which wewill always work to uphold:

• The right to be informed about ourcollection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact usto find out more or to ask any questions using the details in Part 12.The right to access the personal data wehold about you. Part 11 will tell you how to do this.
• The right to have your personal data rectified if any of your personal data held by usis inaccurate or incomplete. Please contact ususing the details in Part 12 to find out more.
• The right to be forgotten, i.e. the right to ask usto delete or otherwise dispose of any of your personal data that we Please contact ususing the details in Part 12 to find out more.
• The right to restrict (i.e. prevent) the processing of your personal data.
• The right to object to ususing your personal data for a particular purpose or purposes.
• The right to data portability. This means that, if you have provided personal data to usdirectly, weare using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask usfor a copy of that personal data to re-use with another service or business in many cases.
• Rights relating to automated decision-making and profiling. Wedo not use your personal data in this way.
• For more information about ouruse of your personal data or exercising your rights as outlined above, please contact ususing the details provided in Part 12.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about ouruse of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

What Data Do You Collect?

Depending upon your use of OurSite, wemay collect some or all of the following personal [and non-personal]data:

• [Name;]
• [Date of birth;]
• [Gender;]
• [Address;]
• [Email address;]
• [Telephone number;]
• [Business name;]
• [Job title;]
• [Profession;]
• [Payment information;]
• [Information about your preferences and interests;]
• [IP address];
• [Web browser type and version;]
• [Operating system;]
• [A list of URLs starting with a referring site, your activity on OurSite, and the site you exit to;

How Do You Use My Personal Data?

Under the GDPR, wemust always have a lawful basis for using personal data. This may be because the data is necessary for ourperformance of a contract with you, because you have consented to ouruse of your personal data, or because it is in ourlegitimate business interests to use it. Your personal data maybe be used for the following purposes:

• [Supplying ourproductsAND/OR services]to you. Your personal details are required in order for usto enter into a contract with you.]
• [Personalising and tailoring ourproductsAND/OR services for you.]
• [Communicating with you. This may include responding to emails or calls from you.]
• [Supplying you with informationby [email] AND/OR [post]that you have opted-in to (you may unsubscribe or opt-out at any time) by emailing office@wrightandmurray.co.uk– subject opt-out.

 With your permission and/or where permitted by law, we]may also use your personal data for marketing purposes, which may include contacting you by emailAND/OR telephoneAND/OR text messageAND/OR post with information, news, and offers on ourproductsAND/OR services. You will not be sent any unlawful marketing or spam. Wewill always work to fully protect your rights and comply with ourobligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

How Long Will You Keep My Personal Data?

Wewill not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

• 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.

How and Where Do You Store or Transfer My Personal Data?

We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that wewill take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK. The security of your personal data is essential to usand to protect your data, wetake a number of important measures, including the following:

• We limit access to your personal data to those employees, Contractors and other third parties who have a business need to know only, They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

 Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to one important exception.

In some limited circumstances, wemay be legally required to share certain personal data, which might include yours, if we areinvolved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

If any of your personal data is required by a third party, as described above, wewill take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, ourobligations, and the third party’s obligations under the law, as described above in Part 8.

If any personal data is transferred outside of the EEA, wewill take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 8.

Can I Withhold Information?

You may access certain areas of OurSite without providing any personal data at all. However, to use all features and functions available on OurSite you may be required to submit or allow for the collection of certain data.

How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask usfor details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 12, so we can respond to your request as quickly as possible.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover ouradministrative costs in responding.

We will respond to your subject access request within 14 days working days and, in any case, not more than]one month of receiving it. Normally, weaim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date wereceive your request. You will be kept fully informed of our progress.

How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details [(for the attention of The Office Manager:

Email address: Office@wrightandmurray.co.uk

Changes to this Privacy Policy

Wemay change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if wechange ourbusiness in a way that affects personal data protection.Any changes will be immediately posted on OurSite and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.