For the purpose of the Data Protection Act 1998, the data controller is 3 Colours Rule of 40 Martell Road, SE21 8EN, London, UK.
Collection and use of personal information
We will generally let you know at the time of collection how we intend to use your personal information. Usually, we collect personal information about you which we require to respond to your enquiries for payment processing and for the provision of goods and services to you. We also process your personal information where we are required to do so by law, and for the exercise or defence of legal claims. From time to time, we may contact you for research purposes, or to tell you about our special offers and other services in accordance with your contact preferences. Where appropriate, we will obtain your consent to do so. Personal information collected from you may include your name, payment processing information, postal address, email address, landline or mobile telephone number, delivery details as well as other non-sensitive personal information. If you use our websites, we may also collect information about you or your computer when you browse to allow you to use the services available.
- Important information and who we are
This privacy notice aims to give you information on how we collect and process your personal data, including any data you may provide to us directly (via our website or otherwise) and any data that may be provided to us by third parties.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
Our full details are:
Full name of legal entity: 3 Colours Rule Limited
Name or title of data privacy manager: Flavilla Fongang
Email address: email@example.com
Postal address: 40 Martell road, Office D113, Dulwich, London, SE21 8EN, UK
Telephone number: 020 3617 8706
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the
chance to deal with your concerns before you approach the ICO so please contact us in the first instance if you have any queries or concerns.
This version was last updated on 16 May 2018 and can be obtained by contacting us. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
- The data we collect about you
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 (e.g. anonymous data or statistical data).
We may collect, use, store and transfer different kinds of personal data about current, former and prospective clients, opponents, witnesses, business contacts and other third parties which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender and any KYC (Know Your Client) document required to verify identity (e.g. a passport or a driving licence).
- Contact Data includes registered business address, personal residential address, email addresses, telephone numbers and any KYC documentation required to verify residence (e.g. a financial statement or utility bill).
- Financial Data includes bank account and payment card details and details of funds held in our client and office accounts relating to transactions, cases and other matters involving clients, opponents, witnesses and other third parties.
- Transaction Data includes personal data relating to transactions, cases and other matters involving clients, opponents, witnesses and other third parties (e.g. personal data contained in grievance and disciplinary letters, claims documents and medical records).
- Technical Data includes internet protocol (IP) address, browser type and version, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
- Usage Data includes your preferences and other information about how you use our website and services.
- Marketing and Communications Data includes your preferences in receiving emails and other correspondence from us.
We may also collect Special Categories of Personal Data or Sensitive 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), as well as data about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law or under the terms of a legal agreement we have with you, and you fail to provide that data when requested, we may not be able to perform the legal agreement we have or are trying to enter into with you (for example, to provide you with legal services). In this case, we may have to terminate the legal agreement we have with you but we will notify you in advance if this is the case.
- How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. Current, former and prospective clients, opponents, witnesses, business contacts and other third parties may give us their Identity, Contact and Financial Data in person, by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data they provide to us when they:
- avail of legal services;
- contact us via our website;
- give us instructions;
- subscribe to our newsletter or other publications;
- request to receive marketing or similar information; or
- give us some feedback.
- Automated technologies or interactions. As users interact with our website, we may automatically collect Technical Data about equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about a user’s visit if they visit other websites employing our cookies.
- Third parties or publicly available sources. We may receive Contact, Financial, and Transaction Data about current and prospective clients, opponents, witnesses, business contacts and other third parties from various third parties and public sources. We may receive Technical Data from analytics providers and search information providers. We may also receive Identity and Contact Data from publicly availably sources such as Companies House, the Electoral Register, LinkedIn and other social media platforms.
- How we use your personal data
We will only process personal data and sensitive data when the law allows us to. Most commonly, we will process your personal data and sensitive data where processing is necessary:
- to comply with a legal or regulatory obligation;
- to perform the contract we are about to enter into or have entered into with you;
- for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of the ways we may use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To engage and register new clients including performing anti-money laundering, anti-terrorism, fraud and other background checks||(a) Identity(b) Contact|
|(a) and (b) Legal or regulatory obligation(c) Legal or regulatory obligation for personal data and establishment, exercise or defence of legal claims for sensitive data|
|To manage transactions, projects and other matters involving clients and other third parties including the management of a project.||(a) Identity(b) Contact|
|(a) and (b) Legal or regulatory obligation(c) Legal or regulatory obligation or necessary for our legitimate interests (to recover debts due to us)|
(d) Legal or regulatory obligation for personal data and establishment,
(b) Asking for a review or other feedback in relation to our legal services.
(c) Providing you with information about our legal services and events.
|(a) Identity(b) Contact|
(c) Marketing and Communications
|(a) and (b) Necessary to comply with a legal obligation and performance of a contract with you(c) Necessary for our legitimate interests (to keep our client records up-to-date, to inform our clients about services and events that may be relevant to them and to evaluate how our clients use our services)|
|To carry out conflict of interest checks||(a) Identity(b) Contact|
|(a) and (b) Necessary to comply with a legal obligation and performance of a contract with you(c) Necessary for our legitimate interests (to understand if there is a conflict of interest)|
|To administer and protect our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity(b) Contact|
|(a) to (c) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)|
|To use data analytics to improve our website, services, marketing and client relationships and experiences||(a) Technical(b) Usage||(a) and (b) Necessary for our legitimate interests (to define types of clients who use our legal services, to keep our website up-to-date and relevant, to develop our business and to inform our marketing strategy).|
|To provide you with our newsletter or other publications or communications which make suggestions and recommendations about our services and events||(a) Identity(b) Contact|
(e) Marketing and Communications
|(a) to (e) Necessary for our legitimate interests (to develop our services and develop our business and to inform our marketing strategy).|
We always strive to provide you with choices regarding the uses of your personal data, particularly where we market our services and events to you.
We may use your Identity, Contact, Technical, Usage and Marketing and Communications Data to form a view on the legal services and events that we feel may be of interest to you. This is how we decide which legal services and events may be relevant for you (we call this marketing).
You may receive marketing communications from us if you have requested information from us in the past or if we have provided legal services to you in the past or if you have contacted us for another reason and, in each case, you have not opted out of receiving that marketing.
Where you opt out of receiving marketing messages, this will not apply to personal data provided to us where the processing of such data was necessary to comply with a legal or regulatory obligation, to perform the contract we are about to enter into or have entered into with you or for the establishment, exercise or defence of legal claims.
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 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.
- Job applicants
We will retain your personal information for a period of seven months after we have communicated to you our decision about whether to appoint you to the role you have applied for. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with our data retention policy.
If we wish to retain your personal information on file, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will write to you separately, seeking your explicit consent to retain your personal information for a fixed period on that basis.
- Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
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.
7. International transfers
Some of our external third parties (e.g. Outlook 365 who provide our email and cloud storage services) may be based outside the European Economic Area (EEA) so the processing of your personal data may involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
- Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, altered, disclosed, used or accessed in an unauthorised way.
Our technical security measures include password protection for our IT systems and documents, anonymization and pseudonymisation of documents where possible.
Our organisational security measures include physical security measures for our premises, limiting 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). We have also 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.
- Data retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, 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, and the applicable legal requirements.
By law we have to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for at least 7 years after they cease being clients (13 years for clients whose files contain deeds).
In some circumstances you can ask us to delete your data and in some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
- Your legal rights
No fee usually required
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.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
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.
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.
Performance of Contract means processing your personal data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Establishment, exercise or defence of legal claims means processing your personal data where it is necessary for the establishment, exercise or defence of a legal claim concerning you or a third party.
Internal Third Parties
Other companies in our corporate group who may act as joint controllers or processors and who may be based inside or outside the EU.
External Third Parties
- Service providers who may act as processors based inside or outside the EU, including accountants who provide payroll services, IT consultants, dictation service providers, cloud-based document management service providers (Law Fusion), email and cloud storage service providers (Outlook 365), shredding service providers, email service providers (MailChimp), hard-copy archive service providers, mobile phone hardware, software and service providers (Apple) and other services.
- Professional advisers who may act as controllers or processors including solicitors, barristers, accountants, costs assessors, auditors and other professional advisers based inside or outside the EU who provide legal, financial, consultancy and other professional advisory services.
Regulators and other authorities who may act as processors based inside or outside the EU who require reporting of processing activities in certain circumstances (e.g. HMRC and the SRA).
YOUR LEGAL RIGHTS
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. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that 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) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. You have an absolute right to object where we are processing your personal data for direct marketing purposes.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. This right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent.
Website usage & cookies
Your use of our website indicates your consent to the cookies described in this policy.
What are cookies?
A web cookie, a commonly used data collection technology, is simply a piece of text which can be placed on the browser of your personal computer or mobile device and subsequently read as you visit a website. A cookie may be a session cookie, that is, a cookie that remains on your browser while you are logged on to a particular website and then disappears when you close your browser, or it may be a persistent cookie, a cookie that remains on your browser over a period of time. Information from a cookie may be collected and used in aggregate form. Or data may be collected into an individual profile or record. That individual record may either be unique but anonymous, or the profile can be linked with information that identifies you as an individual.
You can learn more about cookies, generally, at www.allaboutcookies.org
- We may use a limited number of cookies essential to particular services you have requested or for security purposes. A few of our sites use a cookie for a shopping cart function when you purchase services or offerings. In particular, if you have registered for a site or use a customer portal we may use a cookie to authenticate the pc or mobile device that you are using.
- We allow third parties to set analytics, or performance, cookies to collect and report aggregate information. These cookies provide reporting to us on an aggregate basis and so, do not identify you at all. We use the aggregate reports to understand how our web sites are used and improve their usefulness to our audiences.
- A number of cookies also support how our websites function, identifying your pc or end device on a unique but anonymous basis. These cookies may, for example, remember your language preferences or recognize an individual’s activity within a single session.
- Some of sites may also allow third party ad servers to serve their own cookies to display advertising on our websites. We do not determine, control or have access to their cookies. In addition, some of the ads they serve may generate their own cookies.
How you can control cookies
The cookies we us are an accepted part of ecommerce and important to your use of our websites. Performance cookies allow us to understand our audiences as a whole and improve how our sites meet your needs and expectations. Many the functional cookies are basic to how our sites and services work. The cookies we use for registration allow us to conduct our business online. Our sites and services, or parts of them, may not work properly without these cookies.
Your use of our websites indicates your consent to the cookies we have described in this Policy.
But if you should wish to revoke that consent, or any part of it, at any time you may control cookies and third party ad targeting in the following ways.