All data subjects whose personal data is collected, in line with the requirements of the GDPR. Under General Data Protection Regulation (“GDPR”) Culverlands operates as both Controller and Processor of data. We are required to collect, hold, process and store personal/sensitive data of our clients so as to provide them with our services. This collection and processing of data will be kept to a minimum and done for sole purpose of providing our services and complying with various statutory and regulatory obligations. Should you continue applying for a service (be it successful or not) you are entering a voluntary contractual agreement with Culverlands for services and consent for your data is a condition of this agreement. Should you not want to undertake providing personal data on this contractual basis then please don’t apply for services.
- The Data Protection Officer is responsible for ensuring that this notice is made available to data subjects prior to Culverlands collecting/processing their personal data.
- All employees of Culverlands who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and their consent to the processing of their data is secured.
- Privacy notice
- Who are we?
Our Data Protection Officer can be contacted directly here: K. Huisamen: firstname.lastname@example.org. In order for us to provide you with any service we need to collect personal and corporate data for correspondence purposes.
We may collect the following information:
- name and job title
- contact information including email address
- demographic information such as postcode, preferences and interests
- other information relevant to customer surveys and/or offers
- banking, financial and investment information
- in the course of due diligence, we may collect information about past employment, criminal or civil litigation and/or action you were party to, whether domestic or overseas. If you are a politically exposed person, or a family member of a politically exposed person, we may also hold such information
- full information about any corporation or organisation you are or were a director, partner or principal in.
How will Culverlands use the personal data it collects about me?
Culverlands will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Culverlands is required to retain information in accordance with the law, such as information needed for income tax and audit purposes and as required by the Financial Conduct Authority and the Information Commissioner. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs. We may also use the information to improve our products and services
3.2 Not consent
You are not providing information by consent, but by a Voluntary Agreement. You are unable to request removal of personal data while you hare receiving, holding or processing products or services provided by us.
Culverlands will not pass on your personal data to third parties, except for such third parties as are required to enable the firm to provide you with services and any such professional services we utilize in due diligence.
3.4 Retention period
Culverlands will process personal data for the periods as required by the Information Commissioner, the Financial Conduct Authority and other laws.
- Right of access – you have the right to request a copy of the information that we hold about you.
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
- Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object to certain types of processing such as direct marketing.
- Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
- Right to judicial review: in the event that Culverlands refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.
All of the above requests will be forwarded on should there be a third party involved (as stated in 3.3 above) in the processing of your personal data.
In the event that you wish to make a complaint about how your personal data is being processed by Culverlands (or third parties as described in 3.3 above), or how your complaint has been handled, you have the right to lodge a complaint directly with Culverlands’s data protection representative Data Protection Officer, K. Huisamen: email@example.com or by post to the company’s address as can be found on its website or on the public register at Companies House.
Online privacy statement
Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
Links to other websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
Can I find out the personal data that the organisation holds about me?
Culverlands at your request, can confirm what information we hold about you and how it is processed. If Culverlands does hold personal data about you, you can request the following information:
- Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU.
- Contact details of the data protection officer, where applicable.
- The purpose of the processing as well as the legal basis for processing.
- If the processing is based on the legitimate interests of Culverlands or a third party, information about those interests.
- The categories of personal data collected, stored and processed.
- Recipient(s) or categories of recipients that the data is/will be disclosed to.
- If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
- How long the data will be stored.
- Details of your rights to correct, erase, restrict or object to such processing.
- Information about your right to withdraw consent at any time.
- How to lodge a complaint with the supervisory authority.
- Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
- The source of personal data if it wasn’t collected directly from you.
- Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
Document Owner and Approval
The Data Protection Officer is the owner of this document and is responsible for ensuring that this record is reviewed in line with the review requirements of the GDPR