• CLIENTS: In order to provide the best possible services and the most accurate advice and information to you, we need to process certain information about you. We only ask for details that will genuinely help us to help you, such as your name, age, contact details, your employment background, immigration status, nationality/citizenship information, financial information, information about members of your family (as may be appropriate), extra information which you may choose to tell us, IP address, dates, times and frequency with which you access our services, CCTV footage if you attend our premises.
• To the extent that you access our website we will also collect certain data from you. We use “cookies”. A “cookie” is a bite-sized piece of data that is stored on your computer’s hard drive. They are used by nearly all websites and do not harm your system. We use them to track your activity to help ensure you get the smoothest possible experience when visiting our website. We can use the information from cookies to ensure we present you with options tailored to your preferences on your next visit. We can also use cookies to analyse traffic and for advertising purposes. If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings.
• If you don’t want to receive cookies that are not strictly necessary to perform basic features of our site, you may choose to opt-out by changing your browser settings.
• Most web browsers will accept cookies but if you would rather we didn’t collect data in this way you can choose to accept all or some, or reject cookies in your browser’s privacy settings. However, rejecting all cookies means that you may not be able to take full advantage of all our website’s features. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences.
• For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.
• WEBSITE USERS: We collect a limited amount of data from our Website Users which we use to help us to improve your experience when using our website and to help us manage the services we provide. This includes information such as how you use our website, the frequency with which you access our website, and the times that our website is most popular.
A number of elements of the personal data we collect from you are required to enable us to fulfil our contractual duties to you or to others. Other items may simply be needed to ensure that our relationship can run smoothly. Depending on the type of personal data in question and the grounds on which we may be processing it, should you decline to provide us with such data, we may not be able to fulfil our contractual requirements or, in extreme cases, may not be able to continue with our relationship.
CLIENT DATA: There are two main ways in which we collect your personal data:
1) Directly from you; and
2) From third parties (e.g., introducers) and other limited sources (e.g. online and offline media).
To the extent that you access our website or read or click on an email from us, we may also collect certain data automatically or through you providing it to us.
Please note that communications to and from our staff, including emails, may be reviewed as part of internal or external investigations or litigation.
If we have not had meaningful contact with you (or, where appropriate, the company you are working for or with) for a period of two years, we will Delete your personal data from our systems unless we believe in good faith that the law or other regulation requires us to preserve it (for example, because of our obligations to tax authorities or in connection with any anticipated litigation).
Ashton Rose Ltd. is a UK organisation that often uses international suppliers – this is what enables us to offer the level of services that we do. In order for us to continue operating in this way, we may have to transfer or store your data internationally.
Ashton Rose Ltd. may control the peraonal data tailored to your preferences on your next visit. We can also use cookies to analyse traffic and for advertising purposes.
If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings.
If you don’t want to receive cookies that are not strictly necessary to perform basic features of our site, you may choose to opt-out by changing your browser settings.
Most web browsers will accept cookies but if you would rather we didn’t collect data in this way you can choose to accept all or some, or reject cookies in your browser’s privacy settings. However, rejecting all cookies means that you may not be able to take full advantage of all our website’s features. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences.
For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.
So you’re looking for a bit more insight into what data we collect about you? Here’s a more detailed look at the information we may collect. The information described below is, of course, in addition to any personal data we are required by law to process in any given situation.
CLIENT DATA: Depending on the relevant circumstances and applicable laws, we may collect some or all of the information listed below to enable us to offer you employment opportunities which are tailored to your circumstances and your interests. In some jurisdictions, we are restricted from processing some of the data outlined below. In such cases, we will not process the data in those jurisdictions:
• Please note that the above list of categories of personal data we may collect is not exhaustive.
SUPPLIER DATA: We don’t collect much data about Suppliers – we simply need to make sure that our relationship runs smoothly. We’ll collect the details for our contacts within your organisation, such as names, telephone numbers and email addresses. We’ll also collect bank details, so that we can pay you. We may also hold extra information that someone in your organisation has chosen to tell us.
PEOPLE WHOSE DATA WE RECEIVE FROM CLIENTS, SUCH AS DEPENDANTS: This may include your names, your contact details, your date of birth and other information which the Client chooses to disclose to us.
WEBSITE USERS: We collect a limited amount of data from our Website Users which we use to help us to improve your experience when using our website and to help us manage the services we provide. This includes information such as how you use our website, the frequency with which you access our website, your browser type, the location you view our website from, the language you choose to view it in and the times that our website is most popular. If you contact us via the website, for example by using the chat function, we will collect any information that you provide to us, for example your name and contact details.
• CLIENT DATA: We collect Client personal data in three primary ways:
1. Personal data that you, the Client, give to us;
2. Personal data that we receive from other sources; and
3. Personal data that we collect automatically.
• Personal data you give to us
• Ashton Rose Ltd. need
• We collect your data automatically via cookies, in line with cookie settings in your browser. If you are also a Client, we may use data from your use of our websites to enhance other aspects of our communications with or service to you.
Having obtained data about you, we then use it in a number of ways.
• CLIENT DATA: We generally use Client data in three ways:
Here are some more details about each:
Obviously, our main area of work is to provide you services in those areas in which Ashton Rose Ltd. operates. We’ve listed below various ways in which we may use and process your personal data for this purpose, where appropriate and in accordance with any laws and requirements. Please note that this list is not exhaustive.
We may use your personal data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not happy about this, in certain circumstances you have the right to object.
We may periodically send you information that we think you may find interesting. In particular, we may wish to use your data for the purposes listed below, where appropriate. Please note that this list is not exhaustive.
To:
To help us to establish, exercise or defend legal claims
• SUPPLIER DATA: We realise that you’re probably busy, and don’t want us to be contacting you about all sorts of things. To find the right balance, we will only use your information:
PEOPLE WHOSE DATA WE RECEIVE FROM CLIENTS, SUCH AS
DEPENDANTS AND EMERGENCY CONTACTS: We will only use the information that our Client gives us about you for the following purposes:
• We may use your personal data for these purposes if we deem this to be necessary for our legitimate interests.
• If you are not happy about this, you have the right to object.
• WEBSITE USERS: We use your data to help us to improve your experience of using our website, for example, by analysing your recent searches to help us to present such services that we think you’ll be interested in.
• Where appropriate, we may share your personal data, in various ways and for various reasons, with the following categories of people:
• We are committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures. These include measures to deal with any suspected data breach.
• If you suspect any misuse or loss of or unauthorised access to your personal information please let us know immediately.
• We will delete your personal data from our systems if we have not had any meaningful contact with you (or, where appropriate, the company you are working for or with) for two years (or for such longer period as we believe in good faith that the law or relevant regulators require us to preserve your data). After this period, it is likely your data will no longer be relevant for the purposes for which it was collected.
• When we refer to “meaningful contact”, we mean, for example, communication between us (either verbal or written), or where you are actively engaging with our online services. If you are a Client we will consider there to be meaningful contact with you if you provide your updated KYC documents, request any services from us, request that we comment on any news or legal update or take part in any of our webinar. We will also consider it meaningful contact if you click through from any of our marketing communications. Your receipt, opening or reading of an email or other digital message from us will not count as meaningful contact – this will only occur in cases where you click-through or reply directly.
• One of the GDPR’s main objectives is to protect and clarify the rights of EU citizens and individuals in the EU with regards to data privacy. This means that you retain various rights in respect of your data, even once you have given it to us. These are described in more detail below.
• To get in touch about these rights, please contact us. We will seek to deal with your request without undue delay, and in any event within one month (subject to any extensions to which we are lawfully entitled). Please note that we may keep a record of your communications to help us resolve any issues which you raise.
• Right to object: this right enables you to object to us processing your personal data where we do so for one of the following four reasons: (i) our legitimate interests; (ii) to enable us to perform a task in the public interest or exercise official authority; (iii) to send you direct marketing materials; and (iv) for scientific, historical, research, or statistical purposes.
• The “legitimate interests” and “direct marketing” categories above are the ones most likely to apply to our Website Users, Clients and Suppliers. If your objection relates to us processing your personal data because we deem it necessary for your legitimate interests, we must act on your objection by ceasing the activity in question unless:
• If your objection relates to direct marketing, we must act on your objection by ceasing this activity.
• Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example, for our marketing arrangements or automatic profiling), you may withdraw this consent at any time and we will cease to carry out the particular activity that you previously consented to unless we consider that there is an alternative reason to justify our continued processing of your data for this purpose in which case we will inform you of this condition.
• Data Subject Access Requests (DSAR): You may ask us to confirm what information we hold about you at any time, and request us to modify, update or delete such information. We may ask you to verify your identity and for more information about your request. If we provide you with access to the information we hold about you, we will not charge you for this unless your request is “manifestly unfounded or excessive”. If you request further copies of this information from us, we may charge you a reasonable administrative cost where legally permissible. Where we are legally permitted to do so, we may refuse your request. If we refuse your request we will always tell you the reasons for doing so.
• Right to erasure: You have the right to request that we erase your personal data in certain circumstances. Normally, the information must meet one of the following criteria:
• We would only be entitled to refuse to comply with your request for one of the following reasons:
• When complying with a valid request for the erasure of data we will take all reasonably practicable steps to delete the relevant data.
• Right to restrict processing: You have the right to request that we restrict our processing of your personal data in certain circumstances. This means that we can only continue to store your data and will not be able to carry out any further processing activities with it until either: (i) one of the circumstances listed below is resolved; (ii) you consent; or (iii) further processing is necessary for either the establishment, exercise or defence of legal claims, the protection of the rights of another individual, or reasons of important EU or Member State public interest.
• The circumstances in which you are entitled to request that we restrict the processing of your personal data are:
• If we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal data.
• Right to rectification: You also have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. Where appropriate, we will also tell you which third parties we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.
• Right to lodge a complaint with a supervisory authority: You also have the right to lodge a complaint with your local supervisory authority.
• If you would like to exercise any of these rights, or withdraw your consent to the processing of your personal data (where consent is our legal basis for processing your personal data), details of how to contact us can be found on Ashton Rose Ltd. webpage. Please note that we may keep a record of your communications to help us resolve any issues which you raise.
• You may ask to unsubscribe from our marketing materials or electronic communications at any time.
• It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during the period for which we hold your data.
• Ashton Rose Ltd. is responsible for processing your personal data. If you have any comments or suggestions concerning this Privacy Policy please contact us immediately. We take privacy seriously so we’ll get back to you as soon as possible.
HOW DO WE STORE AND TRANSFER YOUR DATA INTERNATIONALLY?
• So you want to know more about how we store and transfer your data internationally? In order to provide you with the best service and to carry out the purposes described in this Privacy Policy, your data may be transferred:
• We want to make sure that your data are stored and transferred in a way which is secure. We will therefore only transfer data outside of the European Economic Area or EEA (i.e. the Member States of the European Union, together with Norway, Iceland and Liechtenstein) where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, for example:
• To ensure that your personal information receives an adequate level of protection, we have put in place appropriate procedures with the third parties we share your personal data with to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the law on data protection.
For questions and/or comments about our Privacy Policy and this statement, please contact us by using the following contact details:
ASHTON ROSE LTD
5 Stratford Place, London, United Kingdom, W1C 1AX
United Kingdom
Website: https://ashtonrose.com
Email:
