Welcome to the Legal Clarity Limited privacy notice.
Who we are
The term ‘Legal Clarity’ used in this privacy notice refers to Legal Clarity Limited This privacy notice is issued on behalf of Legal Clarity and any of its group companies so when we mention ‘we’, ‘us’ or ‘our’ in this privacy notice, we are referring to Legal Clarity Limited or any relevant company in Legal Clarity’s group from time to time, responsible for processing your data, including (without limitation) LC Nominees Limited.
We have notified the Information Commissioner’s Office under the Data Protection Act 2018 that we process personal information. Our registration number is PZ1346103. Further details about us are set-out below This policy sets out how we use and protect your personal information. Any personal information we collect will be processed in accordance with our legal obligations, including those contained in the Data Protection Act 2018.
Legal Clarity Limited is the data controller responsible for the website www.legalclarity.co.uk, hereafter referred to as ‘our website’.
Legal Clarity respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the Data Protection Act 2018 and the European General Data Protection Regulations (‘GDPR’) protect citizens of the United Kingdom and the European Union.
Please use the Glossary at the end of this document to understand the meaning of some of the terms used in this privacy notice.
- Important information
Purpose of this privacy notice
This privacy notice aims to give you information on how Legal Clarity collects and processes your personal data when you purchase products or services from us or interact with us through your use of our website, including any data you may provide through our website, the website email system, or when you email us with sales or general enquiries or when you provide consents for inclusion on mailing lists or enter any promotion or marketing activity we run or promote.
Our website is not intended for children and we do not knowingly collect data relating to children. If you are under 18, please get your parent or guardian to contact the data privacy manager.
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. This privacy notice supplements the other notices and is not intended to override them.
Data Privacy Manager
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights under the GDPR, please contact the data privacy manager using the details set out below.
Our full details are:
- full name of legal entity: Legal Clarity Limited;
- company number: 06452925;
- registered office: 1st Floor, Charles House, 148-149 Gt Charles Street, Birmingham, West Midlands, United Kingdom, B3 3HT;
- data privacy manager: Richard Underwood;
- email address: email@example.com;
- postal address: 1st Floor, Charles House, 148-149 Gt Charles Street, Birmingham, West Midlands, United Kingdom, B3 3HT and
- Telephone number: 0121 314 9102.
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.
Changes to the privacy notice and your duty to inform us of changes
We keep our privacy notice under regular review. This version was last updated on 5 October 2020 and historic versions 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.
Our website may include links to third-party websites (including our partner networks, advertisers and affiliates) plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
- 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 (anonymous data).
We do not collect personal information about you if you only browse our website.
Otherwise, we may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, middle name, last name, username or similar identifier, title, date of birth and gender;
- Contact Data includes the name of your company or business (if relevant), the billing address, delivery address, home address, email address, telephone numbers and fax number (if any);
- Financial Data includes bank account, payment card details and accreditation records;
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us;
- Technical Data includes but is not limited to internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website, the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page, any phone number used to call our customer service number or otherwise communicate with us using electronic communications systems;
- Profile Data includes your username and password (if you have one), purchases or orders made by you, your interests, preferences, feedback and survey responses;
- Usage Data includes information about how you use our website or our distributor portal or how you otherwise communicate with us using electronic or other communications systems, products and services; and
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may calculate the percentage of sales, or visits to a particular part of the website by region. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
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.
All payments through our websites are processed securely by HSBC plc. We will need to pass your payment details to HSBC so that they can process your payment. Please refer to www.hsbc.co.uk for further details.
If you fail to provide personal data
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 goods or services). In this case, we may have to cancel a product or service order or service contract you have with us but we will notify you if this is the case at the time.
- How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- order products or services;
- create an account on the website;
- request marketing materials or information to be sent to you;
- enter a competition, promotion or survey; or
- give us some feedback.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
In particular, when you visit the website we may use third-party services such as Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google or any other third-party service provider to make, any attempt to find out the identities of those visiting the website.
- Third parties or publicly available sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
In particular, we may receive personal data about you from various third parties and public sources as set out below:
- We receive:
- anonymised data concerning visitors to our website harvested by Google Analytics (Google LLC, 1600 Amphitheatre, Parkway, Mountain View, CA 94043);
- Contact, Financial and Transaction Data from providers of financial information and credit reference agencies;
- Identity and Contact Data from brokers and aggregators; and
- Identity and Contact Data from publicly availably sources based inside the EU such as Companies House and the Electoral Register.
- How 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 circumstances:
- 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.
To find out more about the types of lawful basis that we will rely on to process your personal data please refer to the table in the section below called ‘Purposes for which we will use your personal data’.
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. You have the right to withdraw consent to marketing at any time by contacting us; please refer to the ‘Contact details’ above.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all 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.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. If you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below, please contact us (see the ‘Contact details’ above).
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer||(a) Identity (b) Contact||Performance of a contract with you|
To process orders and requests and to deliver services to you including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy notice
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To enable you to partake in a prize draw, competition, complete a survey or provide other feedback||
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
|To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||
(a) 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)
(b) Necessary to comply with a legal obligation
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
You should note we may record telephone conversations made to any telephone number published on the website for training and other purposes.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Marketing communications from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us.
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving marketing information.
We will get your express opt-in consent before we share your personal data with any company outside of Legal Clarity’s group or control, for marketing purposes.
You can ask us or our internal third parties to stop sending you marketing messages at any time by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
Each website can send its own cookie to your browser if your browser’s preferences allow it, but (to protect your privacy) your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other websites. Many websites do this whenever a user visits their website in order to track online traffic flows.
We use the following cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
- Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, and remember your preferences (for example, your choice of language or region).
- Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
Please note that during your visits to the Legal Clarity website you may notice some cookies that are not related to Legal Clarity. When you visit a page with content embedded from, for example, YouTube or other social media or news websites, you may be presented with cookies from these websites. Legal Clarity does not control the dissemination of these cookies and embedded content from other websites behaves in the exact same way as if the visitor has visited the other website
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies If you set up your browser to reject the cookie, you may still use our website but some parts of our website may not function properly.
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 (see ‘Contact details’ above).
Save where notification would be a breach or our legal obligations, 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.
- 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.
- Internal third parties within our corporate group who may act as joint controllers or processors and who may be based inside or outside the EU.
- External Third Parties as set out in the Glossary.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
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.
- International transfers
If any external third parties are based outside the European Economic Area (EEA) their processing of your personal data will 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.
- Please contact us, refer to the ‘Contact details’ above, if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
- Data security and how we store your data
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.
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.
Unfortunately, the transmission of information via the internet is not completely secure. Although Legal Clarity will do its best to protect Your personal data, Legal Clarity cannot guarantee the security of Your data transmitted to the Website; any transmission is at Your own risk.
- Data retention
How long will you use my personal data for?
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax, regulatory and other purposes.
In some circumstances you can ask us to delete your data: see ‘Request erasure’ in the section below for further information.
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
Under certain circumstances, 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. 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. 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 compelling legitimate grounds to process your information which override your rights and freedoms.
- 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. Note that 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. 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
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.
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 are a 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.
External Third Parties
- Companies and other persons or service providers who may act as processors based inside or outside the EU and who provide IT, system administration and other services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, the Solicitors Regulation Authority, the Law Society and other regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.