1. GENERAL
First4Lawyers Limited (company number 06462116) of Permanent House, Dundas Street, Huddersfield, HD1 2HE, together with any group companies (“we” “us” “our”) are committed to protecting and respecting your privacy. For the purposes of data protection legislation, we are the data controller and we will process your personal data in accordance with the General Data Protection Regulation (EU) 2016/679 and national laws which relate to the processing of personal data. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
2. VISITORS TO OUR WEBSITE
2.1 We may collect and process personal data about you in the following circumstances:
2.1.1 when you complete forms on our website (“Site”). This includes your name, telephone number, email address and details of your enquiry which is provided when you ask us to contact you about our services;
2.1.2 whenever you provide information to us when reporting a problem with our Site, making a complaint, making an enquiry or contacting us for any other reason. If you contact us, we may keep a record of that correspondence;
2.1.3 details of your visits to our Site including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise, and the resources that you access (see section 2.2.2 on cookies below); and
2.1.4 whenever you disclose your information to us, or we collect information from you in any other way, through our Site.
2.2 We may also collect data in the following ways:
IP address
2.2.1 We may collect information about your device, including where available your Internet Protocol address, for reasons of fraud protection. We may also collect information about your device’s operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.
Cookies
2.2.2 Our Site uses cookies to distinguish you from other users of our Site. This helps us to provide you with a good experience when you browse our Site and also allows us to improve our Site. For detailed information on the cookies we use and the purposes for which we use them see our cookie policy.
2.3 We may use your personal data for our legitimate interests in order to:
2.3.1 provide you with information, or services that you requested from us;
2.3.2 allow you to participate in interactive features of our Site, when you choose to do so;
2.3.3 ensure that content from our Site is presented in the most effective manner for you and for your device;
2.3.4 improve our Site and services;
2.3.5 process and deal with any complaints or enquiries made by you; and
2.3.6 contact you for marketing purposes where you have signed up for these (see section 6 for further details).
Website links
Our Site may, from time to time, contain links to and from the websites of third parties. Please note that if you follow a link to any of these websites, such websites will apply different terms to the collection and privacy of your personal data and we do not accept any responsibility or liability for these policies. When you leave our Site, we encourage you to read the privacy notice/policy of every website you visit.
3. CUSTOMERS
3.1 Third party organisations we appoint to deal with inbound telephone enquiries and to respond to enquiries made through our Site will collect your personal details such as your name and contact details, as well as any other information that may be relevant to the nature of your enquiry. We will use this information to consider your enquiry or claim and, if we decide we can assist you with your enquiry, we will use your personal data to deliver the services.
3.2 We can also collect your contact details when you complete one of our online enquiry forms and will use this information to make contact with you/follow up on an enquiry you have made.
3.3 In order to provide you with the services you have requested, we may also need to share personal data with third parties such as payment providers, and our panel solicitors who we or you may instruct to process your enquiry. For certain enquiries this may also include other business partners (instructed by us or our panel solicitors) including (but not limited to) medical agencies, insurance companies, credit hire companies and conveyancing search providers to assist in the delivery of services you have requested, as applicable.
3.4 To help us provide the best level of service to you, we may instruct third parties to conduct customer experience surveys on our behalf.
3.5 We may also advertise your feedback on our website and marketing materials (subject to obtaining your prior consent where necessary);
3.6 We will retain your information as long as we require this to provide you with the services ordered from us and for a period of 6 years afterwards. Where you have subscribed to receive marketing correspondence from us we will keep your personal data for the period of time described in section 6 below.
4. PANEL SOLICITORS AND BUSINESS PARTNERS
We will collect details such as your name, contact details and position within your organisation in order to contact you about your services, comply with our contractual obligations and to invoice you for amounts payable to us under our contract with you. We may also share personal data relating to panel solicitors with our business partners to facilitate the provision of services to our customers. We will keep your personal data for 6 years further to being provided with the services.
5. SUPPLIERS
We will collect details such as names, contact details, telephone numbers and bank details in order to contact you about goods or services ordered with you, to place further orders and to pay you for the goods and/or services supplied. Will keep your personal data for 6 years further to being provided with the goods/services.
6. THIRD PARTIES
We may collect, and the third party organisations we appoint to deal with customer enquiries may collect personal data about third parties in the course of acting for our customers. We will use this information to provide the services requested by our customers and for the establishment, exercise or defence of customer claims. We will retain such personal data for a period of 6 years.
7. 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 the 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 our services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
8. MARKETING
8.1 In addition to the uses described in sections 2-6 above, where you indicate you would like to receive marketing correspondence from us, subscribe to our marketing lists or newsletters or provide us with your details at events, we may use your personal data for our legitimate interests in order to provide you with details about our services which we think may be of interest.
8.2 We may also share your personal data with our group company, First4Lawyers Legal Services Limited, in order to provide you with details of their services which we think may be of interest.
8.3 You have the right to opt-out of receiving the information detailed in sections 8.1 and 8.2 at any time. To opt-out of receiving such information you can:
8.3.1 click the unsubscribe button contained in any such communication received; or
8.3.2 email us at [email protected] providing us with your name and contact details.
8.4 Where you have subscribed to receive marketing correspondence from us we will keep personal data 6 years from when you provide us with your consent.
9. MONITORING AND RECORDING
We may monitor and record communications with you (such as telephone communications and emails) for the purposes of quality assurance, training, fraud prevention and compliance. We also have CCTV cameras installed in our premises for the purpose of crime prevention and for health and safety reasons. We retain such information for 6 years.
10. AUTOMATED PROCESSING
10.1 In certain situations we may use personal data to help us make automated decisions to further improve our business. For example, we may use personal data (such as an individual’s geographical location) to target users of our website with personalised marketing messages.
10.2 We may carry out a credit check on our customers:
10.2.1 so that we can make credit decisions about you; and
10.2.2 to prevent fraud and money laundering.
10.3 Our search won’t be recorded on the files of the credit reference agency.
10.4 If further to undertaking a credit check you receive a low credit score, we reserve the right not to [supply you with services on credit and/or require upfront payment for the services you wish to purchase].
10.5 If you provide false or inaccurate information and we suspect fraud, we will record this. If you want to see your credit file, please contact the credit agency we use, Experian.
11. LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA
We will only use your personal data where the law or your personal consent allows us to. Most commonly, we will use your personal data in the following circumstances:
11.1.1 for performance of a contract we enter into with you;
11.1.2 where necessary for compliance with a legal or regulatory obligation we are subject to; and
11.1.3 for our legitimate interests (as described within this policy) and your interests and fundamental rights do not override these interests.
11.1.4 consent as a lawful basis for processing personal data when placing cookies and similar technologies on user devices, see section 2 on cookies for further detail.
Access to information
You have the right to request access to your personal data which we process. This formal request is made under the DPA and is referred to as a Data Subject Access Request. If you wish to exercise this right and make a Subject Access Request, you should;
- Put your request in writing; either by Email or by letter.
- Include proof of your identity and address (e.g. a copy of your driving licence or passport, and a recent utility or credit card bill);
- Specify the personal data you want access to, including any account or reference numbers where applicable.
You have the right to require us to correct any inaccuracies in your data free of charge. If you wish to exercise this right, you should:
- Either speak to us via telephone or put your request in writing;
- Provide us with enough information to identify you; and
- Specify the information that is incorrect and what it should be replaced with.
12. DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES
12.1 In addition to the third parties mentioned above, we may disclose your information to the following third parties for our legitimate interests as follows:
12.1.1 third party agencies which assist us with marketing;
12.1.2 third party agencies which conduct customer experience surveys on our behalf;
12.1.3 staff members, in order to facilitate the provision of goods or services to you;
12.1.4 our affiliated entities, to support internal administration;
12.1.5 IT software providers that host our website and store data on our behalf and, with your consent, analyse online identifier data;
12.1.6 professional advisers including consultants, lawyers, bankers and insurers who provide us with consultancy, banking, legal, insurance and accounting services;
12.1.7 HM Revenue and Customs, regulators and other authorities who require reporting of processing activities in certain circumstances; and
12.1.8 third parties who we may choose to sell, transfer or merge parts of our business or assets. Alternatively, we may seek to acquire other business or merge with them. If a change happens to our business then the new owners my use your personal data in the same way as set out in this privacy policy.
12.1.9 third parties who we may choose to assist us with validating data submitted to us via our website to enable us to respond to your enquiry and facilitate the provision of goods or services to you.
12.2 We may disclose personal data to the police, regulatory bodies, legal advisors or similar third parties where we are under a legal duty to disclose or share personal data in order to comply with any legal obligation, or in order to enforce or apply our website terms and conditions and other agreements; or to protect our rights, property, or safety of our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
12.3 We will not sell or distribute personal data to other organisations without your approval.
13. CROSS-BORDER DATA TRANSFERS
Where permitted by applicable law, we may transfer your personal data to the United States and other jurisdictions outside the European Economic Area (‘EEA’) for the purposes set out in this privacy policy, including where personal data is transferred to third parties who process data on our behalf. Constant Contact, an organisation which conducts client surveys on our behalf have implemented the EU-US Privacy Shield and Swiss-US Privacy Shield to secure the transfer of your personal data to jurisdictions outside the EEA.
14. DATA SECURITY
14.1 Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
14.2 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your information transmitted to our Site; any transmission is at your own risk.
14.3 Information you provide to us is shared on our secure servers. We have implemented appropriate physical, technical and organisational measures designed to secure your information against accidental loss and unauthorised access, use, alteration or disclosure. In addition, we limit access to personal data to those employees, agents, contractors and other third parties that have a legitimate business need for such access.
15. ACCESS TO, UPDATING, DELETING AND RESTRICTING USE OF PERSONAL DATA
15.1 It is important that the personal data we hold about you is accurate and current. Please keep us informed if the personal data we hold about you changes.
15.2 Data protection legislation gives you the right to object to the processing of your personal data in certain circumstances or withdraw your consent to the processing of your personal data where this has been provided. You also have the right to access information held about you and for this to be provided in an intelligible form. If you would like a copy of some or all of your personal information, please send an email to [email protected]. In certain circumstances we reserve the right to charge a reasonable fee to comply with your request.
15.3 You can also ask us to undertake the following:
15.3.1 update or amend your personal data if you feel this is inaccurate;
15.3.2 remove your personal data from our database entirely;
15.3.3 send you copies of your personal data in a commonly used format and transfer your information to another entity where you have supplied this to us, and we process this electronically with your consent or where necessary for the performance of a contract; or
15.3.4 restrict the use of your personal data.
15.4 We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal data that we hold about you or make your requested changes. Data protection legislation may allow or require us to refuse to provide you with access to some or all the personal data that we hold about you or to comply with any requests made in accordance with your rights referred to above. If we cannot provide you with access to your personal data, or process any other request we receive, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
15.5 Please send any requests relating to the above to our Data Protection Lead at [email protected] specifying your name and the action you would like us to undertake.
16. RIGHT TO WITHDRAW CONSENT
Where you have provided your consent to the collection, processing and transfer of your personal data, you have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, please contact us at [email protected].
17. CHANGES TO OUR PRIVACY POLICY
We reserve the right to update this privacy policy at any time, and any changes we make to our privacy policy will be posted on this page. We encourage you to check this privacy policy from time to time for any updates or changes to this privacy policy. If we would like to use your previously collected personal data for different purposes than those we notified you about at the time of collection, we will provide you with notice and, where required by law, seek your consent, before using your personal data for a new or unrelated purpose. We may process your personal without your knowledge or consent where required by applicable law or regulation.
18. CONTACT US
We have appointed a Data Protection Lead to oversee compliance with this privacy policy. If you have any questions, comments or requests regarding this policy or how we use your personal data please contact our Data Protection Lead at [email protected]. This is in addition to your right to contact the Information Commissioners Office if you are unsatisfied with our response to any issues you raise at https://ico.org.uk/global/contact-us/
Last updated: May 2021
