We take your privacy very seriously. Please read this Privacy Policy (the Policy) carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use and are responsible for certain personal information about you. When we do so we are subject to the DPA and we are responsible as ‘Controller’ of that personal information for the purposes of those laws.

Key terms

It would be helpful to start by explaining some key terms used in this Policy:

We, us, our means Naomi-Pearl Limited

DPA means Data Protection Act 2018 (as amended from time to time)

Personal information means any information relating to an identified or identifiable individual.

Special category personal information means personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership. Genetic and biometric data. Data concerning health, sex life or sexual orientation.

Personal information we collect about you

We may collect and use the following personal information about you:

• your name and contact information, including email address and telephone number and company details;

• information to enable us to check and verify your identity, e.g. your date of birth;

• your gender information;

• your billing information, transaction and payment details;

• your personal and/or professional interests;

• your professional online presence, e.g. LinkedIn profile; and

• your contact history, purchase history and saved items.

The personal information is required to provide the services to you. If you do not provide the personal information we ask for, it may delay or prevent us from providing our services to you.

How your personal information is collected

We collect most of the personal information directly from you—in person, by telephone, text or email. However, we may also collect information:

• from publicly accessible sources, e.g. Companies House;

• directly from a third party, e.g. customer due diligence providers; and

• from a third party with your consent, e.g. your bank or building society.

How and why we use your personal information

Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:

• to comply with our legal and regulatory obligations;

• for the performance of our contract with you or to take steps at your request before entering into a contract;

• for our legitimate interests or those of a third party; or

• where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

Who we share your personal information with

We routinely share personal information with:

• third parties we use to help deliver our services to you and run our business; e.g. agents, contractors and IT service providers;

• third parties approved by you;

• our insurers and brokers; and

• our bank.

We only allow our service providers to handle your personal information if we are satisfied that they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with accountants in the preparation of our accounts.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

Where your personal information is held

Information may be held at our offices and those of our third-party agencies, service providers, representatives and agents as described above under the section ‘Who we share your personal information with’. Some of these third parties may be based outside the United Kingdom. For more information, including on how we safeguard your personal information when this occurs, see the section below on ‘Transferring your personal information out of the UK’.

How long your personal information will be kept

We will keep your personal information while we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:

• to respond to any questions, complaints or claims made by you or on your behalf;

• to show that we treated you fairly; and

• to keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this Policy. Different retention periods apply for different types of personal information. When it is no longer necessary to retain your personal information, we will delete or anonymise it.

Transferring your personal information out of the UK

To deliver services to you, it is sometimes necessary for us to share your personal information outside the UK, e.g.:

• with your and our service providers located outside the UK;

• if you are based outside the UK; and

• where there is an international dimension to the services we are providing to you.

Where your information is transferred outside the UK, we will, however, ensure the transfer complies with data protection law and all personal information will be secure. Where relevant, we will use standard data protection contract clauses that have been approved by the European Commission.

Your rights

You have the following rights, which you can exercise free of charge:

Access: The right to be provided with a copy of your personal information (the right of access).

Rectification: The right to require us to correct any mistakes in your personal information.

Erasure: The right to require us to delete your personal information—in certain situations.

Restriction of Processing: The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data.

Data Portability: The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations.

Objection: The right to object:

• at any time to your personal information being processed for direct marketing (including profiling); and

• in certain other situations to our continued processing of your personal information, e.g., processing carried out for the purpose of our legitimate interests.

Automated Decision Making: The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.

For further information on each of these rights, including the circumstances in which they apply, please see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation. If you would like to exercise any of these rights, please:

• email, call or write to us using the details in the section below on ‘How to contact us’; and

• let us have enough information to identify you (e.g. your full name, address and customer or matter reference number);

• let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and

• let us know what right you want to exercise and the information to which your request relates.

Keeping your personal information secure

We have appropriate security measures to prevent personal information from being accidentally lost, used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How to complain

We hope that we can resolve any query or concern you may raise about our use of your information. You have the right to lodge a complaint with the supervisory authority in the UK which is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or by telephone on 0303 123 1113.

Changes to this privacy policy

This Policy was last updated on 1st December 2020 We may change this Policy from time to time and will notify you where we have made material changes to the Policy which include changes to the type of data we collect or the way in which we process data.

How to contact us

Please contact us by post, email or telephone if you have any questions about this Policy or the information we hold about you. Our contact details are shown below:

Naomi-Pearl Limited

10 Linkfield Lane

Redhill, Surrey, RH1 1JL

info@naomi-pearl.co.uk

07380 894691

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