Effective as of 1 February 2020

1. Application

This Privacy Policy applies to the website of and services provided by Arinna Law Limited.
Protecting personal data is a priority.   This policy tells you the types of information we collect when you visit our website and/or use our services, how we use that information, and when we may share that information.  This policy may change from time to time so please check it every so often. The date that it comes into effect is set out above.
For the purposes of this Privacy Policy, the term “personal data” means any information which identifies a person or which allows that person to be identified when combined with other information. Arinna is a “data controller” for some data and a “data processor” for others.  We are responsible for this website and the provision of our services and the personal data collected from it.
If you have any questions about this policy, including any requests to exercise your legal rights, please contact us using the details set out below:
Attention:  Privacy Manager
, Arinna Law Limited
, 48 Dover Street, London, W1S 4FF, United Kingdom, +44 20 3393 0484
Email: [email protected]

2. Data We Collect

We collect and use personal data to operate our website and to deliver services, as well as to provide useful legal updates and other information about our services.  Further information about this is below. In this context, we are a “data controller”.
If you are using our services, it may be necessary or useful for you to provide certain personal data to us, for example, about clients, staff, suppliers, etc.  In this context, you are the “data controller” and we are your “data processor“. You must therefore ensure you are lawfully permitted to transfer such personal data to us. We will only use the data to provide the services or as necessary to comply with applicable laws.
We may collect, use, store and transfer different kinds of personal data which we have grouped together as follows:

• identity data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, and social media accounts
• contact data includes billing address, delivery address, email address and telephone numbers
• financial data includes bank account and payment card details
• transaction data includes details about payments made and other details of goods and/or services purchased
• technical data includes information about use of a website, internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology used to access websites
• profile data includes usernames and passwords, purchases or orders made, preferences, feedback and survey responses
• marketing and communications data includes preferences in receiving marketing from us and third parties and communication preferences
• employment data includes current and past employment, experience, qualifications, skills, interests and any other information disclosed by you

We may also collect, use and share Aggregated Data such as statistical or demographic data. 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. 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 Policy.
It is unlikely, but possible that in the course of providing services we may also collect special categories of personal data (such as race, ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about health, and information about criminal convictions and offences.

3. How personal data is collected

We use different methods to collect data including through:

Direct interaction

You may give us details such as a name, email address and other contact details in person, or by filling in forms on our website or by corresponding with us by post, phone, email, social media and/or otherwise. This includes personal data provided when you:

• request our services
• meet with or contact one of our staff
• are introduced to one of our staff by another contact
• participate in an event which we have attended or organised
• contact us via our website
• subscribe to our publications or newsletters
• request information about our services or other information or for materials to be sent to you
• respond to a survey
• contact us about a role within Arinna
• make a complaint or give us some feedback

Automated technologies or interaction.

If you interact with our website, we may automatically collect technical data about equipment, IP address, browsing actions and patterns. We collect this data by using cookies and other similar technologies. We may also receive technical data if you visit other websites employing our cookies. Please see our cookie policy for more information.

Third parties and publicly available sources.

We may receive personal data from various third parties as set out below:

• technical data from analytics providers and/or search information providers; and
• employment, identity and contact data from recruitment agencies, previous employers, etc.

4. How we use personal data

We will only use personal data as permitted by law. Most commonly, we will use personal data in the following circumstances:

• where we need to provide services (i.e. because we are contractually obliged to do so).
• where it is in our legitimate interest to do so (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.

Generally, we do not rely on consent as a legal basis for processing personal data other than in relation to sending useful information and marketing communications to you via telephone and/or email. You have the right to withdraw consent to us contacting you like this at any time by responding to the person that contacts you and/or by contacting us via the details given above.

We may process personal data for more than one lawful ground depending on the specific purpose for which we are using data. Please contact us if you want further details about the specific legal ground we are relying on to process your personal data.

Where we need to collect personal data by law, or under the terms of a contract and you do not provide that data when requested, we may not be able to perform the contract. In this case, we may have to cancel a service you have with us but we will notify you of this at the time.

Newsletters and marketing communications

You may receive newsletters, legal updates, news and information about our services and/or other marketing communications from us if you have requested such information from us, purchased our services or if you provided us with your details when you contacted or registered with us unless you told us you did not want to receive such information. We may also contact you via surveys to conduct research about your opinion of our services. We do not give or provide client lists in any other way to third parties.

Opt-out or unsubscribe

We respect your privacy. You may, at any time opt-out of receiving certain types or all communications from us by contacting us (as set out above) or selecting the “unsubscribe” option in any e-communication from us.

Third-party links and services

Our website may include links to third-party websites and/or plug-ins. 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 or services and are not responsible for their privacy practices or privacy statements. When you leave our website, we encourage you to read the privacy policy of any new website you visit if this is a concern for you.

Children

This website and our services are not intended for children and we do not knowingly collect data relating to children.

5. How we may share, protect and retain personal data

We may need to share personal data with third parties as set out below for the purposes set out above:

• service providers who perform services and functions on our behalf in connection with the operation of our business such as software and application service providers, third parties who host, store and manage data or provide programming or technical support, etc.
• professional advisers including our accountants, insurers and brokers, etc.
• analytics partners to analyse website traffic and understand client needs and trends.
• marketing service providers to help us to communicate with you.
• if we are required to do so by law, or if we believe that such action is necessary to: (a) fulfil a government, or regulatory authority request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, our websites or clients.

We require third parties to respect the security and confidentiality of personal data and to treat it in accordance with the law. We do not allow third-party service providers to use personal data for their own purposes and only permit them to process personal data for specified purposes and in accordance with our instructions.

We will disclose personal information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to:

• comply with legislation or legal process served on us;
• protect and defend our rights and/or property; and
• to protect personal safety.

International transfers

Our third-party service providers may be based outside the European Economic Area (EEA) and when they are their processing of personal data will involve a transfer of data outside the EEA. Whenever we transfer personal data out of the EEA or UK, 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 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.

Security of your personal data 

We have put in place appropriate security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to personal data to those of our staff and other third parties who have a business need to know. They will only process 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.

Data retention

We will retain personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of personal data, the purposes for which we process personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. For example, if you are a client, we will generally keep your personal data for the longer of six years from the date of the last interaction with you or until the applicable statutory limitations period has expired. We regularly review the personal data we hold taking into account the lawful purpose for which we hold it and any data that is deemed no-longer relevant or required is deleted where it is practicable to do so.

6. Your legal rights

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 processing it lawfully.
• 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 rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. It is unlikely, but 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.

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 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 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 does not have a 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 as soon as reasonably practicable and at least within one month. Occasionally it may take us longer 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.

Cookies

The Arinna Law website uses “cookies” to help personalize your online experience and to help us to distinguish you from other users.  When you use our website for the first time you will be given the opportunity to accept or decline cookies.  By accepting the cookies, you agree to our use of the cookies as set out in this policy.

What is a cookie?

A cookie is a piece of data sent to your device from a website which is stored on your browser or the hard drive of your computer if you agree.  A cookie is a text file that is placed on your hard disk by a web page server. Cookies are not used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you.

Cookies used on our website

The exact names of cookies we use on our websites may change from time to time. The descriptions below set out the types of cookies that operate on our website:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include cookies used to recognise you when you return to our website so we remember your preferences (for example, our newsletter pop-up that logs the date it will next show for the visitor).
• 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.

You can obtain an up to date list of the cookies we use by contacting us at [[email protected]].

We may also use other technologies with similar functionality to cookies, such as web beacons and tracking URLs on our website and in emails, for example, to determine whether a recipient opened the email or accessed a certain link.

How to delete or change your cookies preferences

You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer.   You can also set your browser to alert you when a website sets or accesses cookies.  The ‘Help’ function within your browser should tell you how to do this.

Please be aware that restricting cookies may impact on the functionality of our websites.