Privacy Policy

Purpose of this privacy notice

This privacy notice aims to give you information on how White Hart Associates collects and processes your personal data, including any data you may provide through this website or via any other means (such as via e-mail, over the telephone etc.) when you engage us to provide you with professional services.

This website is not intended for children; we do not knowingly collect any data relating to children.

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.

Controller

This privacy notice is issued on behalf of White Hart Associates (London) Limited and White Hart Associates LLP so when we mention “White Hart Associates”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company, i.e. White Hart Associates (London) Limited or White Hart Associates LLP that is responsible for processing your data. White Hart Associates (London) Limited and White Hart Associates LLP are joint-controllers and are responsible for this website.

We have appointed a data protection officer (DPO) 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, please contact the DPO using the details set out below.

Contact details

Our full details are:

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 (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

This version was last updated on 8 May 2018 and historic versions can be obtained by contacting us.

The data protection law in the UK will change on 25 May 2018. Although this privacy notice sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests (for example, a request for the transfer of your personal data) until 25 May 2018 as we are still working towards getting our systems ready for some of these changes.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if any of the details you provide to us should change, during the course of your relationship with us.

Third-party links

This website may include links to third-party websites, 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.

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 may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

1. Identity Data
   This includes data relating specifically to your identity, such as your first name, maiden name, last name, marital status, title, date of birth and gender.
2. Contact Data
   This includes data relating to how you may be contacted, such as your address, email address and telephone numbers.
3. Payment Data
   This include data relating to your means and methods of payment, such as your bank account and payment card details.
4. Financial Data
   This includes data relating to audit, regulatory, statutory accounting, tax, employment and related terms.
5. Transaction Data
   This includes data relating to the transactions you have carried out with us, such as details about payments to and from you and other details of professional services you have purchased from us.
6. Technical Data
   This includes more technical data that we may obtain when you make use of our website, such as your 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 this website.
7. Usage Data
   This includes information about how you use our website, products and services.
8. Marketing and Communications Data
   This includes your preferences in relation to whether or not you want to receive marketing from us and our third parties and also 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 aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data which will be used in accordance with this privacy notice.

Special Categories of Personal Data

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), unless we are obligated to do so by a regulatory authority; where we are required to collect special categories of personal data owing to the requirements of a regulatory body, we will inform you accordingly. Nor do we collect any information about criminal convictions and offences.

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.

In other words, where we require details from you in order to provide you with professional services that you have chosen to engage us to provide, if you do not provide us with the necessary details then we will not be able to provide the services in question.

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.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending 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.

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 plan to 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. Please contact us 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.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We have set out below the various mechanisms by which we strive to provide you with choices around how we use your personal data, particularly for marketing and advertising purposes. You can also contact our DPO at any time to discuss this further (dataprotectionofficer@whitehartassociates.com).

Promotional offers 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 professional services and offers may be relevant for you (we call this marketing).

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time (dataprotectionofficer@whitehartassociates.com).

Where you opt out of receiving these marketing messages, this will not apply to personal data that you have provided to us as a result of an engagement to provide you with professional services or other such transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see https://whitehartassociates.com/terms-and-conditions/.

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.

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.

LAWFUL BASIS

• Legitimate Interest
  means the interest of our business in conducting and managing our business to enable us to give you the best service 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.

THIRD PARTIES

• Internal Third Parties
  Both White Hart Associates (London) Limited and White Hart Associates LLP acting as joint controllers and who are based in the United Kingdom and provide various IT and system administration services and undertake leadership reporting to one another.
• External Third Parties
  • Service providers such as Xero Limited acting as processors based outside the EEA who provide cloud accounting and storage services.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom, United States, Australia and/or such other countries as necessary for the purposes of your instructions who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators (such as the CAA, ABTA, IATA, ABTOT) and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
  • Regulatory bodies and other authorities acting as processors or joint controllers and based in the United States, Australia and/or such other countries as necessary for the purposes of your instructions and who require reporting of processing activities in certain circumstances.

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 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:
  • if you want us to establish the data’s accuracy;
  • where our use of the data is unlawful but you do not want us to erase it;
  • 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
  • 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.