Privacy & Cookies

WHAT IS THIS PRIVACY POLICY FOR?

This privacy policy is for the website humphreyandbo.com and served by Humphrey & Bo and governs the privacy of its users who choose to use it.

The policy sets out the different areas where user privacy is concerned and outlines the obligations & requirements of the users, the website and website owners. Furthermore the way this website processes, stores and protects user data and information will also be detailed within this policy.

THE WEBSITE

This website and its owner take a proactive approach to user privacy and ensure the necessary steps are taken to protect the privacy of its users throughout their visiting experience. This website complies to all UK national laws and requirements for user privacy.

We may change this privacy notice from time to time by updating this page in order to reflect changes in the law and/or our privacy practices. We encourage you to check this privacy notice for changes whenever you visit our website.

PERSONAL INFORMATION WE MAY PROCESS

Personal information that we’ll process in connection with all our services, if relevant, includes:

· Personal and contact details, such as title, full name, email address, date of birth, contact details, address and contact details history

· Records of your contact with us such as via phone or email, or if you get in touch with us online using our contact form

· Products and services you have purchased from us, as well as have been interested in and have held and the associated payment methods used

· Marketing to you and analysing data, including history of those communications, whether you open them or click on links, and information about products or services we think you may be interested in, and analysing data to help target offers to you that we think are of interest or relevance to you.

Any information we collect about you will come either from yourself, any person who may have referred you to us, or from our advertising or social media platforms.

HOW WE MAY USE YOUR DATA

We use your personal data, including any of the personal data listed in section 1 above, for the following purposes.

· Assessing an enquiry for a product or service, including considering whether or not to offer you the product or service

· Managing any aspect of the product or service

· To improve the operation of our business

· For management and auditing of our business operations including accounting

· To keep records of our communications with you

· For market research and analysis and developing statistics

· For direct marketing communications and related profiling to help us to offer you relevant products and service, including deciding whether or not to offer you certain products and service. We may send marketing to you by email, phone, post, social media and digital channels (for example, using Facebook Custom Audiences and Google Custom Match).

· For email marketing communications to provide you with relevant information and offers occasionally.

· To provide personalised content and services to you, such as tailoring our products and services, our digital customer experience and offerings, and deciding which offers or promotions to show you on our digital channels

· To develop new products and services and to review and improve current products and services

· To comply with legal and regulatory obligations, requirements and guidance

LEGAL GROUNDS FOR PROCESSING YOUR INFORMATION

We rely on the following legal bases to use your personal data:

1. Where it is needed to provide you with our products or services, such as:

a) Assessing an enquiry for a product or service you hold with us, including considering whether or not to offer you the product or service

b) Managing products and services you have purchased from us

c) All stages and activities relevant to managing the product or service including enquiry, administration and management of accounts

2. Where it is in our legitimate interests to do so, such as:

a) Managing your products and services relating to that and updating your records

b) For management and audit of our business operations including accounting

c) To keep records of our communications with you

d) For market research and analysis and developing statistics

e) For direct marketing communications and related profiling to help us to offer you relevant products and services, including deciding whether or not to offer you certain products and service. We may send marketing to you by email, phone, post and social media and digital channels (for example, using Facebook Custom Audiences and Google Custom Match)

f) For email marketing communications to provide you with relevant information and offers occasionally.

g) Where we need to share your personal information with people or organisations in order to run our business or comply with any legal and/or regulatory obligations

3. To comply with our legal obligations

4. With your consent or explicit consent for some direct marketing communications

SHARING YOUR DATA

We may share information with the following third parties for the purposes listed above:

· Governmental and regulatory bodies such as HMRC, the Financial Conduct Authority, the Prudential Regulation Authority, the Ombudsman, the Information Commissioner’s Office and under the Financial Services Compensation Scheme

· Any other businesses that are needed in order to fulfil our services or products, such as suppliers or outsourcing companies

STORING YOUR DATA

We may use third party tools to store your personal data and keep your information safe, such as a CRM System, cloud storage or email marketing software, as well as our own hard drives and data storage systems.

PROVIDING US WITH YOUR PERSONAL INFORMATION

We’re unable to provide you with our products or services if you do not provide certain information to us. In cases where providing some personal information is optional, we’ll make this clear.

You should tell us so that we can update our records using the details in the Contact Us section of our website. We’ll then update your records if we can.

We may use your home address, phone numbers, email address and social media or digital channels (for example, Facebook, Google and message facilities in other platforms) to contact you according to your marketing preferences. You can stop our marketing at any time by contacting us using the details below or by following the instructions in the communication.

DATA RETENTION

Unless we explain otherwise to you, we’ll hold your personal information based on the following criteria:

· For as long as we have reasonable business needs, such as managing our relationship with you and managing our operations and accounts

· For as long as we provide goods and/or services to you and then for as long as someone could bring a claim against us; and/or

· Retention periods in line with legal and regulatory requirements or guidance.

YOUR RIGHTS UNDER DATA PROTECTION LAW

Here is a list of the rights that all individuals have under data protection laws. They don’t apply in all circumstances. If you wish to use any of them, we’ll explain at that time if they are engaged or not. The right of data portability is only relevant from May 2018.

· The right to be informed about the processing of your personal information

· The right to have your personal information corrected if it is inaccurate and to have incomplete personal information completed

· The right to object to processing of your personal information

· The right to restrict processing of your personal information

· The right to have your personal information erased (the “right to be forgotten”)

· The right to request access to your personal information and to obtain information about how we process it

· The right to move, copy or transfer your personal information (“data portability”)

· Rights in relation to automated decision making which has a legal effect or otherwise significantly affects you

· You have the right to complain to the Information Commissioner’s Office which enforces data protection laws: https://ico.org.uk/. You can contact us using the details below.

You have the right to object to certain purposes for processing, in particular to data processed for direct marketing purposes and to data processed for certain reasons based on our legitimate interests.

Individuals can find out if we hold any personal information by making a ‘subject access request’ under the GDPR law. If we do hold information about you we will:

· Give you a description of it;

· Tell you why we are holding it;

· Tell you who it could be disclosed to; and

· Let you have a copy of the information in an intelligible form.

You can contact us or make an SAR by going to the CONTACT section of our website to exercise these rights.

COOKIES:

Cookies are small files that hold information; they’re placed or ‘dropped’ on your computer when you access websites or use apps on your device. The data contained in the cookie can be retrieved by the website or app that placed them there. They can also be accessed by websites or apps that have been authorised to use them by the site or app that first dropped them.

Some cookies only exist for a short period of time, and are then automatically deleted by your device. Others last for longer – these are called ‘persistent cookies’ – and some exist for years unless manually deleted. These can be used to analyse multiple site visits over time, or customise the content that’s displayed.

Some cookies are set by the website or app you’re visiting; these are called ‘first party’ cookies. Others may be set by a third party when you use a site or app – for example, by a tool built into the website, or by an advertising network that displays adverts on the site or in the app.

Read more about cookies on the site of the UK Information Commissioner’s Office (who regulated data usage).

COOKIES WE USE

WordPress Cookies: needed for things like logging whether you see error messages – so we can make improvements and fix bugs – as well as allowing you to use shopping baskets (which remember your choices as you navigate our site) and make a purchase.

Analytics Cookies: needed to analyse the performance of this website and create reports on website traffic, sources and popular pages etc. This includes Squarespace cookies and Google Analytics cookies.

Advertising Cookies: needed for information about your browsing habits (including details of the websites you’ve visited), which we use to make sure you receive advertising relevant to you. We (or third parties and advertising networks on our behalf) may use them to show you ads we think you’ll be interested in across the internet (including on other sites you visit), based on your interaction with our website, app and your browsing history. This may include Google Adwords, Facebook, Twitter, Instagram, Mailchimp and various other display advertising providers.

COOKIES ON WEBSITES WE LINK TO

We often link to other sites to give you extra information or services. Where these are provided by a third party, you may leave our website by clicking through to theirs. In this case, the cookies policy set out on the third party’s website will also apply. As this won’t be controlled by us, you should read their policy to find out what information is being collected and how it’s used.

THIS SITE OPERATES ON AN ‘IMPLIED CONSENT’ POLICY:

Currently this website operates with an ‘implied consent’ policy which means that we assume you are happy with the usage of Cookies detailed here. This means you don’t get that annoying ‘Please Accept Cookies’ pop up when you visit.

If you are not happy, then you should either not use this site, delete our website cookies after visiting the site, or you should browse the site using your browser’s anonymous usage setting (called “Incognito” in Chrome, “InPrivate” for Internet Explorer, “Private Browsing” in Firefox and Safari etc.).

IF YOU DON’T WANT COOKIES

You can restrict, remove or block cookies through your browser settings at any time.

To find out more about Cookies, including how to control, opt-out and delete them, go to http://www.aboutcookies.org for guidance.