Privacy Notice - Lothbury UK Ltd

Lothbury UK Limited

This Privacy Notice explains the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe.

1. Lawful basis

The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:

Consent – in specific situations, we can collect and process your data with your consent. When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.

Contractual obligations – in certain circumstances, we need your personal data to comply with our contractual obligations.

Legal compliance – if the law requires us to, we may need to collect and process your data.

Legitimate interest – in specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.

For example, we will use your buying history to advise you of products or services suitable to your requirements. We also combine the buying history of our clients to identify trends to assist us the development of new products/services. We will also use your address details to send you direct marketing information, advising you about products and services that we think might interest you.

2. When do we collect your personal data?

When you purchase a product or service by letter, email or phone.
When you contact us by any means with queries, complaints etc.
When you ask us to email you information about a product or service.
When you’ve given a third party permission to share with us the information they hold about you.
When we collect data from publicly-available sources
When you have given your consent to share information or where the information is made public as a matter of law.

3. What sort of personal data do we collect?

Your name, gender, date of birth, address, email and telephone number.
Where the law requires us to take copies of documents you provide to prove your age or identity (including your passport and driver’s licence). This will include details of your full name, address, date of birth and facial image. If you provide a passport, the data will also include your place of birth, gender and nationality.

4. How and why do we use your personal data?

We want to provide you with the best possible service and this is assisted by our developing a comprehensive picture of you, combining the data we have about you. We can then use this to offer you appropriate and relevant products and services.

The data privacy law allows this as part of our legitimate interest in understanding our clients and providing the highest levels of service.

If you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below.

Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for.

Here’s how we’ll use your personal data and why:

To process any enquiries or orders that you make with our staff through our offices. If we don’t collect your personal data, we won’t be able to process your order and comply with our legal obligations.
To respond to your queries, using the information you sent to enable us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
To protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account. We’ll do all of this as part of our legitimate interest.
To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.
With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, telephone and through our offices about relevant products and services. Of course, you are free to opt out of hearing from us by any of these channels at any time.
To send you relevant, personalised communications by post in relation to updates, services and products. We’ll do this on the basis of our legitimate business interest. You are free to opt out of hearing from us by post at any time.
To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice and legally required information relating to your insurances. These service messages will not include any promotional content and do not require prior consent when sent by email. If we do not use your personal data for these purposes, we would be unable to comply with our legal
To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests.
To comply with our contractual or legal obligations to share data with law enforcement.
To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email. We have a legitimate interest to do so as this helps make our products or services more relevant to you. Of course, you are free to opt out of receiving these requests from us at any time by updating your preferences in your online account.
To build a comprehensive picture of who you are and your preferences, and to inform our business decisions, we’ll combine data captured from our interaction with you and data from publicly-available data. We’ll do this on the basis of our legitimate business interest.

5. Combining your data for personalised direct marketing

We want to bring you detail of services and products that are most relevant to your interests at particular times. To help us form a better, overall understanding of you as a client, we combine your personal data gathered across the business as described above. For this purpose we also combine the data that we collect directly from you with data that we obtain from third parties to whom you have given your consent to pass that data onto us.

6. How we protect your personal data

We know how much data security matters to all our clients. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.

7. How long will we keep your personal data?

Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected. At the end of that retention period, your data will be deleted completely.

8. Who do we share your personal data with?

We sometimes share your personal data with trusted third parties.

Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:

We provide only the information they need to perform their specific services.
They may only use your data for the exact purposes we specify in our contract with them.
We work closely with them to ensure that your privacy is respected and protected at all times.
If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.

Sharing your data with third parties for their own purposes which we will only do this in very specific circumstances, for example:

For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.
We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.

9. What are your rights over your personal data?

You have the right to request:

Access to the personal data we hold about you, free of charge in most cases.
The correction of your personal data when incorrect, out of date or incomplete.
That we stop using your personal data for direct marketing.
That we stop any consent-based processing of your personal data after you withdraw that consent and where we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end.

You have the right to request a copy of any information about you that Lothbury UK holds at any time, and also to have that information corrected if it is inaccurate. To ask for your information, please contact the Compliance Officer, Lothbury UK Ltd, Bank House, 18 White Friars, Chester, CH1 1PW, or email info@lothburyuk.com

You can also use the same contact methods to ask for your information to be amended.

If we choose not to action your request we will explain to you the reasons for our refusal.

Your right to withdraw consent:
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.

Where we rely on our legitimate interest:
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.

Direct marketing:
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.

Right to data portability:
You have the right to data portability of the personal information that you have provided to us which allows you to obtain and use your personal data for your own purposes.

Checking your identity:
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.

10. How can you stop the use of your personal data for direct marketing?

You can stop direct marketing communications from us by:

writing to the Compliance Officer, Lothbury UK Ltd, Bank House, 18 White Friars, Chester, CH1 1PW, or
by emailing us at info@lothburyuk.com

Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.

11. Contacting the Regulator

If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

You can contact them by calling 0303 123 1113.
Or go online to www.ico.org.uk concerns (opens in a new window; please note we can’t be responsible for the content of external websites)

This notice was last updated on 15/05/2018