Article 5 of the General Data Protection Regulation (GDPR) States that Personal Data must be processed lawfully fairly and in a transparent manner. In line with the GDPR changes we are updating our Privacy Notice so you can better understand why and how we collect, process and destroy your data. We are committed to protecting and respecting your privacy. This policy, (together with the Terms and Conditions and any other documents referred to in it), sets out the legal basis on which any Personal Data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your Personal Data and how we will treat it
2. What types of Personal Data do we collect?
We collect information about you when you subscribe to our newsletter or become an online customer. We also gather data information when you share information based on consent by participating in surveys and competitions or attending events. We may control, process and use your Personal Data, which may include:
- Postal addresses
- Email addresses
- Telephone numbers
- Or any other Personal Data that you provide to us.
We may also, in appropriate cases and to the extent permitted by law, control, process and use certain special categories of Personal Data which are more sensitive in nature. Example of some of these cases may arise when undertaking “Know Your Customer” (KYC) on potential clients where potential restrictions may arise from political or religious beliefs
3. Identity of the Firm
Whitestep Ltd (company number 06208613), registered at The Stations Masters’ House, 168 Thornbury Road, Osterley Village, Isleworth TW7 4QE, United Kingdom
4. Lawful basis for Processing
Where we act as Data Controller, we rely on the following legal basis for Processing your Personal Data:
- Consent: if you are a recipient of our online direct marketing. If you have consented to receive marketing, you may opt out at a later date.
- Legitimate Interest: if you are our client or prospect client, business affiliate, or our website visitor, we may decide to send you materials of interest such as information about our services/products which we believe it would beneficial to you All such decisions are subject to Legitimate Interests Assessment (LIA) in order to ensure that processing is in line with that Data Subjects’ rights.
- Performance of Contract: if you are our client, supplier, employee, akin to employee or business affiliate or our website visitor;
- Legal Obligation: if we process Personal Data according to requirements of domestic legislation as in the case AML checks
Where we act as a Data Processor, we process Personal Data on behalf of Data Controller and we act on their written instructions.
5. Data protection officer
The Firm has no regulatory obligations under the GDPR to appoint a DPO; the Firm has no data protection officer (DPO) currently appointed. The GDPR sets out guidelines on when the appointment of a DPO shall be required as follows:
- where the scope or purpose of collecting data requires a regular systematic monitoring of the Data Subjects;
- where the Firm processes special categories of data on a large scale;
- where Processing is carried out by a public authority.
The Firm has instead agreed to name a responsible officer (the “Responsible Officer”) who may be reached at firstname.lastname@example.org
6. Purpose of data collected
The personal information we collect is for the following legitimate interest:
• Promotion of ideas and events relating to services we provide;
• Keeping your records accurate and up to date,
• Maintenance of records of communications and management of your relationship with us;
• Responding to your enquiries;
7. Who we share our information with
We will not share personal information about you with third parties without your consent. We are required, by law, to sometimes pass on some of this Personal Data to:
- other bodies as required by law or regulation; or
To fulfill our contract with you, the Firm may sometimes pass information to:
- Intra group entities who provide additional or complementary services
- Third party IT Service Providers
- Any other third-party services providers e.g. Paypal, Mailchimps
We will keep your Personal Data for no longer than reasonably necessary. We will retain your personal information in accordance with legal and regulatory requirements as set out in our Data retention policy.
9. Your rights and your Personal Data
You have a right:
- to request a copy of your Personal Data which the Firm or related data Controller holds about you;
- to request the Firm or any related Data Controller to correct any Personal Data if it is found to be inaccurate or out of date;
- to request your Personal Data is erased where it is no longer necessary for the Firm or related Data Controller to retain such data;
- to withdraw your consent to the Processing at any time if consent constitutes the lawful basis for processing;
- to object to Processing based on grounds relating to the Data Subject situation if the processing is necessary for the performance of a task carried out in the public interest or the processing is necessary for the purposes of the legitimate interest by us or a third party, unless such interest is overridden by your fundamental rights and interests;
- to request a restriction is placed on further Processing;
- to lodge a complaint with the Information Commissioners Office (the UK Supervisory Authority); you can contact the Information Commissioners Office on 0303 123 1113 or via
email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF;
- not to be subject to a decision based on automated Processing; the Firm does not practice such decision making.
10. Further Processing
Where we may seek to further process your data other than for the original purpose for which it was collected, the Firm shall only further process such data where the new Processing is compatible with the original purpose.
11. Safeguarding measures
We take your privacy seriously and take every reasonable measure and precaution to protect and secure your Personal Data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place, including, without limitation, encryptions.
When sending marketing materials to customers, we may have the option to rely on your consent or legitimate interest.
We only use legitimate interests for marketing if we have assessed that the information being sent is beneficial to the customer, and have weighed our interests against your own and there is little to no risk posed, the method and content is non-intrusive, and the material being sent is something you would usually expect to receive.
13. Cookies, analytics and traffic data
We provide the following information with some explanations to ensure transparency to our users:
- what types of cookies are set;
- how long they persist on your user’s browser;
- what data they track;
- for what purpose (functionality, performance, statistics, marketing, etc.;
- where the data is sent and with whom it is shared;
- how to reject cookies, and how to subsequently change the status regarding the cookies.