ASTORTS LTD understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits Our Site, www.astorts.com (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with ourobligations and your rights under the law.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
|“Account”||means an account required to access and/or use certain areas and features of Our Site;|
|“Cookie”||means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and|
|“Cookie Law”||means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;|
2. Information About Us
Our Site is owned and operated by ASTORTS LTD, a company registered in England, under No. 08060635, with a registered office located at Rowlandson House, 289-297 Ballards Lane, London, N12 8NP.
3. What Does This Policy Cover?
4. What Is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
5. What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
- The right to access the personal data we hold about you. Part 13 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 15 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. we would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 15.
6. What Data Do You Collect and How?
We may collect, record and use your personal data in physical and electronic form, and will hold, use and otherwise process that data in line with the Data Protection Legislation and as set out in this statement.
When we provide services to you or our clients and perform due diligence checks in connection with our services (or discuss possible services we might provide), we will process personal data about you. We may also collect personal data from you when you use Our Site.
We may process your data because:
- you give it to us (for example, in a form on Our Site);
- other people give it to us (for example, your employer or adviser, a tax authority and/or other relevant authority/administrative bodies; or third- party service providers that we use to help operate our business); or
- it is publicly available.
The personal data we process may include your:
- name, gender, age and date of birth;
- contact information, such as address, email, and mobile phone number;
- country of residence;
- employment and education details (for example, the organisation you work for, your job title and your education details, employment records);
- financial and tax-related information (for example your income, investments and tax residency);
- Government identifiers (such as national insurance number);
- postings or messages on Our Site;
- IP address, browser type and language, your access times;
- information in any complaints you make;
- details of how you use our products and services;
- details of how you like to interact with us, and other similar information relevant to our relationship.
We may also need to process personal information about you that may be considered sensitive or a special category (for example about your health or ethnic origin) that we require to be able to provide the services or that may become apparent to us based on the personal information that we receive.
If you choose not to provide, or object to us processing, the information we collect, we may not be able to process your instructions or continue to provide some or all of our services to you or our client.
Personal data provided by or about third parties
When our client or another third party gives us personal data about you, we make sure they have complied with the relevant privacy laws and regulations. This may include, for example, that the client or other third party has informed you of the processing, and has obtained any necessary permission for us to process that information as described in this privacy statement.
7. How Do You Use My Personal Data?
We process information about you and/or your business to enable us to provide our services to you or our clients, and to meet our legal or regulatory obligations.
Some of your personal data may be used for other business purposes. Below are some examples.
Use of personal data to provide services to our clients.
We will use your personal data to provide you or our clients or other third parties with services, and this includes using your personal data in correspondence relating to those services. That correspondence may be with:
- other third parties or other members related to us;
- our service providers; or
- competent authorities.
We may also use your personal data to conduct due diligence checks relating to the services.
Because we provide a wide range of services to our clients or other third parties, the way we use personal data in relation to our services also varies. For example, we might use personal data about:
- a client’s employees to help those employees manage their tax affairs when working overseas;
- a client’s employees and customers in the course of conducting an audit (or similar activity) for a client; or
- a client to help them complete a tax return.
Use of personal data for other activities that form part of the operation of our business
We may also use your personal data in connection with:
- legal or regulatory requirements;
- requests and communications from competent authorities;
- client account opening and other administrative tasks;
- financial accounting, invoicing and risk analysis;
- recruitment and business development, which may involve:
(a) the use of testimonials from a client’s employees as part of our recruitment and business development materials (with that employee’s permission); and
(b) the use of third-party data sources to help us verify and improve the information we hold about key business relationships with individuals;
- services we receive from our professional advisors, such as lawyers, accountants and consultants;
- investigating or preventing security incidents; or
- protecting our rights and those of our clients.
Use of personal data collected via Our Site
In addition to the above, we may also use your personal data collected via Our Site:
- to manage and improve Our Site;
- to tailor the content of Our Site to give you a more personalised experience;
- to draw your attention to information about our products and services that may be of interest to you; or
- to manage and respond to any request you submit through Our Site.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone, text message or post with information, news, and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
Third Parties whose content appears on Our Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.
We may use your personal information for the purposes outlined above because:
(a) we have a legitimate interest in processing your personal information, which may be to:
- provide services to our clients;
- keep you or our clients informed about relevant products and services and provide you with information, unless you have indicated at any time that you do not wish us to do so;
- evaluate, develop or improve our services or products; or
- protect our business interests.
or (b) we are subject to legal or regulatory obligations, such as providing information to a public body or law enforcement agency.
To the extent that we process any special categories of data relating to you for any of the purposes outlined above, we will do so because either: (i) you have given us your explicit consent to process that data; (ii) we are required by law to process that data in order to ensure we meet our ‘know your client’ and ‘anti-money laundering’ obligations (or other legal obligations imposed on us); (iii) the processing is necessary to carry out our obligations under employment, social security or social protection law; (iv) the processing is necessary for the establishment, exercise or defence of legal claims; (v) you have made the data manifestly public; or (vi) the processing is necessary for reasons of substantial public interest.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
8. How Long Will You Keep My Personal Data?
We seek to ensure that we only keep your personal data for the longest of:
- the period necessary for the relevant activity or services;
- any retention period that is required by law; or
- the period in which litigation or investigations might arise in respect of the services.
9. How and Where Do You Store or Transfer My Personal Data?
Information we hold about you may be stored or transferred to other countries (which may include countries outside the European Economic Area (“EEA”)) :
- where we do business;
- which are linked to your engagement with us;
- from which you regularly receive or transmit information; or
- where our third parties conduct their activities.
These countries may have less stringent privacy laws than we do, so any information they hold can become subject to their laws and disclosure requirements, including disclosure to governmental bodies, regulatory agencies and private persons. In addition, a number of countries have agreements under which information is exchanged with other countries for law enforcement, tax and other purposes.
When we, or our permitted third parties, transfer your personal data outside the EEA, we will impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the EEA. We or they may also require the recipient to subscribe to international frameworks intended to enable secure data sharing.
We may also transfer your personal data when:
- the transfer is to a country deemed to provide adequate protection of your personal data by the European Commission; or
- where you have consented to the transfer.
If we transfer your personal data outside the EEA in other circumstances (for example, because we have to by law), we will make sure it remains adequately protected.
We may share non-personal, anonymised and aggregated information with third parties for several purposes, including data analytics, research, submissions, thought leadership and promotional activity.
10. Do You Share My Personal Data?
In connection with any of the purposes outlined in the “How and Where Do You Store or Transfer My Personal Data?” section above, we may disclose details about you to:
Our Site hosts social media applications or services that allow you to share content with other users (collectively “Social Media Applications”). Any personal data that you contribute to these Social Media Applications can be read, collected and used by other users of the application. We have little or no control over these other users, so any information you contribute to these Social Media Applications might not be handled in line with this privacy statement.
If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation.
11. How Can I Control My Personal Data?
In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails.
You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
12. Can I Withhold Information?
You may access Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
13. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within twenty days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
By using Our Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on Our Site for on-site analytics and are in place to improve Our Site’s user engagement. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
All Cookies used by and on Our Site are used in accordance with current Cookie Law.
We may use some or all of the following types of Cookie:
Strictly Necessary Cookies
A Cookie falls into this category if it is essential to the operation of Our Site, supporting functions such as logging in, your shopping basket, and payment transactions.
Functionality Cookies enable Us to provide additional functions to you on Our Site such as personalisation and remembering your saved preferences. Some functionality Cookies may also be strictly necessary Cookies, but not all necessarily fall into that category.
It is important for Us to know when and how often you visit Our Site, and which parts of it you have used (including which pages you have visited and which links you have visited). As with analytics Cookies, this information helps us to better understand you and, in turn, to make Our Site and advertising more relevant to your interests.
Third Party Cookies
Third party Cookies are not placed by Us; instead, they are placed by third parties that provide services to Us and/or to you. Third party Cookies may be used by advertising services to serve up tailored advertising to you on Our Site, or by third parties providing analytics services to Us (these Cookies will work in the same way as analytics Cookies described above).
Any of the above types of Cookie may be a persistent Cookie. Persistent Cookies are those which remain on your computer or device for a predetermined period and are activated each time you visit Our Site.
Any of the above types of Cookie may be a session Cookie. Session Cookies are temporary and only remain on your computer or device from the point at which you visit Our Site until you close your browser. Session Cookies are deleted when you close your browser.
It is important for Us to understand how you use Our Site, for example, how efficiently you are able to navigate around it, and what features you use. Analytics Cookies enable us to gather this information, helping Us to improve Our Site and your experience of it.
External web services
We sometimes use external web services on Our Site to display content within the web pages of Our Site, for example to display images, show videos or run polls. As with the social buttons, we cannot prevent these sites, or external domains, from collecting information on your use of this embedded content.
We may also use tracking technologies to determine whether you have read, clicked on, or forwarded certain email communications we send to you so that we can make our communications more helpful and interesting. If you do not wish us to confirm whether you have opened, clicked on or forwarded our communications, you will need to unsubscribe, as it is not possible for us to send these emails without tracking enabled. Registered subscribers can update their communication preferences at any time by contacting us, or you can unsubscribe following the instructions in the individual email communications you receive from us.
Please contact us if you would like more detailed information on the cookies we use.
Before Cookies are placed on your computer or device, you will be shown a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies [unless those Cookies are strictly necessary]; however, certain features certain features of Our Site may not function fully or as intended.
In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
15. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:
Email address: firstname.lastname@example.org.
Postal Address: Rowlandson House, 289-297 Ballards Lane, London, England, N12 8NP.
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.