Boscobel & Partners respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or purchase our services, or apply for a job, or as an individual or entity with whom we communicate with on behalf of clients and tell you about your privacy rights and how the law protects you.

Important Information & Who We Are

1.1 Purpose of this privacy policy

This privacy policy aims to give you information on how Boscobel & Partners collects and processes personal data. This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy 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 policy supplements the other notices and is not intended to override them.

1.2 Controller

Boscobel & Partners Limited (collectively referred to as “Boscobel & Partners”, “we”, “us” or “our” in this privacy policy) is the data controller and is responsible for your personal data.

Boscobel & Partners, as the data controller, is responsible for this website and for managing the data we have in order to conduct our business as a financial communications and public relations adviser.

We have appointed a Data Protection Officer (“DPO”) who is responsible for overseeing questions in relation to this privacy policy.  The DPO is Rachel Davis.   If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

1.3 Contact details

Full name of legal entity: Boscobel & Partners Limited

Name and title of DPO : Rachel Davis, executive assistant and office manager.

Email address: rdavis@boscobelandpartners.com

Telephone number: +44 (0)203 642 1310

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 (www.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.

1.4 Changes to the privacy policy and your duty to inform us of changes

It is important that the items of personal data we hold about you are accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Any changes to this privacy policy will be posted on this site and where appropriate notified to you in writing.

The Data We Collect About You

2.1 Meaning of and types of personal data

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 (rendered anonymous, or “pseudonymised”).

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

(a)    Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender and, where you are applying for a job with us, any data contained in any CV provided by you.

(b)    Contact Data includes billing address, delivery address, email address and telephone numbers.

(c)    Financial Data (for clients, suppliers and employees) includes bank account and payment card details.

(d)   Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us or materials and publications you have subscribed to from us.

(e)    Technical Data may include 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.

(f)     Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

(g)    Usage Data includes information about how you use our website, products and services, materials or publications.

(h)    Marketing and Communications Data includes correspondence with us and your preferences in receiving marketing from us and our third parties and your communication preferences.

Please relate (a) to (h) above to the chart in paragraph 4.3, below.

We also may 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 treat the combined data as personal data which will be used in accordance with this privacy notice.

2.2 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 (for example, to provide you with products or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

How Is Your Personal Data Collected?

We use different methods to collect data from and about you including the following:

3.1 Direct interactions

You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

3.1.1 apply for our products or services;

3.1.2 create an account on our website;

3.1.3 subscribe to our service or publications;

3.1.4 request marketing to be sent to you;

3.1.5 enter a competition, promotion or survey;

3.1.6 give us some feedback; or

3.1.7 apply for a job with us.

3.2 Subscriber directories

intended to provide personal data where relevant. We only use such directories which we believe themselves comply with appropriate regulations such as GDPR.

3.3 Automated technologies or interactions

As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

How We Use Your Personal Data

4.1 We use only as permitted by law

We will only use your personal data when the law allows us so to do. Most commonly, we will use your personal data in the following circumstances:

4.1.1 Where we need to perform the contract we are about to enter into or have entered into with you.

4.1.2 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.

4.1.3 Where we need to comply with a legal or regulatory obligation.

4.2 Consent/withdrawal

Save as stated above in paragraph 4.1.2 and 4.1.3, we rely on consent as the legal basis for processing your personal data; where we do, in most (but not all) cases,  you have the right to withdraw consent at any time by contacting us.

 4.3 Table of ways of usage of 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 wish to discuss 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.

Purpose/Activity	Type of data
To register you as a new client	(a) Identity (b) Contact
To process and deliver your order including: (i) Manage payments, fees and charges (ii) Collect and recover money owed to us	(a) Identity (b) Contact (c)Financial (d) Transaction (e) Marketing and Communications
To manage our relationship with you which will include: (i) Notifying you about changes to our terms or privacy policy (ii) Sending communications on behalf of clients, for example to members of the press, politicians and civil servants (iii)Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we send to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f)  Technical
To use data analytics to improve our website, products/services/materials/publications, marketing, customer relationships and experiences	(a) Technical (b) Usage
To make suggestions and recommendations to you about goods or services/ materials/publications that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile
To administer any job applications/CVs you  provide, or in which you are involved	(a) Identity (b) Contact

Marketing

 We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:  namely, our recent emails to our clients and other contacts entitled ‘We’d like to stay in touch’ and ‘Stay up to date with Boscobel & Partners’, inviting recipients to choose to opt-in if they would like to do so.

Opting Out

You can ask us or third parties to stop sending you marketing messages at any time by contacting our DPO, in writing or by phone, at any time.

Where you opt out of receiving these marketing messages, this opt-out will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions, in relation to which we are required by law to retain your data.

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 may not function properly.  For more information about the cookies we use, please see here.

Change of Purpose

We will only use your personal data for the purposes for which we collected it.

If we need to use your personal data for an unrelated purpose, we will contact you to explain why we wish to use it for the unrelated purpose and to request your consent to our using it for that unrelated purpose.

Please note that we may process your personal data without your knowledge or consent, where this is required or permitted by law.

Disclosures of Your Personal Data

For the purposes set out in the table in paragraph 4.3 above, we may have to share your personal data with the parties set out below:

• Internal Third Parties who will become members of the Boscobel & Partners group, if it grows.
• External Third Parties who may receive personal data, which parties currently include our external IT providers and third parties who manage our marketing database and deliver marketing emails on our behalf.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.
• Third parties in respect of which we may seek to acquire their businesses or to merge with them.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. In any event, we would not allow our third-party service providers to use your personal data for their own purposes and we would only permit them to process your personal data for specified purposes and in accordance with our instructions and your prior consent.

International Transfers

Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data would involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we will ensure that a no lesser degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where we use service providers, we will only use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
• Specifically, where we use service providers based in the USA, we may transfer data to them if they are part of the Privacy Shield which requires them to provide protection to personal data which protection is no less strong than that shared between the European Union and the USA.

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, stolen, used or accessed in an unauthorised way, altered, or disclosed.  In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a professional need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and the UK Information Commissioner’s Office (“ICO”)  of a breach where we are legally required to do so.

Data Retention Periods

• We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
• To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data, whether we can achieve those purposes through other means and the applicable legal requirements.
• Unless you opt-out, we will keep marketing data for three years and CVs for one year.
• By law, we have to keep basic information about our clients (including Contact, Identity,
• Financial and Transaction Data) for six years after they cease being customers, for tax purposes.
• In some circumstances, you can ask us to delete your data: see paragraph 9 below for further information.

Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data which are as follows.

13.1 You have the following 8 fundamental rights

1. Right to be informed — i.e. the right to know how our personal data is used;
2. Right to access — i.e. gives an individual access to their data and associated data (if any). You can access your personal data by what is 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.
3. Right to rectification — i.e. the right to have rectification of any personal data if it is inaccurate / deficient. You can have correction made to the personal data that we hold about you if it is incomplete or inaccurate. However, we may need to verify the accuracy of the new data you provide to us.
4. Right to erasure / to be’ forgotten’ –i.e. remove personal data if there is no compelling reason to retain it. This enables you to require us to delete or remove personal data where there is no compelling reason for us continuing to hold / process it.
5. Right to restrict processing — i.e. if data is stored, the individual can insist that it is not processed (e.g. if rectification is awaited).  You can require us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful, but you do not want us to erase it; (c) 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 (d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.  You can withdraw consent at any time where we are relying on your 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 to you certain products or services or materials/publications. We will advise you if this is the case at the time you withdraw your consent.
6. Right to data portability — i.e. a person may ask for copies of stored information to be used in other areas (e.g. if they are applying for financial products from different providers).  We will provide to you, or to a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.
7. Right to object — i.e. data controller must comply if someone raises an objection to the processing of their data for a particular use (e.g. for marketing). You can object to processing of your personal data where we say we are relying on a legitimate interest (or that of a third party) but you believe that there is something about your particular situation which makes you want to object to our processing on this ground as you feel it impacts on your fundamental rights and freedoms. We may be able to demonstrate that we have compelling legitimate grounds to process your information, which grounds override your rights and freedoms.
8. Right not to be subject to automated decision-making, including profiling — i.e. where decisions are being made about someone by a machine (without human involvement – e.g. tracking online shopping habits) a person may raise an objection.

If you wish to exercise any of the rights set out above, please contact us.

13.2 No fee usually required

You will not have to pay a fee to access your personal data, or to exercise any of the other fundamental rights, specified above in paragraph 13.1. However, we may charge a reasonable fee, or we may refuse to comply, if your request is clearly unfounded.

13.3 What we may need from you

We may need to request specific information from you to help us confirm your identity and to ensure your right to access your personal data, or to exercise any of your other fundamental rights. This is a security measure to ensure that personal data is not disclosed to any person who has no right to it. We may also contact you to ask you for further information in relation to your request to accelerate our response.

13.4 Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.