Privacy Policy

Introduction

This privacy policy (“Privacy Policy”) sets out how The Security Circle and affiliated partnerships, offices and undertakings authorised to practice under the name ‘The Security Circle’ (and references to ‘The Security Circle’, ‘we ‘or ‘us’ are to one or more of those partnerships, offices and undertakings, as appropriate) collects, uses and protects the personal information that you provide to us through this website (“Website”) or elsewhere. You should also check the terms on our Website and any additional terms and conditions as notified to you from time to time that may regulate your use of this Website. Without prejudice to the foregoing, if you or your organisation is an The Security Circle client, these terms of use should be read in conjunction with our applicable engagement letter and terms of business, which will prevail in the event of any conflict with this Privacy Policy.

For the purpose of this Privacy Policy, the controller of personal data is The Security Circle and our contact details are set out in the Contact section at the end of this Privacy Policy. We also aim to satisfy the obligation of transparency under the EU General Data Protection Regulation 2016/679 ("GDPR") and national laws implementing the GDPR.

Changes to our Privacy Policy
We reserve the right to revise this Privacy Policy at any time. If we make any changes to our privacy policy, we will advise you of any material changes or updates by email.

Personal Information
We only collect personal information from you through the Contact Us section on the website. This includes name, email address, and optional information of your Organisation and Phone Number. Provision of personal information is voluntary but failure to provide certain personal information requested may render you unable to use or access certain services or parts of this Website. This personal information is referred to in this Privacy Policy as “Your Information”. We may also collect information about your use of our Website (for example, the URL you came from, your browser type and the pages of our Website that were viewed during your visit). For more information on how we do this, please see the section headed ‘Cookies’ below.

Use of Your Information
We may use Your Information and other information we gather about your use of this Website for the purposes of:

providing you with access to our Website and personalising your visit to our Website;
administering, supporting, improving and developing our business and services;
dealing with your enquiries and providing you with information about services which are similar to services you previously received from us;
marketing, as referred to in the section headed ‘Direct Marketing’ below;
letting you know about new legal developments;
providing you with alerts, newsletters and information about events or conferences;
seeking your participation in surveys or research by email, phone, fax or mail; and
modifying and improving our Website.

We may also contact you for other purposes that you consent to from time to time. You can opt-out from receiving further marketing communications from us at any time by emailing us at the link in each of our e-mails.

Legal Obligations
We will collect and use Your Information in accordance with The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679).

Disclosing Your Information to Third Parties
We do not sell, trade, or rent Your Information to others. We do not disclose Your Information to third parties without your consent unless we are legally required to do so or where such disclosure is necessary to enable third parties with whom we work to assist us in providing our services to you or to respond to your enquiry. Where we pass Your Information to any third parties, we will require those third parties to act in accordance with our instructions and adopt appropriate security measures to protect Your Information. We will take reasonable steps to ensure that Your Information is used by those third parties in accordance with this Privacy Policy.

International Transfers
Given the international scope of our business, by using this Website and providing us with Your Information, you acknowledge and agree to us sharing Your Information between our offices located in the United Kingdom and other parts of the world (as referred to on this Website) to be used in accordance with this Privacy Policy. Your Information will only be disclosed to our staff, contractors and consultants who all share our commitment to treating Your Information responsibly. Where data is being transferred to a third country, that third country has to have an adequate level of protection. Where there is not an adequate level of protection, appropriate safeguards are in place, ensuring your data subject rights are enforceable, along with effective legal remedies.

Direct Marketing
Your personal data (including your name, correspondence address, phone number, and email address) may be used for the purpose of marketing of our legal, regulatory and advisory services but we may not do so unless we have obtained your clear and freely given consent (which includes an indication of no objection). We may contact you for such purpose by telephone, SMS, e-mail, fax or automated message. You can opt-out from receiving further marketing communications from us at any time by emailing us at the link in each of our e-mails.

Your Data Rights
In accordance with your legal rights under the GDPR and other applicable law, you have certain rights, which are detailed below along with how to exercise them. Before we are able to act on your request, proof of identity will be required.

Right of Access

You have the right at any time to ask us for a copy of the personal information about you that we hold. Where we have good reason, and if the GDPR permits, we can refuse your request for a copy of your personal information, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reasons for doing so.

Right of Correction or Completion

If personal information we hold about you is not accurate, out of date or incomplete, you have a right to have the data rectified, updated or completed. You can let us know by contacting us here.

Right of Erasure

In certain circumstances, you have the right to request that personal information we hold about you is erased e.g. if the information is no longer necessary for the purposes for which it was collected or processed or our processing of the information is based on your consent and there are no other legal grounds on which we may process the information.

Right to Object to or Restrict Processing

In certain circumstances, you have the right to object to our processing of your personal information by contacting us here. For example, if we are processing your information on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which override your rights and interests. You also have the right to object to use of your personal information for direct marketing purposes.

You may also have the right to restrict our use of your personal information, such as in circumstances where you have challenged the accuracy of the information and during the period where we are verifying its accuracy.

Right of Data Portability

In certain instances, you have a right to receive any personal information that we hold about you in a structured, commonly used and machine-readable format.

You can ask us to transmit that information to you or directly to a third-party organisation.

The above right exists only in respect of personal information that:

· you have provided to us previously; and

· is processed by us using automated means.

While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third-party organisation's systems. We are also unable to comply with requests that relate to personal information of others without their consent.

You can exercise any of the above rights by contacting us using any of the methods in the Contact section here.

Most of the above rights are subject to limitations and exceptions. We will provide reasons if we are unable to comply with any request for the exercise of your rights.

Where applicable law allows, we reserve the right to make a small charge to cover our administrative expenses in responding to your request. We may also require further information to verify your identity or locate the specific information that you seek before responding.

Security to Protect Your Information
We employ appropriate technical and organisational security measures to protect Your Information from being accessed by unauthorised persons and against unlawful processing, accidental loss, destruction and damage. We will retain Your Information for a reasonable period or (if longer) as long as the law requires us to.

In particular, we will store certain categories of your personal information for the following periods of time:

Category of Personal Data

Contact details 5 years

Existing Customers 2 years after the contract ceases

We also endeavour to take all reasonable steps to protect Your Information from external threats. However, please be aware that there are inherent security risks of sending information by public networks or on public computers and we cannot therefore 100% guarantee the security of any data disclosed or transmitted over the internet.

Our Use of Cookies
By using this Website, you consent to us using “cookies” and similar technologies. Cookies are small pieces of information sent by the web server that hosts our Website to the web browser (for example, Internet Explorer, Safari, Google Chrome or Firefox) on the computer or device you use to access or Website. These cookies enable our web server to collect information from the browser on your device about your browsing activity when using this device to access our Website.

Other Websites
This Website contains links to third party operated websites which are outside our control and are not covered by this Privacy Policy. If you access such other websites using the links provided, the operators of those websites may collect personal information about you in accordance with their own privacy practices. These practices are likely to differ from ours, so you should check the terms of any applicable privacy policy or terms of use when you visit such third-party website.

Contact
If you have further comments, queries and requests relating to how we use Your Information, please contact us at compliance@thesecuritycircle.com.

Complaints

If you are unhappy about our use of your personal information, you can contact us using the details in the Contact section here. You are also entitled to lodge a complaint with the UK Information Commissioner's Office using any of the below contact methods:

Telephone: 0303 123 1111
Website:       https://ico.org.uk/concerns/
Post: Information Commissioner's Office
                      Wycliffe House
                      Water Lane
                      Wilmslow
                      Cheshire

Governing Law
This Privacy Policy is subject to UK law. To the maximum extent legally permitted, you agree that any dispute relating to use of your data as referred to under this Privacy Policy is subject to the exclusive jurisdiction of the courts of the United Kingdom and any proceedings relating to a dispute shall be in the English language.

If you have any enquiries or if you would like to contact us about our processing of your personal information, including to exercise your rights as outlined above, please contact us centrally by any of the methods below.

When you contact us, we will ask you to verify your identity.

Contact name: Scott Simpson, Gaynor Simpson

Telephone: +44 141 278 6422

Email: compliance@thesecuritycircle.com

Post: The Security Circle

272 Bath Street

Glasgow

G2 4JR

Scotland, UK

The Security Circle is a company registered in Scotland, Company Registration no. SC500583, registered office at 272 Bath Street, Glasgow, G2 4JR, Scotland, UK