Dixcart Legal Limited
Privacy Notice (Marketing)(CRM)
Welcome to the Dixcart Legal Limited (“Dixcart Legal”) Privacy Notice (Marketing)(CRM)
This notice relates to the processing of personal data for marketing purposes including where we use CRM software and when you visit our website, www.dixcartlegal.com (“Website”). We use CRM software to process personal data whenever a data subject subscribes to one of our newsletters or has provided consent to one of our marketing communications via our Website. This software is operated by the Dixcart Group and is used by all the entities in the Dixcart Group for marketing communications.
A separate notice is in place in connection with the provision of legal services and in connection with business relationships.
Dixcart Legal respects your privacy and is committed to protecting your personal data. This privacy notice will inform you how we collect, use, share and look after your personal data when you visit our Website (regardless of where you visit it from) and when you subscribe to one of our newsletters or have provided consent to one of our marketing communications via our Website. It also tells you about your privacy rights and how the law protects you.
- Who we are
Dixcart Legal is the controller and responsible for your personal data where Dixcart Legal process it for marketing purposes.
Please note that where you have consented to the Dixcart Group contacting you for marketing purposes then the relevant entity within the Dixcart Group is the controller of your data in relation to any contact the Dixcart Group make with you, they are responsible for processing your data and their privacy notice applies to you. A copy of that Privacy Notice can be found on the Dixcart website at www.dixcart.com.
Any reference to “Dixcart Group” means Dixcart Group Limited (Registered in IOM, no. 004595C) of 69 Athol Street, Douglas, IM1 1JE, Isle of Man, Dixcart Group UK Holding Limited (Registered in Guernsey, no. 65357) of Ground Floor, Dixcart House, Sir William Place, St Peter Port, Guernsey, Channel Islands, GY1 4EZ, Dixcart Professional Services Limited (Registered in Guernsey, no. 59422) of Dixcart House, Sir William Place, St Peter Port, Guernsey, Channel Islands, GY1 4EZ, Dixcart Audit LLP (Company number OC304784) of Dixcart House, Addlestone Road, Bourne Business Park, Addlestone, Surrey KT15 2LE and any subsidiary company from time to time of any of them and each of them is a member of the Dixcart Group.
Dixcart Legal is authorised and regulated by the Solicitors Regulation Authority No. 612167.
Dixcart International Limited (Chartered Accountants and Tax Advisers) and Dixcart Audit LLP are authorised and regulated by the Institute of Chartered Accountants in England and Wales (ICAEW).
Dixcart International Limited (Surrey Business IT) is an unregulated business.
We do not have a data protection officer. We have appointed a data privacy manager. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Our full details are:
Dixcart Legal Limited
Postal address: Dixcart House, Addlestone Road, Bourne Business Park, Addlestone, Surrey KT15 2LE
Telephone number: +44 (0) 333 122 0010
Name or title of data privacy manager: Peter Wilman
Email address: firstname.lastname@example.org
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.
Changes to the privacy notice and your duty to inform us of changes
This version is effective from the effective date as indicated at the end of this notice. Historic versions (if any) can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
The Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy notices. When you leave our Website, we encourage you to read the privacy notice of every website you visit.
- The data we collect about you
The Website is not intended for children and we do not knowingly collect data relating to children.
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 (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Contact Data such as first name, last name, title, email address, postal address, telephone numbers, employer and job title.
- Profile Data such as your preferences in receiving marketing from us and from the Dixcart Group, your communication preference and your feedback responses.
- Other Information any information you choose to provide to us such as an inability to attend an event due to a holiday.
We also 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.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
- How and why we use your personal data for marketing and to whom we disclose it
This privacy notice only deals with the use of personal data for marketing using CRM software and when you visit our Website . We use CRM software to process personal data whenever a data subject subscribes to one of our newsletters or has provided consent to one of our marketing communications via our Website. This notice applies to such marketing for both clients and non-client contacts. Use of personal data in relation to the provisional legal services and/or in connection with business relationships is dealt with in a separate Privacy Notice (Legal Services and Business Relationships).
We rely on your consent as the legal basis for processing your personal data in relation to such marketing communications to you. You have the right to withdraw consent to such marketing at any time (opting out).
We have set out how and why we use your personal data and to whom it may be disclosed in a table format:
Types of Data
Information you give us by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
To contact you with our publications and/or marketing communications as consented to by you.
To respond to any feedback from you on one of our marketing events or communications.
Personal data may be transferred to and viewed by any entity within the Dixcart Group both in the UK and overseas.
Dixcart Group entities may contact you if you have consented.
Personal data may be transferred to and viewed by any party providing services to us to support the operation of our business, such as IT and other administrative support.
Where you are a professional service provider we may pass your details onto clients or contacts by way of referral and networking.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
You can ask us to stop or stop us sending you marketing messages at any time by following the opt-out/unsubscribe links or instructions on any newsletter mailshot sent to you or by contacting us at any time at email@example.com. [or via our website]
Where you opt out of receiving marketing messages we may continue to process your personal data in relation to the provision of legal services and in connection with our business relationships with you. Our Privacy Notice (Legal Services and Business Relationships) will govern such processing of your personal data. See our Website for a copy of the Privacy Notice (Legal Services and Business Relationships).
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we obtain your consent to use it for another purpose or where the alternative purpose is required or permitted by law without your consent.
- International transfers
We share your personal data within the Dixcart Group. This will involve transferring your data outside the European Union.
Where you are a professional service provider and we pass your details onto clients or contacts by way of referral and networking they may be outside the European Union.
Whenever we transfer your personal data out of the European Union, we take all reasonable steps to ensure that the transfer is made securely and that there is adequate protection in place to protect your personal data. This can be done in a number of different ways, including:
- transferring your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- by using model contractual clauses approved by the European Commission which give personal data the same protection it has in the European Union.
- if we use providers based in the US, by ensuring that they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the European Union and the US.
- other means permitted by applicable data protection law.
Please contact us at firstname.lastname@example.org if you want further information on the specific mechanism used by us when transferring your personal data out of the European Union.
- Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
- Data retention
How long will you use my personal data for?
We will retain your contact details for as long as your consent allows us to do so. On withdrawal of your consent your contact details may be held on a marketing suppression list.
Details relating to particular events and invites may be held for a minimum of 3 years or for as long as necessary to fulfil the purposes we collected it for.
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 and the applicable legal requirements.
- Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
Request access to your personal data (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.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Request restriction of processing of your personal data. This enables you to ask 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.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on 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 certain services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us at email@example.com so that we may consider your request. As a law firm we have certain legal and regulatory obligations which we will need to take into account in considering any request. No fee is usually required. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). We may also contact you to ask you for further information in relation to your request to speed up our response.
Effective Date: 11 October 2018
Dixcart Legal Limited