Lince Salisbury is keen to ensure the highest level of privacy arising from contact through our its website. This privacy statement is split into two parts:
An explanation behind the data and its usage collected when you visit our website; and
An explanation behind the data and its usage collected under our standard terms of business.
INFORMATION WE COLLECT WHILST VISITING OUR WEBSITE
In operating our website we may collect and process the following data about you:
Details of your visits to our website and the resources that you access, including, but not limited to, traffic data, location data, weblogs and other communication data.
Information that you provide by filling in forms on our website.
Information provided to us when you communicate with us for any reason.
USE OF COOKIES
Cookies are sometimes used to improve the website experience of a visitor to a website. When collected, this information is used by us to improve our website and further enhance the visitor experience.
Where used, these cookies are downloaded to your computer automatically. This cookie file is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive and then stored there and transferred to us where appropriate to help us to improve our website and the service that we provide to you.
All computers have the ability to decline cookies. You can easily decline or remove cookies from your computer using the settings within the Internet Options section in your computer control panel.
USE OF YOUR INFORMATION
The information that we collect and store relating to you is primarily used to enable us to provide our services to you. In addition, we may use the information for the following purposes:
To provide you with information requested from us, relating to our products or services. To provide information on other products which we feel may be of interest to you, where you have consented to receive such information.
To meet our contractual commitments to you.
To notify you about any changes to our website, such as improvements or service/product changes, that may affect our service.
STORING YOUR PERSONAL DATA
Any data that is provided to us (i.e. email address) is stored on our secure servers. If you do not wish us to store your information on our secure database, please email info@lince-salisbury.com
The transmission of information via the internet is not completely secure and therefore we cannot guarantee the security of data sent to us electronically and transmission of such data is therefore entirely at your own risk.
DISCLOSING YOUR INFORMATION
We may disclose your personal information to third parties:
Where we are legally required to disclose your information, including but not limited to, AML and CFT disclosures.
To assist fraud protection and minimise credit risk.
Otherwise, we will never share your information with any third parties.
THIRD PARTY LINKS
You will find links to third party websites on our website. These websites should have their own privacy policies which you should check. We do not accept any responsibility or liability for their content whatsoever as we have no control over them.
ACCESS TO INFORMATION
You are free to request a copy of any information that we hold about you. Please contact us if you wish to make such a request.
If for any reason the details we hold are incorrect, please email us as info@lince-salisbury.com
CONTACTING US
We welcome any queries, comments or requests you may have regarding this Privacy Policy. Please do not hesitate to contact us at info@lince-salisbury.com
PRIVACY NOTICE RELATING TO CLIENTS AND SERVICES OFFERED AND PROVIDED
We fully understand that we can deal with some of your most sensitive personal information. However, we will only use your personal information to deliver the services we have been engaged to provide and to meet our legal responsibilities.
THE LEGAL FRAMEWORK
Any personal data collected and used by Lince Salisbury is done so in accordance with the Data Protection (Bailiwick of Guernsey) Law, 2017 and in accordance with the European Union General Data Protection Regulation (2016/679).
HOW WE COLLECT YOUR INFORMATION
As noted above, we collect some information when you use our website. We also collect information as part of taking you on as a client and through our continuing relationship with you. This is defined in our engagement letters.
THE TYPE OF INFORMATION WE COLLECT
The personal information we collect from you will vary depending on which services you engage us to deliver. It might include:
your name, address, telephone number
email address
tax and social security references
your driving licence and passport details
bank account details
HOW WE USE YOUR INFORMATION
We are required to gather certain information in order to fulfil our obligations under the legislative framework under which we offer our services. This means, in general terms, we may need to:
verify your identity;
verify your address;
understand your needs and how they may be met;
prevent and detect crime, fraud or corruption;
process your financial transactions; and
contact you, be it by post, email or telephone
We are required by legislation, other regulatory requirements and our insurers to retain your data where we have ceased to act for you. The period of retention required varies with the applicable legislation but is typically six years. To ensure compliance with all such requirements it is the policy of the firm to retain all data for a period of six years after we cease to act.
OTHERS ACCESS TO YOUR INFORMATION
Lince Salisbury respect your right to privacy. As such we will:
never sell your information to third parties;
not share your information with third parties for marketing purposes; and
ensure all staff with access to your information are made fully aware of their duty to abide by legislation and ethical standards by which the firm operates.
THIRD PARTY SERVICE PROVIDERS
As part of our business processes, we engage third party service providers (including agents, subcontractors and associates) to enable us to provide our services to you. For example, we use online accounting tools, as well as Guernsey governmental websites to assist in the filing of certain financial information.
However we ensure that those providers only receive the minimum required level of personal information and that they themselves are aware of their obligations as a data processor under the law.
We commit to not releasing your information to third parties unless it is essential to complete a task you have asked us to do, you have explicitly requested us to release the information (eg certified documents to another professional agent) or we are required to do so by law, for example, by a court order or for the purposes of prevention and detection of crime, fraud or corruption.
YOUR ACCESS TO YOUR INFORMATION
It is important for us to keep your information accurate and up to date. In general we perform our work at least annually and at that stage we review the information we hold about you. If any of your information changes, please contact us via email, phone (on 01481 735000) or write to us.
You have the right to ask for a copy of the information that Lince Salisbury holds about you.
OUR SECURITY MEASURES IN PLACE TO PROTECT YOUR INFORMATION
Whilst we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk.
Once we receive your information, we make our best effort to ensure its security on our systems. Where we have given, or where you have chosen, a password which enables you to access information, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Your data will usually be processed in our office in Guernsey. However, as is customary with efficient technological platforms, we sometimes need to store information in servers located outside Guernsey.
We take the security of your data seriously and so all our systems have appropriate security in place that complies with all applicable legislative and regulatory requirements.
LET US KNOW
There may be occasions, such us updating you on legal and regulatory matters, where we think contacting you is appropriate. If you do not want to receive these communications please let us know via email.
YOUR RIGHTS
The Data Protection (Bailiwick of Guernsey) Law, 2017 provides the following rights for you:
The right to be informed
The right of access – you can request from us a copy of the personal information we hold on you.
The right to rectification – We want to have the most accurate information on you as we believe it enables us to give a better service to you. However, if you feel any of the information we have is not up to standard you can ask us to correct it.
The right to erasure (or the right to be forgotten) – notwithstanding our needs under law to retain certain information you are able to request we delete the information we hold on you. You have this right if:
the personal data is no longer necessary for the purpose which we originally collected or processed it for;
you withdraw consent – you may withdraw that consent at any time and we will stop using your personal information for the purpose(s) for which consent was given. This may mean we are unable to perform our services;
you don’t think we have a legitimate interest in the data;
we are processing the personal data for direct marketing purposes and you object to that processing;
we have processed the personal data unlawfully;
we have to do it to comply with a legal obligation
The right to restrict processing – In certain circumstances, you can ask us to limit how we process your data. You can find more on this here (Data Protection Commissioner Website).
The right to data portability.
The right to object – You have an absolute right to object if we use your data for direct marketing. You also have a right to object in certain other specific circumstances.
Rights in relation to automated decision making and profiling.
Please contact us in any of the ways set out in ‘Contact information’ below if you wish to exercise any of these rights.
CHANGES TO OUR PRIVACY NOTICE
We keep this privacy notice under regular review and update it here from time to time. This privacy notice was last updated on 22nd May 2018.
CONTACT INFORMATION
By Post:
Lince Salisbury Limited
Avenue House
St Julian’s Avenue
St. Peter Port
Guernsey
GY1 1WA
By phone:
01481 735000
By email:
COMPLAINTS
We seek to resolve directly all complaints about how we handle your personal information but you also have the right to lodge a complaint with the Data Protection Commissioner at:
Data Protection Office
Block A, Lefebvre Court
Lefebvre Street
St Peter Port
Guernsey
GY1 2JP
Or online at https://www.odpa.gg/for-individuals/make-a-complaint/