Who are we?
We are Sub Rosa Global Ltd and you can find us at 10a Browning Road, London E11 3AR
What does this Policy cover?
At Sub Rosa Global Ltd we take your personal data seriously. This policy:
- Sets out the types of personal data that we collect about you.
- Explains how and why we collect and use your personal data.
- Explains how long we keep your personal data for.
- Explains when, why and with who we will share your personal data.
- Sets out the legal basis we have for using your personal data.
- Explains the effect of refusing to provide the personal data requested.
- Explains the different rights and choices you have when it comes to your personal data.
- Explains how we may contact you and how you can contact us.
When do we collect personal information and what personal information do we collect?
We may collect personal information about you as follows:
- If you fill in forms on our website, we will collect your contact details and the other information you provide in the form.
- If you contact us by any other means (e.g. email or telephone), we may keep a record of that contact and the information you provide us at that time.
- If you ask to be added to our marketing database, we will collect your name, the name of your company/organisation (if any) and email address.
- If you instruct us to provide professional services, we will collect a range of information relating to you that is relevant to that instruction and will be available upon request.
- We may collect personal data relating to third parties in the course of providing our services to our clients, including professional contact information and contact details of suppliers to us or our clients.
- If you apply for employment with us, we will collect a range of information relating to you and potential employment.
Links to other websites
Where do we store your personal information and how it is kept secure?
Some of the information you provide to us will be transmitted electronically, e.g. information provided via our website or by email. We would remind you that information transmitted via the internet is not completely secure and although we will do our best to protect any information transmitted in this way, we cannot guarantee its complete security.
We have put in place appropriate security measures to prevent your personal data being accidentally lost, accessed or used in an unauthorised way, altered or disclosed. All information you provide to us is stored on our secure servers located in the European Economic Area. No information you provide to us is transferred to or stored at, a destination outside the EEA.
In addition, we limit access to your personal data to those partners, employees, agents, contractors and other third parties who have a business 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 any applicable regulator of a breach where we are legally required to do so.
Who do we share your personal information with?
How long do we keep your personal information?
We will keep your personal information for the following periods of time:
Information submitted via website form which does not lead to instructions to provide our services. Information kept for 12 months
Contact by any other means (e.g. email or telephone) which does not lead to instructions to provide our services Information kept for 12 months
When added to our marketing database Information kept for the duration of your consent (to be deleted upon consent being withdrawn)
In the course of providing our services Information usually kept for 7 years from the closure of the matter unless we inform you otherwise
Your rights in relation to the personal information we hold
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.
Object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
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. If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for marketing purposes.
We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:
- baseless or excessive/repeated requests,
- or further copies of the same information.
Alternatively, we may be entitled to refuse to act on the request.
Please consider your request responsibly before submitting it. We’ll respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we’ll come back to you and let you know.
How will we contact you?
We may contact you by phone, email or social media. If you prefer a particular contact means over another please just let us know.
- Email: email@example.com
- Post: 10a Browning Road, London E11 3AR
- Phone: +44 (0)7872 929101
You have the right to complain to the Information Commissioner about the way in which we collect and use your personal data: www.ico.org.uk/concerns or telephone 0303 123 1113.