1.1 We are committed to safeguarding the privacy of our website visitors and service users.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
1.5 In this policy, “we”, “us” and “our” refer to Lorraine Silver.
2. How we use your personal data
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
2.2 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is [our analytics tracking system]. This usage data may be processed for the purposes of analysing the use of the website and services.
2.3 We may process your account data (“account data“). The account data may include your name, email address and telephone number. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent.
2.6 We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent]
2.7 We may process information relating to our customer relationships, including customer contact information (“customer relationship data“). The customer relationship data may include your name, your contact details, telephone and information contained in communications between us and you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is consent.
2.10 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
2.11 We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users
2.13 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.14 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
2.15 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
2.16 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
The personal information we collect and use: Information Collected By Us
In the course of conducting business with you we collect some or all of the following personal information when you provide it to us:
- Contact information (such as name, postal or e-mail address, and phone number)
- Your professional information (such as job title, department and name of organization)
- Bank Account information
- Subscription details
- Payment account information
- Content you provide
- Details of other professional organisations acting on your behalf (such as accountants or solicitors)
- Title information obtained from the Land Register
- Information about your use of our websites
3. Providing your personal data to others
3.1 We may be required to share your data with third parties with the following categories of recipients:
- Contractors and other professional bodies from time to time engaged on behalf of our clients, including Solicitors if we need to invoke our debt collection process.
- IT service providers who collect and process personal data on our behalf (acting as Data Processors); including (but not limited to) Microsoft; Nasstar.
- third party ISO 9001 Audit supplier, and
- where relevant to an individual instruction or project, information may be shared with relevant third party consultants and suppliers.
4.International transfers of your personal data
4.1 The hosting facilities for our website are situated in Europe.
It is not intended that your information be transferred outside the European Economic Area (EEA), but if it is, mechanisms approved by the European Commission or the Information Commissioner’s Office (ICO) will be put in place prior to us processing your information. Where required we will also obtain your consent.
4.2 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
5. Retaining and deleting personal data
5.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.3 We will retain your personal data as follows:
(a) We will only keep your personal data:
- for as long as we need to in order to fulfil the purposes for which it was collected, and
- for as long as we are required to keep it by law
- for as long as we are required to keep it by our governing bodies
5.5 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
6.1 We may update this policy from time to time by publishing a new version on our website.
6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
6.3 We may notify you of significant changes to this policy by email or through the private messaging system on our website.
7. Your rights
7.1 In this Section 7, we have summarised the rights that you have under data protection law.
7.2 Your principal rights under data protection law are:
(a) the right to be informed;
(b) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object;
(f) the right to data portability;
(g) rights in relation to automated decision making and profiling
7.2.1 Right to Information: You have the right to clear and concise information about everything we do with your personal data. This encompasses the contents of this privacy notice.
7.2.2 Right to Access: You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
7.2.3 Right to Rectification: You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
7.2.4 Right to Erasure: In some circumstances, you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
7.2.5 Right to Restrict Processing: In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
7.2.6 Right To Object: You have the right to object to our processing of your personal data;
- on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
- for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
- for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
7.2.7 Right to Data Portability: To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
7.2.8 Rights in relation to automated decision making including profiling: We do not use any form of automated decision making in our business.
However, we can only carry out solely automated decision-making or profiling with legal or similarly significant effects if the decision is:
- necessary for entering into or performance of a contract between us and you;
- authorised by law; or
- based on your explicit consent.
You have the right to object, challenge and/or request a review of such decisions.
7.3 You also have the following rights;
7.3.1 Right to make a complaint to the Supervisory Authority: If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with the supervisory authority, the Information Commissioner’s Office (ICO) for the United Kingdom. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
7.3.2 Right to Withdraw Consent: To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
7.4 You may exercise any of your rights in relation to your personal data by written notice to us.
8. About Cookies
8.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
8.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
8.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
9. Cookies that we use
List of cookies used on the Lorraine Silver website
Google Analytics cookie; tracks the number of times you have visited the site
__utmb and __utmc
Google Analytics cookies; work together to calculate how long you have spent on the website in each session
Google Analytics cookie; tracks what search engine you have visited the site from and which search terms you used to find the website
Used to distinguish users
Used to distinguish users
Contains campaign related information for the user. If you have linked your Google Analytics and Google Ads accounts, Google Ads website conversion tags will read this cookie unless you opt-out.
10. Cookies used by our service providers
10.2 Google Analytics: This is an analytics service provided by Google, Inc. USA. Information generated by cookies about your use of our website will be transmitted to and stored by Google on servers in the United States.
Google will use your information;
- To evaluate your use of our website,
- Create reports on website activity for us and
- Provide other services relating to website activity and internet usage.
Google may also transfer your information to third parties;
- where required to do so by law, or
- where such third parties process the information on Google’s behalf.
11. Managing cookies
11.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
11.2 Blocking all cookies will have a negative impact upon the usability of many websites.
11.3 If you block cookies, you will not be able to use all the features on our website.
12. Contact details
12.1 This website is owned and operated by Lorraine Silver
12.2 You can contact us:
(a) by post to our head office address: –
PO Box 1151
(b) using our website contact form;
(c) by telephone, on the contact number published on our website from time to time; or
(d) by email, using the email address published on our website from time to time.
12.3 For all data protection matters please use the following email address:
13.1. Please contact us in the first instance to discuss any concerns.
13.2. If we do not resolve your query to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on;
- by phone – 0303 123 1113 or
- via email – https://ico.org.uk/global/contact-us/email/ or
- at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.