New Leaf Advisory Limited – Website Privacy Notice
Introduction
New Leaf Advisory Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, www.newleafadvisory.co.uk (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
Please read this Privacy Notice carefully and ensure that you understand it. Your acceptance of this Privacy Notice is requested when accessing our site and when using our online form on the “Contacts” page of our website, or our email addresses, to contact us .
1. Definitions and Interpretation
1.1 In this Notice, unless the context otherwise requires, the following terms have the following meanings:
“Account” means an account required to access and/or use certain areas and features of Our Site;
“Cookie” means a small file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site;
“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 and, where applicable, the UK GDPR;
2. Information About Us
2.1 Our Site is owned and operated by New Leaf Advisory, a limited company registered in England under Company Number 9694850, whose registered address is St Mary’s House, Netherhampton, Salisbury, England, SP2 8PU.
2.2 Our VAT number is 218494587.
2.3 Our Data Protection Agency Registration Number is ZA131283
2.4 Our representative is: Marcus Rickard
2.5 Our contact email is: contact@newleafadvisory.co.uk
3. What Does This Notice Cover?
This Privacy Notice applies only to your use of Our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
4. What Is Personal Data?
Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified, in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
5. What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
a) The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.
b) The right to access the personal data we hold about you. Part 13 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we Please contact us using the details in Part 15 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to ususing your personal data for a particular purpose or purposes.
g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
h) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
i) Rights relating to automated decision-making and profiling.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 15.
6. What Data Do You Collect and How?
Depending upon your use of Our Site, we may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. Please also see Part 14 for more information about our use of Cookies and similar technologies and our Cookie Policy. We do not collect any ‘special category’ or ‘sensitive’ personal data or personal data relating to children.
| Data Collected | How We Collect the Data |
|---|---|
| Identity information including name, title, date of birth | This information is collected only if sent to us, for example if an individual were to send us an email, using the contact email on Our Site, containing their personal identity details |
| Contact information including address, email address, telephone number | This information is collected only if sent to us, for example if an individual were to send us an email, using the contact email on Our Site, containing their personal contact details |
| Business information including business name, job title, contact name and contact address/email/telephone numbers | This information is collected only if sent to us, for example if business or individual representing a business were to send us an email, using the contact email on Our Site, containing their personal contact details |
| Profile information including Cookie choices | Please see section 14 for more information about our use of Cookies |
| Other information | We do not collect other information via Our Site, unless sent to us in using our contact details on Our Site, and not solicited by us |
7. How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our bases for doing so:
| What We Do | What Data We Use | Our Lawful Basis |
|---|---|---|
| Providing and managing your access to Our Site | Cookies | We have a legitimate interest in using necessary Cookies for the functioning of our website and for registering user Cookie preferences.
Where optional tracking Cookies are consented to, we rely on user consent to allow Google Analytics Cookies (https://support.google.com/analytics/answer/6004245 for Google’s overview of privacy and data safeguarding). |
| Responding to correspondence we receive using the contact details on our website | Contact details that you have provided to us in order to respond to your enquiry | We have a legitimate interest in responding to enquiries made to our business. |
We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time, unless you provided that consent at the time of sharing your data with us in the first place.
Third Parties (including Google Analytics) whose content appears on Our Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so but we would only do so if we have a legitimate interest in using data to delivery our professional services.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
8. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
| Type of Data | How Long We Keep It |
|---|---|
| Identity Information | No longer than is reasonable for the purposes that we have been provided with this information, and not longer than six months without reviewing permission to keep such data. |
| Contact information | No longer than is reasonable for the purposes that we have been provided with this information, and not longer than six months without reviewing permission to keep such data. |
| Business Information | As long as is reasonable for business continuity, and subject to periodic reviews of no longer than six months. |
| Profile Information | As long as is reasonable for business purposes within scope of the consent given, and subject to periodic reviews of no longer than six months. |
| Other Information | No longer than is reasonable for the purposes that we have been provided with this information, and not longer than six months without reviewing permission to keep such data. |
9. How and Where Do You Store or Transfer My Personal Data?
We will store some of your personal data in the UK. This means that it will be fully protected under the Data Protection Legislation.
AND
We will store some of your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the EU GDPR and/or to equivalent standards by law. Transfers of personal data to the EEA from the UK are permitted without additional safeguards.
AND
We may store some or all of your personal data in countries outside of the UK. These are known as “third countries”. We will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:
We ensure that your personal data is protected under binding corporate rules. Binding corporate rules are a set of common rules which all our group companies are required to follow when processing personal data. For further information, please refer to the Information Commissioner’s Office.
OR
We will only store or transfer personal data in or to countries that are deemed to provide an adequate level of protection for personal data. For further information about adequacy decisions and adequacy regulations, please refer to the Information Commissioner’s Office.
OR
We will use specific approved contracts which ensure the same levels of personal data protection that apply under the Data Protection Legislation. For further information, please refer to the Information Commissioner’s Office.
Please contact us using the details below in Part 15 for further information about the particular data protection safeguard(s) used by us when transferring your personal data to a third country.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
-
- limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
- procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so.
10. Do You Share My Personal Data?
Save where we have obtained express consent so to do, we will not share any of your personal data with any third parties for any purposes, subject to the following exception[s].
If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Notice.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
11. How Can I Control My Personal Data
In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data.
12. Can I Withhold Information?
You may restrict our use of Cookies. For more information, see Part 14 and our Cookie Policy.
13. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
14. How Do You Use Cookies?
Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by usand are used only by us or by Google Analytics. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve our products and services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.
By using Our Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies may be used on Our Site for tracking purposes. For more details, please refer to the table below. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
All Cookies used by and on Our Site are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended. You will be given the opportunity to allow only first-party Cookies and block third-party Cookies.
Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
The following first-party Cookies may be placed on your computer or device:
| Name of Cookie | Purpose & Type | Strictly Necessary |
|---|---|---|
| privacy_embeds | This functional cookie stores your cookie user preferences. Expiration period: 30 days | yes |
| _ga | A Google Analytics cookie used to distinguish users. Default expiration period: 2 years. | no |
| _gat | A Google Analytics cookie used to throttle request rate. Default expiration period: 1 minute. | no |
| _gid | A Google Analytics cookie used to distinguish users. Expiration period: 1 day. | no |
The following third party Cookies may be placed on your computer or device:
| Name of Cookie | Purpose & Type | Provider | Strictly Necessary |
|---|---|---|---|
| None at present |
Our Site uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to improve Our Site and the products and services offered through it. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.
The analytics service used by Our Site uses analytics Cookies to gather the required information.
The analytics service used by Our Site uses the following analytics Cookies:
| Name of Cookie | Purpose & Type | Provider | Strictly Necessary |
|---|---|---|---|
| _ga | A Google Analytics cookie used to distinguish users. Default expiration period: 2 years. | Google Analytics | no |
| _gat | A Google Analytics cookie used to throttle request rate. Default expiration period: 1 minute. | Google Analytics | no |
| _gid | A Google Analytics cookie used to distinguish users. Expiration period: 1 day. | Google Analytics | no |
In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
The links below provide instructions on how to control Cookies in all mainstream browsers:
-
- Google Chrome: https://support.google.com/chrome/answer/95647?hl=en-GB
- Microsoft Internet Explorer: https://support.microsoft.com/en-us/kb/278835
- Microsoft Edge: https://support.microsoft.com/en-gb/products/microsoft-edge (Please note that there are no specific instructions at this time, but Microsoft support will be able to assist)
- Safari (macOS): https://support.apple.com/kb/PH21411?viewlocale=en_GB&locale=en_GB
- Safari (iOS): https://support.apple.com/en-gb/HT201265
- Mozilla Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-Cookies-website-preferences
- Android: https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DAndroid&hl=en (Please refer to your device’s documentation for manufacturers’ own browsers)
To opt out of being tracked by Google Analytics across all websites, visit: http://tools.google.com/dlpage/gaoptout
15. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Marcus Rickard):
Email address: contact@newleafadvisory.co.uk.
Postal Address: St Mary’s House, Netherhampton, Salisbury, England, SP2 8PU
16. Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change ourbusiness in a way that affects personal data protection.
Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Notice on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date. This Privacy Notice was last updated on 12th March, 2022.