1.1. We want you to know that when you use our organisation you can trust us with your information. We are determined to do nothing that would infringe your rights or undermine your trust. This Privacy Notice describes the information we collect about you, how it is used and shared, and your rights regarding it.
1.2. We are registered with the Information Commissioner’s Office (ICO) as a Data Controller for the personal data that we hold and process. Our registration number is Z3654951. Our registered address is Keenan CF, 10th Floor, Victoria House, 15-27 Gloucester Street, Belfast, BT1 4LS. Our Data Protection Officer (DPO) is Mr Tom Keenan. Our Data Protection Officer can be contacted at firstname.lastname@example.org .
1.3. 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.
Your duty to inform us of changes
1.4. 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.
1.5. This 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 statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
1.6. The vast majority of the information that we hold about you is provided to us by yourself when you seek to use our services. We will tell you why we need the information and how we will use it.
1.7. 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).
1.8. When you contact us in relation to the provision of services by us to you we will collect personal information such as your name, address, email address, telephone number. Additional types of information may be required before we provide services to you (for example information on your passport and your driving licence) to enable us to comply with our regulatory requirements. Personal data may also be collected from public sources such as Companies House.
1.9. When you become a client of the Keenan Corporate Finance Limited we may, with your consent, add your personal data to our marketing database so that we can send you information in relation to upcoming events, send you updates and other useful information. You can opt out at any time and chose not to receive such communications by emailing email@example.com.
1.10. If you are not a client we may send you email marketing communications. You can opt out at any time and chose not to receive such communications by emailing firstname.lastname@example.org.
If you fail to provide personal data
1.11. Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
How we use your personal data
1.12. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to comply with a legal or regulatory obligation.
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where you have given your consent to us using your information for the purposes outlined in this Privacy Notice
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
1.13. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
1.14. You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Disclosures of your personal data
1.15. We will not disclose any information you provide to any third parties other than:
- Where you have given your consent for us to share this information
- Where we are under a legal or regulatory duty to disclose or share your personal data.
- Where it is necessary to carry out your instructions.
- Where we instruct professional advisors on your behalf.
- Where it is necessary to enforce the terms and conditions or agreements between us.
- Where there is a sale of some or all of our business and assets to a third party or where there is a restructuring of our business.
1.16. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
1.17. We do not transfer the personal data you give us to countries outside the EEA, except where the international transfer is necessary in connection with the services we are providing to you.
1.18. Where we transfer your personal data outside the EEA and the country in question is not recognised by the European Commission to have adequate data protection laws, we will provide appropriate safeguards and we will be responsible for ensuring your privacy rights are protected as outlined in this notice.
1.19. 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. In addition, we limit access to your personal data to those 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.
1.20. 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.
1.21. We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
1.22. 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 whether we can achieve those purposes through other means, and the applicable legal requirements.
1.23. Details of retention periods for different aspects of your personal data are available in our Retention Policy which you can request from us by contacting us at email@example.com.
Your legal rights
1.24. Under certain circumstances, you have rights under data protection laws in relation to your personal data to:
- Request access to your personal data. This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of your personal data which is incorrect, incomplete or inaccurate.
- Request erasure of your personal data where there is no good reason for us continuing to hold it.
- Object to processing of your personal data to further our legitimate interests or where we are using your information for direct marketing purposes.
- Request restriction of processing your personal data.
- Request transfer of your personal data to another person or organisation.
- Withdraw consent at any time if you have given your consent to us processing your personal data.
1.25. If you wish to exercise any of the rights set out above, please contact us. If you wish to make a subject access request 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.
1.26. You can find out more information from the ICO’s website http://ico.org.uk/for_the_public/personal_information and this is the organisation that you can complain to if you are unhappy with how we deal with you.