Smallbutcool Ltd | Privacy Policy

This privacy policy explains what happens to any personal data that you provide, or that we collect from you on https://sbcwebsite.wpengine.com (“the site”).

smallbutcool.com is a registered trading name of Smallbutcool Ltd.

The site is owned and operated by Smallbutcool Ltd, a private company (number 9779502) that is limited by shares, and whose registered office is in England and Wales.

Smallbutcool Ltd will update this policy from time to time so please review this policy regularly.

Why do we need your personal information?

Your personal information helps Smallbutcool Ltd give you the best service possible. If you instruct Smallbutcool Ltd, we will need to store and use your personal data in order to carry out the service you have contracted us to do.

We will sometimes want to use your details to send you information which we feel you will be legitimately interested to receive – but you can opt out from these at any time you want by following the unsubscribe links in any email marketing, by changing your marketing preferences or by simply contacting Smallbutcool Ltd.

Here are some of the things we use your personal information for:-

• To provide you with the services you have instructed us to deliver
• Sending you compliance and regulatory updates that may affect you
• To send you billing information
• Getting to know you so we can send you information we know you would be interested in, based on how who you are and what services we offer
• To invite you to events we think you may be interested in.

Our full Privacy Policy below explains this in greater detail.

Our Privacy Policy

1. Purpose of this privacy notice

This notice describes how we collect and use personal data about you, in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act 1998 and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (‘Data Protection Legislation’).

Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

2. About Us

For the purpose of the Data Protection Legislation and this notice, Smallbutcool Ltd is both the ‘data controller’ and the ‘data processor’. This means that Smallbutcool Ltd is responsible for deciding how we hold and use personal data about you. We are required under the Data Protection Legislation to notify you of the information contained in this privacy notice.

We have appointed a privacy officer, Barry Day, who is responsible for assisting with enquiries in relation to this privacy notice or our treatment of your personal data. Should you wish to contact our Privacy Officer you can do so using the contact details noted at paragraph 16 (Contact Us), below.

3. Glossary of useful terms

What is personal data?

The meaning of ‘personal data’ refers to any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier. It may include (but is not limited to):

• Your name and your contact information
• National Insurance numbers
• Employment information
• Financial information such as credit history
• Specific data relevant to the service we provide you with, such as personal tax information or payroll and accounting data

What is sensitive personal data?

The GDPR refers to sensitive personal data as “special categories of personal data”. The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual.

What is a Data Controller?

A ‘data controller’ determines the purposes and means of processing personal data.

What is a Data Processor?

A “data processor” is a person or organisation which processes personal data for the controller.

What is Data Processing?

Data processing in relation to information or data means obtaining, recording or holding the information or data or carrying out any operation or set of operations on the information or data, including:

1. the organisation, adaptation or alteration of the information or data,
2. the retrieval, consultation or use of the information or data,
3. the disclosure of the information or data by transmission, dissemination or otherwise making available, or
4. the alignment, combination, blocking, erasure or destruction of the information or data.

4. How we may collect your personal data

We obtain personal data about you, for example, when:

• you request a proposal from us in respect of the services we provide;
• you engage us to provide our services and also during the provision of those services;
• you contact us by email, telephone, post (for example when you have a query about our services); or
• from third parties and/or publicly available resources (for example, from your employer or from Companies House).

5. The kind of information we hold about you

The information we hold about you may include the following:

• your personal details (such as your name and/or address);
• details of contact we have had with you in relation to the provision, or the proposed provision, of our services;
• details of any services you have received from us;
• our correspondence and communications with you;
• information about any complaints and enquiries you make to us;
• information we receive from other sources, such as publicly available information or information provided by your employer OR our clients.

6. How we use personal data we hold about you

We may process your personal data for purposes necessary for the performance of our engagement with you and to comply with our legal obligations.

We may process your personal data for the purposes necessary for the performance of our contract with our clients. This may include processing your personal data where you are an employee, subcontractor, supplier or customer of our client.

We may process your personal data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This includes processing for marketing, business development, statistical and management purposes.

We may process your personal data for certain additional purposes with your consent, and in these limited circumstances where your consent is required for the processing of your personal data then you have the right to withdraw your consent to processing for such specific purposes.

Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.

Situations in which we will use your personal data

We may use your personal data in order to:

• carry out our obligations arising from any agreements entered into between you and us (which will most usually be for the provision of our services);
• carry out our obligations arising from any agreements entered into between our clients and us (which will most usually be for the provision of our services) where you may be a subcontractor, supplier or customer of our client;
• provide you with information related to our services and our events and activities that you request from us or which we feel may interest you, provided you have consented to be contacted for such purposes;
• notify you about any changes to our services.

In some circumstances we may anonymise or pseudonymise the personal data so that it can no longer be associated with you, in which case we may use it without further notice to you.

If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered into with you. Alternatively, we may be unable to comply with our legal or regulatory obligations.

We may also process your personal data without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.

Data retention

We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected.

When assessing what retention period is appropriate for your personal data, we take into consideration:

• the requirements of our business and the services provided;
• any statutory or legal obligations;
• the purposes for which we originally collected the personal data;
• the lawful grounds on which we based our processing;
• the types of personal data we have collected;
• the amount and categories of your personal data; and
• whether the purpose of the processing could reasonably be fulfilled by other means.

Change of purpose

Where we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal data where that reason is compatible with the original purpose.

Should it be necessary to use your personal data for a new purpose, we will notify you and communicate the legal basis which allows us to do so before starting any new processing.

Disclosing your information

We will not disclose your personal information to any other party other than in accordance with this privacy policy and in the circumstances detailed below:-

• where we are legally required by law to disclose your personal information.
• To further fraud protection and reduce the risk of fraud.

7. How long we will hold your data for

We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected.

When assessing what retention period is appropriate for your personal data, we take into consideration:-

• The requirements of our business and the services provided;
• Any statutory or legal obligations;
• The purposes for which we originally collected the personal data;
• The lawful grounds on which we based our processing;
• The type of personal data we have collected;
• The amount and categories of your personal data; and
• Whether the purpose of the processing could reasonably be fulfilled by other means.

8. Data sharing

Why might you share my personal data with third parties?

We will share your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so.

Which third-party service providers process my personal data?

“Third parties” includes third-party service providers and other entities within our group OR the members of our firm’s network. The following activities are carried out by third-party service providers: IT and cloud services, professional advisory services, administration services, marketing services and banking services.

All of our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.

What about other third parties?

We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or to otherwise comply with the law.

9. Transferrin personal data outside the (EEA)

For the purposes of providing our services to you, we may transfer your personal data to other professional organisations outside the European Economic Area which do not have the same level of data protection as the UK. We will only do this when appropriate, for example when we work with foreign professionals on your behalf to provide you with certain services, or where we provide the data at your request. Where this is the case, we will ensure that your personal data is protected at all times.

10. Data security

We have put in place commercially reasonable and 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.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

11. Rights of access, correction, erasure, and restriction

Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us, using the contact details below.

Your rights in connection with personal data

Under certain circumstances, by law you have the right to:

• Request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully.
• Request correction of the personal data that we hold about you.
• 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 exercised your right to object to processing (see below).
• Object to 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 basis. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible.

If you want to exercise any of the above rights, please email our Privacy Officer at bada@smallbutcool.com

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 for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

12. Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose (for example, in relation to direct marketing that you have indicated you would like to receive from us), you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email our Privacy Officer at bada@smallbutcool.com.

Once we have received notification that you have withdrawn your consent, we will no longer process your personal information (personal data) for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

13. Other websites

On occasion we include links to third parties on this website. Where we provide a link it does not mean that we endorse or approve that site’s policy towards visitor privacy. You should review their privacy policy before sending them any personal data. This privacy policy only extends to Smallbutcool Ltd.

14. Our cookie policy and links

Click here to find out more.

15. Changes to our privacy policy

This current privacy policy is version 1 and has been updated in accordance with the latest GDPR guidance.

Our privacy policy may need to change from time to time, so we will continue to review this policy and will display any changes on our website.