Abercross Holdings Limited (“Abercross”) respects the privacy of the people we deal with and we uphold high standards of privacy, data protection practice and security. Whenever we handle personal information, we take steps to ensure that appropriate standards of data protection, privacy practice and security are applied.
This privacy notice applies to persons outside our organisation with whom we interact including but not limited to visitors to our website; clients and their personnel; vendors and service providers; visitors to our offices; and registrants for events held by Abercross.
This privacy notice sets out (i) what information we collect about you, (ii) who is collecting data, (iii) how we will use this information, (iv) how data is stored and who it could be shared with and (v) your rights and how to exercise them.
(i) What information we collect or generate about you
This website does not collect personal data about our users by any means unless you contact Abercross via the enquiry form which is included in the website, or if you contact us by phone, email or otherwise. We may collect your name, your email address, phone number and any other personal information which you decide to supply. Abercross records all telephone calls for monitoring purposes.
Information we may generate about you includes (by way of non-exhaustive list): (i) a file with your client records and contact history to be used for enquiry purposes so that we may ensure that you are satisfied with the services which we have provided to you; and (ii) details of site and marketing/communication preferences.
By supplying information to Abercross, you consent to the processing and use of personal data about you for the purposes of providing the services that you have requested.
When someone visits the Abercross website we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone.
(ii) Who is collecting data?
Data will be collected by Abercross with business address at 2 Eaton Gate, London. SW1W 9BJ.
(iii) How we will use this information
Any information you provide to us may be used for the following purposes: (a) to provide information on the products and services you have requested; (b) to notify you of new products and services that we offer, and think may be of interest to you; (c) for the management and administration of our business; (d) for IT analysis and website monitoring purposes (including cyber-security); (e) to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures; and/or (f) for the administration and maintenance of internal databases storing personal data.
If, in your enquiry, you ask for information about new products and services of ours and companies within our group we will ask for your consent prior to providing any such information. If you no longer wish to be contacted for marketing purposes you can opt out at any time by sending us an e-mail at this address email@example.com. Prior to providing you with any marketing material, we will assess your eligibility for the relevant product or service in accordance with our obligations under the laws governing financial promotion in the UK.
However we use your personal data we make sure that the usage complies with law and the law allows us and requires us to use personal data for a variety of reasons, including but not limited to the following: (a) in order to perform our contractual obligations; (b) where we have obtained your consent; (c) where we have legal and regulatory obligations that we have to discharge; (d) where we may need to do so in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings; (e) the use of your personal data as described is necessary for our legitimate business interests, such as: (i) allowing us to effectively and efficiently manage and administer the operation of our business; (ii) maintaining compliance with internal policies and procedures; (iii) monitoring the use of our copyrighted materials; (iv) for IT and security purposes.
(iv) How data is stored and with whom it may be shared
Data is recorded on paper and IT systems. Basic personal data, including name and contact details will be stored on our client relationship management system which is accessible to certain employees that have a need to access such data for the above-mentioned purposes. Data may be shared with the Abercross group of companies, including subsidiaries and affiliated companies, for the purposes set out above. We have extensive controls in place to maintain the security of our information and information systems including restricted access controls on IT systems.
Personal data may be shared outside of the Abercross group for the following purposes: (a) with our business partners. Personal data will only be transferred to a business partner who is contractually obliged to comply with appropriate data protection obligations and the relevant privacy and confidentiality legislation; (b) with third-party agents and contractors for the purposes of providing services to us (for example, our accountants, professional advisors, IT and communications providers). These third parties will be subject to appropriate data protection obligations and they will only use your data as described in this privacy notice; (c) with representatives, agents, custodians, intermediaries and/or other third party product providers appointed by the client; (d) to the extent required by law, for example if we are under a duty to disclose your personal data in order to comply with any legal obligation (including, without limitation, in order to comply with tax reporting requirements and disclosures to regulators), or to establish, exercise or defend its legal rights; (e) if we sell our business or assets, in which case we may need to disclose your personal data to the prospective buyer/buyer.
The personal data that we collect may be transferred to and stored at a destination outside the European Economic Area (EEA) in connection with the above purposes. This could be to other companies within Abercross or to service providers working on our behalf.
To comply with the requirements of the UK Data Protection laws and regulations in respect of personal data, we adhere to strict security procedures and have taken all appropriate measures to ensure that no unauthorised disclosures of your details are made to a third party without your permission and unauthorised access to it is prevented. Where any such processing takes place, appropriate controls, such as the adoption of agreements containing the appropriate legal protections, are in place to ensure that your information is protected to the same standard as if it were in the UK.
Data will be stored for such period of time as is necessary for the purposes for which we are using it, subject to laws or regulations which set a minimum period for which we have to keep your data.
(v) Your rights and how to exercise them
Under the UK Data Protection law, you have rights as an individual which you can exercise in relation to the information we hold about you. You can read more about these rights here – https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/
You have the right to determine how we use your data and to oppose to the purposes of processing at any time. You have the right to withdraw your consent at any time, without affecting the lawful processing of data based on consent up to the point of its withdrawal. Consent can be withdrawn at any time.
We remind you that you have the right to request from us access to and rectification or erasure of personal data, or a restriction of processing, or to object to processing of data concerning you.
You also have the right to receive your personal data that you provided to us in a structured, commonly used and machine-readable format and have the right to transmit such data to another controller without hindrance from us. In exercising your right to data portability, you have the right to have your personal data transmitted directly from a controller to another, where technically feasible.
You can contact us to exercise your rights by contacting us at firstname.lastname@example.org.
If you consider that the processing of your personal data infringes applicable data protection laws, as data subject you have the right, without prejudice to any other administrative or judicial remedy, to lodge a complaint with a supervisory authority, in particular, in the Member State of your habitual residence, place of work or place of the alleged infringement. The contact details for the UK Information Commissioner’s Office are set out below.
Information Commissioner's Office
(vi) Links to other websites
This privacy notice does not cover the links within this site linking to other websites, but not limited to, any links we may provide to social media websites. We encourage you to read the privacy statements on the other websites you visit.
(vii) Personal information must be accurate and complete
You must at all times ensure that the personal information you provide is accurate and complete. You will notify us of any changes to these as soon as you are able so that we can update our records. You are solely responsible for your personal information and we may take any action with respect to your personal information we deem necessary or appropriate if we believe it may cause us to suffer any loss, liability or commercial damage.
(viii) Online security
Whilst we will take all reasonable steps to protect your personal information, we cannot guarantee the security of any personal information you disclose online. You accept the inherent security implications of dealing on-line and will not hold us responsible for any breach of security unless such breach has been caused by the specific negligence of Abercross.
If you have any questions or complaints regarding privacy or information handling, please email us. The person responsible for data protection at Abercross is Issam Hamid who can be contacted via email at email@example.com. We will respond to let you know who will be handling your matter and when you can expect a further response.