Last Updated: September 2022
Privacy policy
1. Introduction
1.1. We are committed to safeguarding the privacy of our Risk Sherpa 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.
1.3. We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our Risk Sherpa website and services, we will ask you to consent to our use of cookies when you first visit our website.
1.4. In this policy, "we", "us" and "our" refer to Trubshaw Cumberlege Ltd. For more information about us, see Section 13.
2. Credit
2.1. This document was created using a template from SEQ Legal (https://seqlegal.com).
3. How we use your personal data
3.1. In this Section 3 we have set out:
3.1.1.the general categories of personal data that we may process;
3.1.2.the purposes for which we may process personal data; and
3.1.3.the legal bases of the processing.
3.2. 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 Risk Sherpa service. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
3.3. 3.3 We may process your account data ("account data"). The account data may include your name and email address. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business in particular to be able to contact you related to the performance of our obligations to you when providing the agreed services.
3.4. We may process your personal data that are provided in the course of the use of our services ("service data"). The service data may include your name, phone number and e-mail address. The source of the service data is you or your employer. The service 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 the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
3.5. 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 employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is 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 our legitimate interests, namely the proper management of our customer relationships.
3.6. We may process information relating to transactions, including purchases of services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests.
3.7. 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.
3.8. 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.
3.9. 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.
3.10. Please do not supply any other person's personal data to us, unless we prompt you to do so.
4. Providing your personal data to others
4.1. We may disclose your email address and/or username to our suppliers or subcontractors in so far as reasonably necessary for providing our contractual services to you and your company. You may obtain the names of our suppliers and contractors by sending an e-mail request to info@trubshaw.co
4.2. Financial transactions relating to our website and services if payment is done by credit card may be handled by our payment services provider. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
4.3. In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure 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. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5. International transfers of your personal data
5.1. In this Section 5, we provide information about the circumstances in which your personal data may be transferred to and from countries outside the European Economic Area (EEA) and United Kingdom (UK).
5.2. Transfers to each of these countries is protected by appropriate safeguards, namely appropriate confidentiality and contractual agreements between us and our subsidiaries and subcontractors. You mean obtain copies of these by contacting us.
6. Retaining and deleting personal data
6.1. 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.
6.2. 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.
6.3. We will determine the period of retention based on the following criteria:
6.3.1.the period of retention of your contact information will be determined based on you being a client or a potential client of our company.
6.4. 6.2 Notwithstanding the other provisions of this Section 6, 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.
7. Amendments
7.1. We may update this policy from time to time by publishing a new version on our website.
7.2. You should check this page occasionally to ensure you are happy with any changes to this policy.
7.3. We may notify you of changes to this policy by email or through the notification system on our website.
8. Your rights
8.1. In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
8.2. Your principal rights under data protection law are:
8.2.1.the right to access - you can ask for copies of your personal data;
8.2.2.the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
8.2.3.the right to erasure - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
8.2.4.the right to restrict processing - you can ask us to restrict the processing of your personal data;
8.2.5.the right to object to processing - you can object to the processing of your personal data;
8.2.6.the right to data portability - you can ask that we transfer your personal data to another organisation or to you;
8.2.7.the right to complain to a supervisory authority - you can complain about our processing of your personal data; and
8.2.8.the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
8.3. You may exercise any of your rights in relation to your personal data by written notice to us sent via e-mail.
9. About cookies
9.1. 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.
9.2. 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.
9.3. 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.
10. Cookies that we use
10.1. We use cookies for the following purposes:
10.1.1. authentication - we use cookies to identify you when you visit our website and as you navigate our website (cookies used for this purpose are organization identifier);
10.1.2. status - we use cookies to help us to determine if you are logged into our website (cookies used for this purpose are internal user id and session identifier);
10.1.3. personalisation - we use cookies to store information about your preferences and to personalise the website for you (cookies used for this purpose are: form, location, user identifiers);
10.1.4. security - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally (cookies used for this purpose are: internal session identifier);
10.1.5. analysis - we use cookies to help us to analyse the use and performance of our website and services (cookies used for this purpose are: google analytics)
11. Cookies used by our service providers
11.1. Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
11.2. We use Hotjar to analyse the use of our website, which gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Hotjar's privacy policy is available at: https://www.hotjar.com/legal/policies/privacy-v52/
12. Managing cookies
12.1. 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:
12.1.1. https://support.google.com/chrome/answer/95647?hl=en (Chrome);
12.1.2. https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
12.1.3. http://www.opera.com/help/tutorials/security/cookies/ (Opera);
12.1.4. https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
12.1.5. https://support.apple.com/kb/PH21411 (Safari); and
12.1.6. https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
12.2. Blocking all cookies will have a negative impact upon the usability of many websites.
12.3. If you block cookies, you will not be able to use all the features on our website.
13. Our details
13.1. This website is owned and operated by Trubshaw Cumberlege Ltd.
13.2. Trubshaw Cumberlege, Ltd is a company registered in England. Registered number: 9281086. Registered office: 29 Blackwood Close, West Byfleet, KT14 6PP
13.3. You can contact us:
13.3.1. by post, to the postal address given above;
13.3.2. using our website contact form;
13.3.3. by email, using the email address info@trubshaw.co
14. Data protection officer
14.1. 14.1 Our data protection officer can be reached via info@trubshaw.co