Data Privacy Notice

We are Capital Business Links Limited with registered number 05444949 and address Craven House, 40-44 Uxbridge Road, London, W5 2BS. Our Data Protection Lead is Marta Klosinska and can be contacted at office@jdauman.com. We have produced this privacy notice in order to keep you informed of how we and our affiliates handle your personal data when you visit our website and when you become our client.

All handling of your personal data is done in compliance with the Data Protection Act 2018 and, if and when applicable, the General Data Protection Regulation (EU) 2016/679 (“Data Protection Legislation”). The terms “Personal Data”, “Special Categories of Personal Data”, “Personal Data Breach”, “Data Protection Officer” , “Data Controller”, “Data Processor”, “Data Subject” and “process” (in the context of usage of Personal Data) shall have the meanings given to them in the Data Protection Legislation. “Data Protection Lead” is the title given to the member of staff leading our data protection compliance program in lieu of a requirement for a Data Protection Officer.

What are your rights?

 

When reading this notice, it might be helpful to understand that your rights arising under Data Protection Legislation include:

  • The right to be informed of how your Personal Data is used (through this notice);
  • The right to access any personal data held about you;
  • The right to withdraw consent at any time, by opting-out using the options present in communications;
  • The right to rectify any inaccurate or incomplete personal data held about you;
  • The right to erasure where it cannot be justified that the information held satisfies any of the criteria outlined in this policy;
  • The right to prevent processing for direct marketing purposes, scientific/historical research or in any such way that is likely to cause substantial damage to you or another, including through profile building; and
  • The right to object to processing that results in decisions being made about you by automated processes and prevent those decisions being enacted.

You can gain access to your personal data by emailing at office@jdauman.com. with the subject line: “Subject Access Request”. When you submit a ‘subject access request’, you will need to provide confirmation of your identity. If you have used our website before for submitting an enquiry, but are not our client, please contact us using the email address that you have provided us with initially by sending your enquiry. If you are our client then please include your phone number for us to contact you to confirm your identity. This is provided free of charge and our response will be made within thirty (30) days unless our Data Protection Officer deems your request as being excessive or unfounded. If this is the case, we will inform you of our reasonable administration costs in advance and/or any associated delays, giving you the opportunity to choose whether you would like to pursue your request. If you believe we have made a mistake in evaluating your request, please see the section ‘Who can you complain to?’.

If you have questions about any of the rights mentioned in this section, please contact us at office@jdauman.com.

Who is the Data Controller?

 

Where we collect your personal data directly from you for our own purposes, we are the Data Controller.

If we have been passed your personal data from a third-party for a joint purpose that we both influence, we are a joint Data Controller. We will contact you to let you know about the acquisition (if we receive it indirectly) and who your point of contact is in relation to our processing before we first start to use your data, or, at the latest, within one month of acquiring it.

If your data has been passed to us by a third party for processing under their instruction, that third party is the Data Controller. They should have notified you that they would be passing your personal data to us at the time they collected your data and within their own privacy notices/standards. For a list of Data Controllers that we process personal data for, the section below ‘Third Party Interests’.

What are the lawful bases for processing personal data?

 

Under Data Protection Legislation, there must be a ‘lawful basis’ for the use of personal data. The lawful bases are:

  • ‘your consent’;
  • 'performance of a contract';
  • 'compliance with a legal obligation';
  • 'protection of your, or another’s vital interests';
  • ‘public interest/official authority’;
  • 'our legitimate interests'.

What are Capital Business Link Limited’s ‘legitimate interests’?

 

Legitimate interests are a flexible basis upon which the law permits the processing of an individual’s personal data. To determine whether we have a legitimate interest in processing your data, we balance the needs and benefits to us against the risks and benefits for you of us processing your data. This balancing is performed as objectively as possible by our Data Protection Officer. You are able to object to our processing and we shall consider the extent to which this affects whether we have a legitimate interest. If you would like to find out more about our legitimate interests, please contact office@jdauman.com.

About our processing of your data

 

When you use our website to submit an enquiry or when you become our client, we might collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:

Identity Data such as names; marital status; title; date of birth; sex and gender.

Contact Data such as addresses; email addresses and telephone numbers.

Financial Data such as bank account and payment card information.

Transaction Data such as information about payments and details of purchases you have made.

Technical Data such as IP addresses; browser info; time zone; location; browser plug-ins; operating systems; platforms and other technology on the device used to access this website.

Usage Data such as analytics relating to how you use the website.

Marketing and Communications Data such as your preferences about receiving communications from us or third parties.

Special Categories of Data such as details about race or ethnic origins, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic or biometric data.

Children

 

This Website is not directed toward children (as defined by local law), nor does Capital Business Links Limited knowingly collect information from children without parental consent except where in compliance with applicable law.

We may also collect, use and share Aggregated Data such as statistical or demographic data. Aggregated Data can be derived from your Personal Data but is not itself Personal Data as it cannot be used to reveal your identity. If Aggregated Data is ever used in combination with your Personal Data and becomes identifiable, it will be treated in accordance with this notice.

Reference What categories of information about you do we process? Why are we processing your data? Where did we get your personal data from?
Client Correspondence and Professional Services
  • Identity Data
  • Contact Data
  • Marketing and Communications Data
We use the personal data you have given us in order to communicate with you and provide our goods and services to you. This can also include processing data in relation to support. This processing is conducted lawfully on the basis of 'performance of a contract'. Obtained directly from you.
Direct Marketing
  • Identity Data
  • Contact Data
We use this personal data in order to market our products and services to you that we believe you will benefit from. This processing is conducted lawfully on the basis of 'our legitimate interests'. Obtained directly from you.
B2B Referrals
  • Identity Data
  • Contact Data
We use this personal data to refer you to customers who are interested in the services that you provide. This processing is conducted lawfully on the basis of 'our legitimate interests'. Obtained either directly from you, or from a mutual contact or a pubic source for business contacts.
Legal Obligations
  • Identity Data
  • Contact Data
To ensure we comply with any legal and statutory obligations that might arise. This processing is conducted lawfully on the basis of 'compliance with a legal obligation'. Directly obtained from you.
Enquiries
  • Identity Data
  • Contact Data
  • Any other unsolicited personal data that you choose to submit
We use the contact information sent to us through web forms, by phone or by email in order to respond to enquiries website users. This processing is conducted lawfully on the basis of 'our legitimate interests'. Directly obtained from you.
Internal Analytics
  • Identity Data
  • Contact Data
We use this personal data for internal analysis to provide a better service to you. This processing is conducted lawfully on the basis of 'our legitimate interests'. Directly obtained from you.

What happens if I refuse to give Capital Business Links Limited my personal data?

 

The information about you that we have collected for the performance of our contracts is required in order for us to successfully fulfil our obligations to you. If you choose not to provide the personal data requested, we will not be able to enter into a contract with you to provide the services we offer. If we are already processing your personal information under a contract, you must end our contractual relationship (as/where permitted) in order to exercise some of your rights. If we process some personal information as part of a contractual relationship with a Data Controller, then any requests to restrict this type of processing should be forwarded to the Data Controller; they will be responsible for discussing your concerns and making any decisions.

What profiling or automated decision making does Capital Business Links Limited perform?

 

Capital Business Links Limited does not perform any profiling or automated decision making based on your personal data.

How long will your personal data be kept?

 

Capital Business Links Limited holds different categories of personal data for different periods of time. Wherever possible, we will endeavour to minimise the amount of personal data that we hold and the length of time for which it is held.

  • If ‘consent’ is the basis for our lawful processing of your data, we will retain your data so long as both the purpose for which it was collected, and your consent, are still valid. Occasionally, we might identify a legitimate interest in retaining some of your personal data that has been obtained by consent. If we do, we will inform you that we intend to retain it under these conditions and identify the interest specifically.
  • If we process your data on the basis of ‘legitimate interests’, we will retain your data for as long as the purpose for which it is processed remains active.
  • All categories of personal data that are held by us because they are essential for the performance of a contract, will be held for a period of six years, or as otherwise required under applicable law, for the purposes of exercising or defending legal claims.

Who else will receive your personal data?

 

Capital Business Links Limited may pass your data to the third parties listed in the section ‘Third Party Interests’ below.

Does your data leave the EU?

 

Yes. Details are included in the section ‘Third Party Interests’ below.

Third Party Interests

Data Controllers

Name or Category of Third Party Controller What processing is being performed? If applicable - who is their representative within the EU?
HMRC, regulatory authorities or other authorities We are joint Controller with these authorities who require reporting of processing in some situations. N/A
Postal/Courier Provider Where these providers act as Data Controller, we are joint Controller with them for the purposes of sending you physical documents. N/A

Our Data Processors

Name or Category of Third Party Controller What processing is being performed? If applicable - who is their representative within the EU?
Internal technology providers
  • CRM software providers, whose services we use in order to manage our business with you.
  • Telephony providers.
  • Office software providers, such as email clients.
In the interests of providing a quality service, we may use providers located in the United States. These providers are bound by the contractual provisions of the EU Commissions model clauses.
Marketing technology providers Providers who enable us to send you our marketing emails. In the interests of providing a quality service, we may use providers located in the United States. These providers are bound by the contractual provisions of the EU Commissions model clauses.

Who can you complain to?

 

In addition to sending us your complaints directly to at office@jdauman.com you can send complaints to our supervisory authority. As Capital Business Links Limited predominantly handles the personal data of UK nationals, our supervisory authority is the Information Commissioner’s Office. If you believe that we have failed in our compliance with data protection legislation, complaints to this authority can be made by visiting

https://ico.org.uk/concerns/.

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