PRIVACY POLICY​

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Website Privacy Policy - Website Enquiries & Subscriptions

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Who We Are

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Pamela Clemo & Co is the data controller for the purpose of the Data Protection Act 1998 as amended/superseded by the General Data Protection Regulation 2016. Our contact address is: 146 Coombe Lane West, Kingston-upon-Thames, Surrey KT2 7DE. We may be reached by email as follows: client@pamelaclemo.com

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Our Privacy Policy, described below, tells you what will happen to any personal data which you provide to us, or other third parties, as a result of using this website. This information is provided mainly for the benefit of visitors to the website. Existing or future clients of Pamela Clemo & Co are exposed to broader potential privacy-related issues than the ones mentioned here. Such matters are covered by a separate privacy notice issued at the time of official engagement. Details of these provisions are available and can be requested from us at the above address.

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Personal Data You Provide

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We take your privacy seriously. By providing personal information, including your name, address, telephone numbers and e-mail address via the forms on this website, you agree to our contacting you with regard to the information, submissions and requests which you may provide. In the event that we create mailing lists designed to inform clients and other parties of our on-going activities, your permission must be sought before your details can be added onto such lists. In the case of online submissions or interactions, you may be asked to click a check box thereby granting your permission for us to add your details to our mailing lists. You can only be added to our mailing lists as a result of your opting-in in the manner described. Should you wish to opt-out at any time, you may do so by contacting us via email. 

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Our Use of Your Personal Data

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We use the data which you provide through this website to:

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• communicate with you: for example, we will use the contact details which you provide to us, such as your email address or telephone number, in order to respond to your enquiries or requests submitted via our website. The same data may also be used to communicate with you if you are subscribed to any of our mailing lists. 

• monitor website trends: we use various third-party analytical services (including Google Analytics) to help us to monitor the usage of our website. These services provide us with a number tools through which we can analyse underlying user-data. This information may include such details as the user's geographical location, their IP address and the operating system and type of device used to access our site. Certain services may provide further analytical services relating to demographics, such information possibly being drawn from other data sources. Such analytical services provide us with detailed information relating to how our site has been used, including the time at which the website was accessed, the duration of the visit and the pages visited. The foregoing is not an exhaustive list of the analytical tools which may be available, all of which are subject to change. 

• improve the operation of our business and services: we may perform our own analysis of the data which you provide in order to determine whether we can improve our website or other methods of communication.

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Our Lawful Reasons and Purposes For Processing Your Personal Data

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The "General Data Protection Regulation" (GDPR) is the primary piece of legislation defining your rights in relation to our processing and general or specific usage of your personal information. GDPR requires us to declare which of six "lawful reasons" we are relying on when we are processing your personal data:

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By submitting an enquiry or request via this website, we are assuming that you do so in the expectation that you will receive a reply from us using the methods of communication which you provide to us. We will therefore use your personal data for the purposes of responding to your enquiry or request. We do this on the basis of Performance of a Contract whereby processing of your personal information is necessary in order to respond to your enquiry or request prior to entering into any further contract.

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Alternatively we may rely upon the creation and existence of a Legitimate Interest as a result of which we communicate with you to you based upon the information which you have provided to us. Such communication may be in response to general enquiries, requests, complaints or other such matters as they may attain to our business.

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By taking steps to subscribe to any newsletters, event invitations, or any other propositions or invitations issued by ourselves, we may process the personal data which you have provided to us in order to comply with these requests or to accommodate the provision of such services. 

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How Long We Keep Personal Data

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Personal data relating to enquiries or requests may be stored on our website for a period of up to 180 days. At the end of this period, the personal data so-gathered will be removed automatically. In the event that you subsequently become a client of Pamela Clemo & Co, you are referred to our Client Care letter which will provide details on the length of time that we usually keep your information once your file has closed. Please note that such provision may be subject to change over time; you may request such details by contacting us at the address notified above.

 

In the event that you have opted-in to receive periodic information from the Firm, your personal data will be kept until you advise us that you no longer wish to receive such information, updates or services.

 

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Confidentiality & Security

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We acknowledge that the information which you provide to us may be confidential.  We will maintain the confidentiality of your information and protect it in compliance with all applicable laws. We are committed to ensuring that all information we hold about you is secure.  In order to prevent unauthorised access or disclosure, the Firm adopts procedures to protect your data. These relate to physical, electronic and managerial procedures designed to safeguard and protect the information.

 

Please note that these measures cannot guarantee the complete integrity of your data and cannot, in and of themselves, remove the risk that unauthorised parties may, under certain circumstances, gain access to that information. Furthermore, data entered via our website may not be subject to secure electronic transmission; it is therefore possible that this information may be intercepted, in whole or in part, by unintended third-parties. 

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Transferring Your Personal Data

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Website Enquiries & Requests: data which you enter via our website will inevitably travel electronically via servers and infrastructures of third-parties, including various hosting services. We refer you to the general risks noted immediately above in that regard.

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In relation to the personal data received by us,  we will only transfer that data to others if the matter for which we are instructed to act requires us to do so. In some  circumstances we may ask for your explicit approval to transfer your information.

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Subscription to Newsletters or Events information. The Firm reserves the right to make use of third-party providers in order to fulfill such activities. These service providers may change from time to time. As a result, any subscription data which has been provided to us is likely to be stored on the servers used by the third-party employed at the time. In the event that this service provider operates in a jurisdiction other then the UK, your data would only be protected to a degree commensurate with the legal standards operating in that country.  

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Your Rights

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You have the right to request to see the personal data which we hold for you and to verify that it is being processed in accordance with legal requirements. Should you like a copy of the personal data that we hold for you please contact us using the contact details provided above.  Please note that, with any submission or request of this type, we would need to satisfy ourselves as to the identity of the person making the request before responding.  Normally we make no charge for providing this information, and would expect to provide you with the information requested within one calendar month of receipt of your request. Should you notice that, upon receipt, any of the information provided to you is inaccurate or incomplete, please let us know and we will rectify our records.

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Where you have consented to receive regular newsletters or updates regarding forthcoming events you have the right to withdraw your consent for us to hold and process your information. You can achieve this by opting-out of receiving any such information that you have been receiving from us. In the event that you receive newsletters or similar correspondence from us by email, you will have the option to unsubscribe from within each such email communication that you receive from us. You can also opt-out by either writing to us at our address above, or by sending an email to: client@pamelaclemo.com requesting that your name, and other personal information, be removed from the relevant subscriber list.

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Personal Data Concerning a Third Party

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You should only provide us with personal data relating to someone else with their express permission.  Where personal data about someone else is provided by you, or someone discloses to us personal data about you, it may be added to the personal data we already hold and may be used in the ways described in this Privacy Notice.

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Future Mergers of Changes in Business Structure

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Certain events may change the legal nature or ownership of the Firm. Should those events include alternative business combinations, we may disclose your personal data to a potential merger partner or take-over company, and/or their advisers, provided they agree to keep your data confidential and use it only in relation to consideration of the possible transaction.  In the event that the transaction goes ahead, the new combined business may use your personal data in the same way as is set out in this Privacy Notice. Alternatively, they may supply you with their own Privacy Notice should their terms be materially different from those disclosed herein.

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Use of Website Analytics

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Pamela Clemo & Co from time to time uses a number of website analytical tools, such as Google Analytics, to assess the performance of the company's website. These analytical services extract certain data relating to your use of our website. This information would likely include your IP (Internet Protocol) address, which may then provide information about your geographic location. The providers of website analytical tools enable the Firm to access a range of data relating to usage of our website. It is possible that these service providers may share this information with others. For example, in the case of Google Analytics, that company may make use of the data they collected in order to personalise advertisements promoted to you via its own network. Google, and other similar companies, may therefore combine data about you obtained by ourselves with other data from other sources in order to build a more complete profile of you and your online behaviour.

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Changes To Our Privacy Policy

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Changes made to our Privacy Policy in the future will be posted on this website and, where appropriate, users of our services will be notified by e-mail. 

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Questions or Complaints

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Please contact us directly should you have any questions or complaints (contact details are provided on this website). We will endeavour to reply to your enquiry or complaint on a timely basis. Should you be dissatisfied with our response, you have the right to complain to an appropriate supervisory authority. In the UK, the appropriate body is the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.  Their website can be accessed at https://ico.org.uk