Privacy Policy

In this statement:

“Data Protection Laws” means:

• before 25 May 2018, the EU Data Protection Directive 95/46 and all national implementing laws (including the UK Data Protection Act 1998); and
• on or after 25 May 2018, the EU General Data Protection Regulation 2016/679; together with all other applicable legislation relating to privacy or data protection.
• On or after 1 January 2021 all data processing and collection of sensitive personal data falls under the detailed guidance of the UK’s GDPR which is defined and outlined within the provisions of Data Protection Act 2018. Prior to 31 December 2020 this fell under the rules laid out in the EU’s GDPR.

Notes:

In 2018, the UK Government took on the EU (Withdrawal) Act to prepare the country to leave the European Union. This Act incorporates several EU laws into UK domestic law. As part of this, the EU GDPR was fully incorporated. The European Court of Justice enforced it in the UK until 31 December 2020.

At the beginning of 2021, the UK legal system expelled the European Union GDPR and replaced it with the UK’s GDPR. Businesses in the UK and international organisations must understand both EU and UK GDPR differences to ensure compliance where applicable. For any business based in the UK that offers services or goods to people based in the EU, the EU’s GDPR applies.

Before 28 June 2021, the UK Government and the EU had not agreed the lawful basis upon which personal data can flow between them. UK is now a third country, (those countries outside the EU including UK), data transfers between the two must be covered by additional safeguards. Since 28 June 2021, the EU officially adopted an adequacy decision for the UK. This means that personal data from individuals in the EU and UK can continue to flow freely provided all the rules are followed. This decision is only for four years.

“LACE Partners” or“LACE” means LACE Partners Limited, a UK private company limited by guarantee.

“Process” means any operation performed on information about you, including to collect, record, organise, structure, store, alter, use, transfer, destroy or otherwise make available.

1. Who this privacy statement applies to and what it covers

This privacy statement applies to LACE Partners with registered office address at 30 Stamford Street, London, SE1 9LQ (“LACE”, “we”, “us” or “our”).
We are committed to protecting your privacy and handling your information openly and transparently.

This privacy statement explains how we will collect, handle, store and protect information about you when:

• Providing services to you or our clients;
• You use our Website; or
• Performing any other activities that form part of the operation of our business.

When we refer to “our Website” or “this Website”, we mean the specific webpages of www.lacepartners.co.uk.

This privacy statement also contains information about when we share your personal data with other members of the LACE network.

In this privacy statement, your information is sometimes called “personal data”. We may also refer to “processing” your data, which includes handling, collecting, protecting and storing it.

2. What personal data we collect

We may collect, record and use your personal data in physical and electronic form, and will hold, use and otherwise process that data in line with the Data Protection Laws and as set out in this statement.

When we provide services to you or our clients and perform due diligence checks in connection with our services (or discuss possible services we might provide), we will process personal data about you. We may also collect personal data from you when you use this Website.

We may process your data because:

• You give it to us (for example, in a form on our Website);
• Other people give it to us (for example, your employer or adviser, or third- party service providers that we use to help operate our business); or
• It is publicly available.

We may process personal data from you because we observe or infer that data about you from the way you interact with us or others. For example, to improve your experience of this Website and to make sure that it is working effectively. For example, we (or our service providers) may use cookies (small text files stored in a user’s browser) or Web beacons to collect personal data. More information on how we use these and other tracking technologies – and how you can control them – can be found in our cookie notice.

The personal data we process may include your:

• Name, gender, age and date of birth;
• Contact information, such as address, email, and mobile phone number;
• Country of residence;
• Lifestyle and social circumstances (for example, your hobbies);
• Family circumstances (for example, your marital status and dependents);
• Employment and education details (for example, the organisation you work for, your job title and your education details);
• Financial and tax-related information (for example your income, investments and tax residency);
• Postings or messages on any blogs, forums, platforms, wikis or social media applications and services that we provide (including with third parties);
• IP address, browser type and language, your access times;
• Information in any complaints you make;
• Details of how you use our products and services;
• CCTV footage and other information we collect when you access our premises; and
• Details of how you like to interact with us, and other similar information relevant to our relationship.

The personal data we collect may also include so called ‘sensitive’ or ‘special categories’ of personal data, such as details about your:

• Health (for example, so that we can make it easy for you to access our buildings, products and services); and
• Sexual orientation (for example, if you provide us with details of your spouse or partner).

We may also process personal data relating to ethnic or racial origin (for example, any multicultural networks you belong to), or about your political opinions (inferred from information you give us about political associations you belong to or have donated to).

We will do our best to seek separate permission from you in writing to process these special categories of personal data.

If you choose not to provide, or object to us processing, the information we collect (see section 9 below), we may not be able to process your instructions or continue to provide some or all of our services to you or our client.

3. Personal data provided by or about third parties

When our client or another third party gives us personal data about you, we make sure they have complied with the relevant privacy laws and regulations. This may include, for example, that the client or other third party has informed you of the processing, and has obtained any necessary permission for us to process that information as described in this privacy statement.

If any information you give us relates to a third party (such as a spouse, financial dependent, or joint account holder), by providing us with such personal data you confirm that, in line with the above provisions, you have obtained any necessary permission to use it or are otherwise permitted to give it to us.

We may obtain information from sources such as social media platforms (Facebook, LinkedIn, etc). An example of social media profile information we may collect could be information found on a LinkedIn profile, that is publicly available.

Our carefully selected partners and service providers may process personal information about you on our behalf as described below:

Digital Marketing Service Providers

We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information.  Our appointed data processors include:

(i)Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: http://sopro.io.  Sopro are registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at: dpo@sopro.io.

4. How we use your personal data

We process information about you and/or your business to enable us and other members of the LACE network to provide our services to you or our clients, and to meet our legal or regulatory obligations.

Some of your personal data may be used for other business purposes. Below are some examples.

Use of personal data to provide services to our clients

We will use your personal data to provide you or our clients or other third parties with services, and this includes using your personal data in correspondence relating to those services. That correspondence may be with:

• You;
• Other third parties;
• Our service providers; or
• Competent authorities.

Use of personal data for other activities that form part of the operation of our business

We may also use your personal data in connection with:

• Legal or regulatory requirements;
• Requests and communications from competent authorities;
• Client account opening and other administrative tasks;
• Financial accounting, invoicing and risk analysis;
• Relationship management, which may involve:

(a) Sending you thought leadership or details of our products and services;

(b) Contacting you for feedback on services;

(c) Sending you event invitations; and

(d) Other marketing or research purposes;

• Recruitment and business development, which may involve:

(a) The use of testimonials from a client’s employees as part of our recruitment and business development materials (with that employee’s permission); and

(b) The use of third-party data sources to help us verify and improve the information we hold about key business relationships with individuals;

• Services we receive from our professional advisors, such as lawyers, accountants and consultants;
• Investigating or preventing security incidents; or
• Protecting our rights and those of our clients.

Use of personal data collected via our Website

In addition to the above, we may also use your personal data collected via our Website:

• To manage and improve our Website;
• To tailor the content of our Website to give you a more personalised experience;
• To draw your attention to information about our products and services that may be of interest to you; or
• To manage and respond to any request you submit through our Website.

5. The legal grounds we use for processing personal data

We are required by law to set out in this privacy statement the legal grounds on which we rely in order to process your personal data. We rely on one or more of the following lawful grounds:

• You have explicitly agreed to us processing your information for a specific reason;
• The processing is necessary to perform the agreement we have with you or to take steps to enter into an agreement with you;
• The processing is necessary for compliance with a legal obligation we have such as keeping records for tax purposes or providing information to a public body or law enforcement agency; or
• The processing is necessary for the purposes of a legitimate interest pursued by us or a third party, which might be:

(a) To provide our services to you or our clients and other third parties and ensure that our client engagements are well-managed;

(b) To prevent fraud;

(c) To protect our business interests;

(d) To ensure that complaints are investigated;

(e) To evaluate, develop or improve our services or products; or

(f) To keep you or our clients informed about relevant products and services and provide you with information, unless you have indicated at any time that you do not wish us to do so.

To the extent that we process any special categories of data relating to you for any of the purposes outlined above, we will do so because:

• You have given us your explicit consent to process that data;
• We are required by law to process that data in order to ensure we meet our ‘know your client’ and ‘anti-money laundering’ obligations (or other legal obligations imposed on us);
• The processing is necessary to carry out our obligations under employment, social security or social protection law;
• The processing is necessary for the establishment, exercise or defence of legal claims; or
• You have made the data manifestly public.

Please note that in certain circumstances it may be still lawful for us to continue processing your information even where you have withdrawn your consent, if one of the other legal bases described above is applicable.

6. Sharing your personal data

In connection with any of the purposes outlined in the “4. How we use your personal data?” section above, we may disclose details about you to:

• Other members of the LACE network or third parties that provide services or online platforms to us and/or the LACE network;
• Competent authorities (including courts and authorities regulating us and other members of the LACE network);
• Your employer and/or its advisers, or your advisers;
• Anyone to whom we may transfer our rights and/or obligations under the Terms of Use;
• Any other person or organisation after a restructure, sale or acquisition of any member of the LACE network, as long as they use your information for the same purposes we did;
• Credit reference agencies or other organisations that help us make credit decisions and reduce the incidence of fraud; and
• Other third parties that reasonably require access to personal data relating to you.

Our Website hosts various blogs, forums, wikis and other social media applications or services that allow you to share content with other users (collectively “Social Media Applications”). Any personal data that you contribute to these Social Media Applications can be read, collected and used by other users of the application. We have little or no control over these other users, so any information you contribute to these Social Media Applications might not be handled in line with this privacy statement.

We use third parties to store our data including a Customer Relationship Management (CRM) system, as well as database for storing CV information. This database is regularly reviewed and updated in line with GDPR regulations to ensure that you are communicated on a regular basis and we obtain your consent to keep your data on file. This is recurring activity by LACE Partners to ensuring the integrity of your personal data, but also to ensure we communicate with you when we are holding your data.

7. Protecting your personal data

We use a range of measures to ensure we keep your personal data secure, accurate and up to date. These include:

• Education and training to relevant staff to ensure they are aware of our privacy obligations when handling personal data;
• Administrative and technical controls to restrict access to personal data to a ‘need to know’ basis;
• Technological security measures, including fire walls, encryption and anti- virus software; and
• Physical security measures, such as security passes to access our premises.

The transmission of data over the internet (including by e-mail) is never completely secure. So although we use appropriate measures to try to protect personal data, we cannot guarantee the security of data transmitted to us or by us.

8. How long we keep your personal data for

We seek to ensure that we only keep your personal data for the longest of:

• The period necessary for the relevant activity or services;
• Any retention period that is required by law; or
• The period in which litigation or investigations might arise in respect of the services.

9. Your rights

You have various rights in relation to your personal data. In particular, you have a right to:

• Obtain confirmation that we are processing your personal data and request a copy of the personal data we hold about you;
• Be informed about the processing of your personal data (i.e. for what purposes, what types, to what recipients it is disclosed, storage periods, any third party sources from where it was obtained, confirmation of whether we undertake automated decision-making, including profiling, and the logic, significance and envisaged consequences);
• Ask that we update the personal data we hold about you, or correct such personal data that you think is incorrect or incomplete;
• Ask that we delete personal data that we hold about you, or restrict the way in which we use such personal data; withdraw consent to our processing of your personal data (to the extent such processing is based on previously obtained consent);
• Receive a copy of the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and to transmit such personal data to another party (to the extent the processing is based on consent or a contract);
• Ask us to stop or start sending you marketing messages at any time by using the contact details in section 11 below; and
• Object to our processing of your personal data

If you would like to access or see a copy of your personal data, you must ask us in writing. We will endeavour to respond within a reasonable period, and in any event within one month in line with Data Protection Laws. We will comply with our legal obligations as regards your rights as a data subject.

To help us ensure that your information is up to date, let us know if any of your personal details change using the contact details set out in section 11.

You may also use the contact details in section 11 if you wish to make a complaint relating to your privacy.

10. Sending you marketing information

We may use your information from time to time to inform you by letter, telephone, email and other electronic methods about products and services (including those of third parties) that may be of interest to you.

You may, at any time, ask us not to send marketing information to you by following the unsubscribe instructions in communications from us, or contacting us in the way described in section 11 below.

11. Complaints procedure

If you wish to raise a complaint about how we are using your information, exercise any of the rights set out above, or if you have any questions or comments about privacy issues, you can contact us by:

• Writing to our Managing Director, LACE Partners, Unit 441 – Metal Box Factory, Great Guildford St, London SE1 0HS; or
• Sending an email to info@lacepartners.co.uk.

You can also complain to the Information Commissioner’s Office, which regulates and supervises the use of personal data in the UK (Ph number: 0303 123 1113).

If you are not based in the UK, you have a right to complain to the EU Data Protection Authority in your specific jurisdiction.

12. Changes to this privacy statement

We may modify or amend this privacy statement from time to time.

When we make changes to this privacy statement, we will amend the revision date at the bottom of this page. The modified or amended privacy statement will apply from that date. We encourage you to review this statement periodically to keep informed about how we are protecting your information.

Privacy Policy was last revised: 8th March 2023