Privacy Policy

Note that you are required to be at least 18 years old to use our website and services, and we do not intentionally collect personal information from anyone under 18. No-one under 18 should attempt to submit any personal information to us.

We collect and use this personal data to provide legal consultancy services. If you do not provide personal data we ask for, it may delay or prevent us from providing those services.

We collect most of this information from you directly. However, we may also collect information:

• from publicly accessible sources, eg Companies House or HM Land Registry;
• directly from a third party, eg:
  • sanctions screening providers;
  • credit reference agencies;
  • client due diligence providers;
• from a third party with your consent, eg:
  • your bank or building society, another financial institution or advisor;
  • consultants and other professionals we may engage in relation to your matter
  • your employer and/or trade union, professional body or pension administrators; or
  • your doctors, medical and occupational health professionals.
• via our website—we use cookies on our website (for more information on cookies, please see our cookie policy
• via our information technology (IT) systems.

Under data protection law, we can only use personal data if we have a proper reason, eg:

• where you have given consent;
• to comply with our legal and regulatory obligations;
• for the performance of our contract with you or to take steps at your request before entering into a contract; or
• for our legitimate interests or those of a third party.

A legitimate interest is when we have a business or commercial reason to use personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.

The table below explains what we use your personal data for and why:

Where we process special category personal data, we will also ensure we are permitted to do so under data protection laws, eg:

• we have your explicit consent;
• the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent; or
• the processing is necessary to establish, exercise or defend legal claims—this includes using special category personal data, where necessary, for:
  • actual or prospective court proceedings;
  • obtaining legal advice; or
  • establishing, exercising or defending legal rights in any other way.

We may use your personal data to send you updates (by email, text message, telephone or post) about legal developments that might be of interest to you and/or information about our services, including exclusive offers, promotions or new services.

We have a legitimate interest in using your personal data for promotional purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you 5 marketing information. However, where consent is needed, we will ask for this consent separately and clearly.

You have the right to opt out of receiving marketing communications at any time by:

Who we share your personal data with

We routinely share personal data with:

• companies within The Solitaire Group
• professional advisers who we instruct on your behalf or refer you to, eg barristers, medical professionals, accountants, tax advisors or other experts;
• other third parties where necessary to carry out your instructions, eg your mortgage provider or HM Land Registry in the case of a property transaction or Companies House;
• credit reference agencies;
• our insurers and brokers;
• external auditors;
• our banks;
• external service suppliers, representatives and agents that we use to make our business more efficient, eg typing services, marketing agencies, document collation or analysis suppliers;

We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers relating to ensure they can only use your personal data to provide services to us and to you.

We may also need to:

• share personal data with external auditors, eg in relation to audit of our accounts;
• disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations;
• share some personal data with other parties, such as potential buyers of some or all of our business or during a restructuring—usually, information will be anonymised but this may not 6 always be possible, however, the recipient of the information will be bound by confidentiality obligations.

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

Personal data may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see ‘Who we share your personal data with’).

Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal data when this occurs, see below: ‘Transferring your personal data out of the UK and EEA’.

We will keep your personal data while we are providing services to you. Thereafter, we will keep your personal data for as long as is necessary:

• to respond to any questions, complaints or claims made by you or on your behalf;
• to show that we treated you fairly;
• to keep records required by law.

We will not keep your data for longer than necessary. Different retention periods apply for different types of data.

To deliver services to you, it is sometimes necessary for us to share your personal data outside the UK/EEA, eg:

• with your and our service providers located outside the UK/EEA;
• if you are based outside the UK/EEA;
• where there is a European and/or international dimension to the services we are providing to you.

Under data protection law, we can only transfer your personal data to a country or international organisation outside the UK/EEA where:

• the UK government or, where the EU GDPR applies, the European Commission has decided the particular country or international organisation ensures an adequate level of protection of personal data (known as an ‘adequacy decision’);
• there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or
• a specific exception applies under data protection law

These are explained below.

We may transfer your personal data to certain countries, on the basis of an adequacy decision. These include:

• all European Union countries, plus Iceland, Liechtenstein and Norway (collectively known as the ‘EEA’);
• Gibraltar; and
• Andorra, Argentina, Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Switzerland and Uruguay.

The list of countries that benefit from adequacy decisions will change from time to time. We will always seek to rely on an adequacy decision, where one exists.

Other countries we are likely to transfer personal data to do not have the benefit of an adequacy decision. This does not necessarily mean they provide poor protection for personal data, but we must look at alternative grounds for transferring the personal data, such as ensuring appropriate safeguards are in place or relying on an exception, as explained below.

Where there is no adequacy decision, we may transfer your personal data to another country if we are satisfied the transfer complies with data protection law, appropriate safeguards are in place, and enforceable rights and effective legal remedies are available for data subjects.

The safeguards will usually include using legally-approved standard data protection contract clauses.

To obtain a copy of the standard data protection contract clauses and further information about relevant safeguards, please contact us (see ‘How to contact us’ below).

In the absence of an adequacy decision or appropriate safeguards, we may transfer personal data to a third country or international organisation where an exception applies under data protection law, eg:

• you have explicitly consented to the proposed transfer after having been informed of the possible risks;
• the transfer is necessary for the performance of a contract between us or to take pre-contract measures at your request;
• the transfer is necessary for a contract in your interests, between us and another person; or
• the transfer is necessary to establish, exercise or defend legal claims.

We may also transfer information for the purpose of our compelling legitimate interests, so long as those interests are not overridden by your interests, rights and freedoms. Specific conditions apply to such transfers and we will provide relevant information if and when we seek to transfer your personal data on this ground.

If you would like further information about data transferred outside the UK/EEA, please contact us (see ‘How to contact us’ below).

Your rights

You have the following rights, which you can exercise free of charge:

For further information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below) or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please contact us (see ‘How to contact us’ below).

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How to complain

Please contact us if you have any query or concern about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the Information Commissioner. The Information Commissioner may be contacted at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.

Changes to this Privacy Policy

We may change this privacy policy from time to time, when we do we will inform you via our website.

How to contact us

Individuals in the UK

You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details are shown below: