Full Circle Partners Ltd is committed to preserving the privacy of our clients and website visitors, and complying with our obligations under the relevant data protection legal framework including the General Data Protection Regulation (“GDPR”).
Please read the following policy which explains how we use and protect the information that you provide. The policy also outlines your rights under GDPR.
For the purposes of GDPR, Full Circle Partners is the data controller of the personal data which it collects and processes.
Data That Full Circle Partners Collects From You
Full Circle Partners collects data about you:
- when you request services or otherwise provide us with your personal details (such as your name, contact details, e-mail address etc); and
- from your usage of the website and any other information you post on the website, e-mail or otherwise send to us; and
- in addition, we may collect personal data about you from background check providers, which may include anti-money laundering services, and from third party publicly accessible sources such as Companies House records.
Full Circle Partners has considered the lawful bases that it relies on to process your personal data. These are:
- Clients and visitors to the website – processing of information is necessary for the performance of a contract with the data subject or to take steps to enter into a contract.
- Personal data relating to transactions carried out – processing is necessary for compliance with legal obligations (VAT, Tax, etc.).
- Legitimate interests – Full Circle Partners may process data for its legitimate interests. We will use people’s data in ways they would reasonably expect, and which have a minimal privacy impact or where there is a compelling justification for their processing.
- Consent – Full Circle Partners may process data where an individual has consented to the processing.
You may be able to subscribe on the website to receive information from us. If you do then you can unsubscribe at any time by clicking on the “click here to unsubscribe” link provided in our emails or by contacting us direct.
Use Of Data
We use the data that you provide:
- to supply you with the products, services and information which you have requested;
- to inform you about our services and about events such as seminars and conferences and to send you briefings and similar material;
- to assess client satisfaction (e.g. where you agree to participate in a survey); and
- to help improve our services generally.
We may contact you by post, telephone or fax as well as by e-mail. If you change your mind about being contacted in the future by any of these means then please let us know.
All information you provide to us is stored on secure servers with industry standard anti-virus and firewall protection in place.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted online or through the website. Any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Disclosure Of Data
Full Circle Partners will only retain your personal data for as long as necessary to fulfil the purposes we collected it for. There are various retention periods for different aspects of the personal data that we hold, which are set out in our Data Retention Policy.
Under GDPR you have the right to the following:
- The right of access. Known as a “data subject access request”, you may access your personal data. A request must be submitted in writing, either by post or in email format. Full Circle Partners will provide a copy of the information free of charge; this will be provided as soon as reasonably possible and at latest within one month of receipt of request. Where a request is manifestly unfounded or excessive – eg if it is repetitive – a reasonable fee will be charged to cover administrative expenses, or Full Circle Partners may at its discretion refuse to respond to the request. Where we refuse to respond we will write to the data subject explaining why and informing them of their right to complain to the supervisory authority within one month of receipt. Before providing any information about personal data, Full Circle Partners will use reasonable means to verify the identity of the person making the request.
- The right to rectification. You are entitled to have personal data rectified if it is inaccurate or incomplete.
- Deletion or removal of personal data. You have a right to have personal data erased and to prevent processing in specific circumstances. Where we receive a request for erasure, Full Circle Partners will limit further processing except where the request falls under one of the grounds for refusal. These are:
- to exercise the right of freedom of expression and information;
- to comply with a legal obligation;
- for public health purposes in the public interest;
- archiving purposes in the public interest;
- the exercise or defence of legal claims.
- The right to restrict processing. You may request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- The right to data portability. You may request the transfer of your personal information to another party.
- The right to object. You have the right to object to direct marketing (including profiling). When an individual communicates an objection to processing for direct marketing, Full Circle Partners will stop processing their personal data for direct marketing purposes as soon as the objection is received. For the avoidance of doubt, the personal data may still be stored for the purposes of fulfilling legal obligations in relation to document retention.
- Rights relating to automated decision making and profiling. Where personal data is processed for profiling purposes, Full Circle Partners will ensure appropriate safeguards are in place by conducting a data protection impact assessment (DPIA) on the relevant activity.
In the UK, the supervisory authority for data protection issues is the Information Commissioner’s Office (ICO). If you have any issues, complaints or require further information you may contact the ICO at any time.
If you have any queries concerning your data or this policy then please contact email@example.com or write to us at: Full Circle Partners Limited, 16 Charlotte Square, Edinburgh EH2 4DF.