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LEYTON UK LTD PRIVACY NOTICE

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Welcome to LEYTON UK LTD’S privacy notice.

LEYTON UK LTD respects your privacy and is committed to protecting your personal data. This notice explains how we look after your personal data when you visit our website (regardless of where you visit it from) and sign service agreements with us. This notice also tells you about your privacy rights and how the law protects you.

This notice is provided in a layered format so that you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how LEYTON UK LTD collects and processes your personal data through your use of this website, including any data you may provide through this website when you make an enquiry into the services that we offer or about a position at the company. This website is not intended for children and we do not knowingly collect data relating to children. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements other notices and privacy notices and is not intended to override them.

CONTROLLER

LEYTON UK LTD is part of a group of entities which, together, are owned by THÉSÉE S.A.S and referred to as the “Leyton Group”. This privacy notice is issued on behalf of LEYTON UK LTD. When we mention "Company", "we", "us" or "our" in this privacy notice, we are referring to LEYTON UK LTD only. LEYTON UK LTD is the controller and is responsible for this website. We have appointed a Data Privacy Manager who is responsible for overseeing questions in relation to this particular privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Data Privacy Manager using the details set out below.

CONTACT DETAILS

If you have any questions about this privacy notice or our privacy practices, please contact our Data Privacy Manager in the following ways:

Full name of legal entity: LEYTON UK LTD
Email address: dpm@leyton.com
Postal address: Harmsworth House, 1st Floor, 13-15 Bouverie Street, London EC4Y 8DP
Telephone number: 020 7043 2300

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy notice under regular review. This version was last updated in December 2019. Historic versions can be obtained by contacting us. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes; first name, last name, role within a company, title, date of birth and gender;
  • Contact Data includes; billing address, email address and telephone numbers;
  • Financial Data includes; bank account and payment card details;
  • Transaction Data includes; details about payments to and from you and other details of products and services you have purchased from us;
  • Technical Data includes; internet protocol (IP) address, browser type and version, location, type of device (PC or smart device) browser plug-in types and versions, on the devices you use to access this website;
  • Profile Data includes; feedback and survey responses;
  • Usage Data includes; information about how you use our website, record online forms.

We also collect, use and share Aggregated Data such as statistical or demographic data to allow us to recognise users and requests. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice. This Aggregated Data is retained for 13 months.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

We use different methods to collect data from and about you including through:

  1. Direct interactions. You give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

    • give us feedback or contact us; or
    • complete a survey.

  2. Indirect interactions from Third Parties or publicly available sources. We collect your Identity and Contact Data from publicly available sources such as Companies House, Deudil, LinkedIn. We may also collect your identity and contact data from businesses we partner with for marketing and event sponsorship purposes.

  3. Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using google analytics and other similar technologies. We also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

We will only use your personal data when the law allows us to. We will use your personal data in the following circumstances:

  1. Where we need to perform the contract we are about to enter into or have entered into with you.
  2. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  3. Where we need to comply with a legal obligation.

Click on the Glossary section to find out more about the types of lawful basis that we will rely on to process your personal data. Generally, we do not rely on consent as a legal basis for processing your personal data. You have the right to withdraw consent to marketing at any time by contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We need to process personal data relating to our customers, our suppliers, the employees of our customers and potential customers in order to function effectively as a business, perform contracts and services, to ensure good governance, for audit purposes and to enable us to meet our legal obligations.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/ Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer

  1. Identity
  2. Contract

Performance of a contract with you

To process and deliver our services including: manage payments, fees and charges, collect and recover money owed to us

  1. Identity (including employees’ professional experience and qualifications)
  2. Contact
  3. Financial (including payroll details and remuneration figures)
  4. Transaction
  5. Contracts and invoices that a customer has with third parties

  1. Performance of a contract with you
  2. Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include; notifying you about changes to our terms or privacy notice, and asking you to leave a review or take a survey

  1. Identity
  2. Contact
  3. Profile

  1. Performance of a contract with you
  2. Necessary to comply with a legal obligation
  3. Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/ services)

To manage our relationships with our suppliers

  1. Contact
  2. Financial
  3. Technical

  1. Administering our business
  2. Performance of contract with suppliers

To use data analytics to improve our website, products/ services, marketing, customer relationships and experiences

  1. Technical
  2. Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy

To make suggestions and recommendations to you about goods or services that may be of interest to you

  1. Identity
  2. Contact
  3. Technical
  4. Usage
  5. Profile

Necessary for our legitimate interests (to develop our products/ services) and for the legitimate interests of businesses within the Leyton Group.

MARKETING

LEYTON UK LTD prospects for new clients through direct marketing and we rely on the legitimate interest lawful basis to allow us to do so. In this regard, calls are recorded for training and monitoring purposes and are deleted after 3 months. We will not call those numbers listed on TPS or CTPS.

COOKIES

We use Cookies and similar technologies to help improve the performance of our website. For example, to ensure that our website remembers you based on your last visit, present tailored options to you, to measure web traffic and track user journeys. You can set your browser to reject Cookies or you can turn Cookies off, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookies policy.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We may share your personal data with the parties set out below for the purposes set out in the table under the heading “PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA”.

  • Internal Third Parties: We share personal data globally, within the Leyton Group (acting as processors or controllers) for referral and cross-selling opportunities, performance management purposes; to improve our products and services, and for the purpose of receiving IT and server administration support. Specifically, we share your personal data with our associate business, Lexleyton (the trading name for Leyton UK Partners LLP and Leyton Legal (Scotland) LLP) and rely on their legitimate interest to allow us to do so. Lexleyton offers employment law and human resources support services. We have identified that customers of LEYTON UK LTD may often benefit from the services offered by our associated business and for this reason, we share your personal data so that you can benefit from the services offered.
  • External Third Parties: If you sign a service contract with us then we will share your personal data with Her Majesty’s Revenue Services in order to perform in terms of the contract. Your personal data will also be stored on our customer relationship management programmes. We may also disclose your identity and contact data with businesses we partner with for marketing and event sponsorship purposes so that we can perform in terms of our contract with them. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We share your personal data within the Leyton Group. This will involve transferring your data outside the European Economic Area (EEA).

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by using specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. We may also retain your personal data for a longer period for the purpose of creating a knowledge base in order to improve the quality of our services and client experience.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research and statistical purposes, in which case we may use this information indefinitely without further notice to you.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

  • Request access to your personal data: this enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of your personal data: this enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal data: this enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing.
  • Object to processing of your personal data: objection to processing of your personal information can occur where we are relying on a legitimate interest (or those of a third party) and it transpires that the legitimate interest infringes unfairly on your rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes;
  • Request restriction of processing your personal data 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.
  • Request transfer of your personal data.
  • Right to withdraw consent in certain circumstances.

If you wish to exercise any of the rights set out above, please contact the DPM at dpm@leyton.com.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us. Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

Other companies in the Leyton Group acting as controllers or processors and who are based in the EU and outside of the EU.

External Third Parties

  • Service providers, such as Salesforce, acting as processors who provide Software as a Service.
  • HM Revenue & Customs, regulators and other authorities acting as processors based in the United Kingdom who require reporting of processing activities in certain circumstances.
  • Businesses we partner with for marketing and event sponsorship purposes.

YOUR LEGAL RIGHTS

You have the right to:

  • Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
    • If you want us to establish the data's accuracy;
    • Where our use of the data is unlawful but you do not want us to erase it;
    • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims;
    • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.