Privacy notice

When reading this notice, it might be helpful to understand that your rights arising under Data Protection Legislation include:

• The right to be informed of how your Personal Data is used (through this notice);
• The right to access any personal data held about you;
• The right to withdraw consent at any time, by emailing will@williamslondon.co.uk;
• The right to rectify any inaccurate or incomplete personal data held about you;
• The right to erasure where it cannot be justified that the information held satisfies any of the criteria outlined in this policy, or where you have withdrawn consent;
• The right to prevent processing for direct marketing purposes, scientific/historical research or in any such way that is likely to cause substantial damage to you or another, including through profile building; and
• The right to object to processing that results in decisions being made about you by automated processes and prevent those decisions being enacted.

You can exercise your right to access personal data held about you by contacting will@williamslondon.co.uk with the subject line: "Subject Access Request". When you submit a 'subject access request', you will need to provide confirmation of your identity by including a photocopy of your driver's license or passport. This service is provided free of charge and our response will be made within thirty (30) days, unless our Data Protection Lead deems your request as being excessive or unfounded. If this is the case, we will inform you of our reasonable administration costs in advance and/or any associated delays, giving you the opportunity to choose whether you would like to pursue your request.

If you have questions about any of the rights mentioned in this section, please contact our Data Protection Lead at will@williamslondon.co.uk.

• If we have collected your personal data directly from you for our own purposes, we are the Data Controller.
• If we have purchased your personal data from a third-party for our own purposes, we are the Data Controller. Where we have purchased your personal data, we will contact you to let you know before we first start to use it, or, at the latest, within one month of acquiring it.
• If we have been passed your personal data from a third-party for our own purposes, we are the Data Controller. We will contact you to let you know before we first start to use it, or, at the latest, within one month of acquiring it.
• If we have been passed your personal data from a third-party for a joint purpose that we both influence, we are the joint Data Controller. We will contact you to let you know before we first start to use your data, or, at the latest, within one month of acquiring it.
• If your data has been passed to us by a third party for processing under their instruction, that third party is the Data Controller. They should have notified you that they would be passing your personal data to us, Williams London, at the time they collected your data and within their own privacy notices/standards.
• If we have received your personal data as part of a business-to-business relationship, the Data Controller is your employer.

Under Data Protection Legislation, there must be a 'lawful basis' for the use of personal data. The lawful bases are:

• your consent;
• performance of a contract;
• compliance with a legal obligation;
• protection of your, or another's, vital interests;
• public interest / official authority; and
• our legitimate interests.

Legitimate interests are a flexible basis upon which the law permits the processing of an individual's personal data. To determine whether we have a legitimate interest in processing your data, we balance the needs and benefits to us against the risks and benefits for you of us processing your data. This balancing is performed as objectively as possible by our Data Protection Lead. You are able to object to our processing and we shall consider the extent to which this affects whether we have a legitimate interest.

Personal data 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, grouped as follows:

• Identity Data, first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data, billing address, delivery address, email address and telephone numbers.
• Financial Data, bank account and payment card details.
• Transaction Data, details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data. IP address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform.
• Profile Data, your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data, information about how you use our website, products and services.
• Marketing and Communications Data, your preferences in receiving marketing from us and our third parties and your communication preferences.

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.

Cookies are small text files placed on your computer's hard drive through your web browser when you visit a website. They are widely used to make websites work, or work more efficiently, and to provide information to the owners of the site.

Cookies enable our web server to identify you to us, and to track your actions and the pages you visit. The cookies we use may last for a single visit, or may remain on your computer until you delete them or a defined period has passed. Although your browser software enables you to disable cookies, we recommend you allow their use in order to take full advantage of our site's features.

The information we have collected for the performance of our contracts is required in order for us to successfully fulfil our obligations to you. If you choose not to provide it, we will not be able to enter into a contract with you to provide the benefits we offer. If we are already processing your personal information under a contract, you must end our contractual relationship (as/where permitted) in order to exercise some of your rights.

Williams London holds different categories of personal data for different periods of time. Wherever possible, we will endeavour to minimise the amount of personal data we hold and the length of time for which it is held.

• If consent is the basis for our lawful processing, we retain your data so long as both the purpose and your consent remain valid. We review the status of your consent every twelve (12) months.
• Identity, Contact and Transaction Data are held indefinitely (subject to objection by the individual) in order to provide a superior service to returning clients.
• If we process your data on the basis of legitimate interests, we retain it for so long as the purpose remains active, reviewed every twelve (12) months.
• Personal data held because it is essential for the performance of a contract is retained for a period of six years, as determined by the Limitations Act 1980, for the purposes of exercising or defending legal claims.

Williams London does not perform any profiling or automated decision making based on your personal data.

Williams London uses overseas web and IT providers. We pass your data only to those third parties necessary for the provision of our services to you, and for no other purpose. Where applicable, we are joint Controller with HMRC and other regulatory authorities, and with postal/courier providers for the purposes of sending you physical documents.

In addition to sending complaints directly to will@williamslondon.co.uk, you can complain to our supervisory authority. As Williams London predominantly handles the personal data of UK nationals, our supervisory authority is the Information Commissioner's Office. Complaints can be made by visiting ico.org.uk.