James Brown Management Limited (“we”, “us” or “our”) are committed to protecting and respecting your (“you” or “your”) privacy.
This policy (together with our Website Terms and Conditions, our Cookies Policy and any other documents referred to in any of these documents) sets out the basis on which any Personal Data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your Personal Data and how we will treat it.
In this policy the following words will have the following meanings:
Data Protection Laws means any applicable laws relating to the processing, privacy, and use of Personal Data, including the General Data Protection Regulation (EU) 2016/679 (the GDPR), the Privacy and Electronic Communications (EC Directive) Regulations 2003 (as amended), and all equivalent and corresponding national legislation, applicable laws and regulations relating to the processing of Personal Data and privacy, including where applicable the guidance and codes of practice issued by the Information Commissioner’s Office;
James Brown Management Limited means the company registered in England and Wales with registered number 02516014 and whose registered office address is at 25 City Road, Cambridge, CB1 1DP;
Personal Data means any information relating to an identified or identifiable natural person (a Data Subject); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person and where referred to in this policy includes the special categories of Personal Data as set out in Article 9 of the GDPR;
Special Categories of Personal Data means Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership; genetic data or biometric data which uniquely identifies a natural person; data concerning a natural person’s health, and data concerning a natural person’s sex life or sexual orientation; and
Website means our website at https://www.jamesbrownmanagement.com/.
- Important information and who we are
- 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.
- INFORMATION WE COLLECT FROM YOU
- We will collect and process the following Personal Data about you:
- Information you give us. This is information about you that you provide to us by corresponding with us by telephone, e-mail or otherwise. The information you give us may include your name, address, e-mail address and telephone number, financial and credit card information. It may also include Special Categories of Personal Data.
- Information we collect about you. With regard to each of your visits to our Website we will automatically collect the following information:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
- information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), pages you viewed or items searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any telephone number used to contact us.
- Information we receive from other sources. This is information we receive about you when working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers and credit reference agencies).
- 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 our services). In this case, we may have to cancel a service you have requested from us or your involvement in a project which we are managing or proposing to manage, but we will notify you if this is the case at the time.
- USES MADE OF THE INFORMATION
- We will only use your Personal Data to the extent that the law allows us to do so. Under the GDPR we require a lawful basis to process your Personal Data. Most commonly we will use your Personal Data in the following circumstances:
- where we need to perform the contract we are about to enter into, or have entered into, with you;
- where you have consented to us processing your Personal Data for one or more specific purposes;
- where it is necessary for the purposes of our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and
- where we need to comply with a legal or regulatory obligation.
- We use information held about you in the following ways:
- for the processing of an enquiry made by you concerning our services;
- to process a request for further details of our services in response to you having expressed an interest in our services;
- providing your information to our marketing team who may contact you by post, telephone or email to request feedback and comments on our services or to provide information to you which may be of interest to you (you will always be given an opportunity to opt-out of receiving communications from our marketing team);
- providing your information to our agents and service providers for the purposes set out in this policy; and
- if applicable, to process your application for engagement or employment and, if you agree to this, we shall then retain a copy of your CV in case of suitable future opportunities.
- INFORMATION YOU GIVE TO US
- We will use this information:
- to register you as a client of our business (if you are a new or ongoing client) or to keep your details on our system for a reasonable time if you have approached us with a view to potentially becoming a client of our business;
- to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information and services that you request from us;
- if you are a client of our business, to manage your affairs (to the extent that you have asked us to do so) and/or to manage projects in which you are involved as our client. This could include making payments on your behalf using your financial and credit card information, and collecting and recovering fees owed to us;
- if you are not a client of our business but are someone who is involved in a project which we are managing on behalf of someone who is a client of our business, to help us manage that project as effectively and efficiently as possible;
- to provide you with information about other services we offer that are similar to those that we already provide to you or about which you have enquired (you will always be given an opportunity to opt-out of receiving such information);
- to provide you with information about services we feel may interest you (you will always be given an opportunity to opt-out of receiving such information). If you are an existing client, we will only contact you by electronic means (e-mail or text message) with information about services similar to those which were the subject of a previous contract with you. If you are a new client we will contact you by electronic means only if you have consented to this and if you do not want us to use your Personal Data you will be able to withdraw your consent by contacting us using the contact details contained in paragraph 16 below; and
- to ensure that content from our Website is presented in the most effective manner for you and for your computer.
- We will only process Special Categories of Personal Data if and to the extent that you have given your explicit consent to such processing and only to the extent that we need to do so to manage your affairs and/or to manage projects in which you are involved as our client or with someone who is our client. Please note that Article 9 of the GDPR does allow processing of Special Categories of Personal Data in the absence of explicit consent in limited circumstances, and we will always ensure that our processing of Special Categories of Personal Data complies with Article 9 of the GDPR.
- Please note that if you are a former client of our business, we may need to continue to process your Personal Data for a period after you have ceased to be our client if and to the extent that it is necessary for us to do so to service your ongoing engagements and/or project management commitments arranged through us.
- 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 using the contact details contained in paragraph 16
- 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.
- INFORMATION WE COLLECT ABOUT YOU.
We will use this information:
- to administer our Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our Website to ensure that content is presented in the most effective manner for you and for your computer;
- as part of our efforts to keep our Website safe and secure;
- to measure or understand the effectiveness of advertising we make available to you and others, and to deliver relevant advertising to you; and/or
- to make suggestions and recommendations to you and other users of our Website about services that may interest you or them.
- INFORMATION WE RECEIVE FROM OTHER SOURCES.
We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
- Disclosure of your information
- You agree that we have the right to share your Personal Data with:
- selected third parties including: business partners, promoters, suppliers, sub-contractors and consultants for the performance of any contract we enter into with them or you;
- our professional advisers including our lawyers, bankers, accountants, auditors and insurers who provide consultancy, banking, legal, insurance and/or accounting services to us;
- if you are a client or former client of our business, whoever you inform us from time to time is acting as your accountant or financial adviser;
- HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances;
- analytics and search engine providers that assist us in the improvement and optimisation of our Website; and
- credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
- We will disclose Personal Data to third parties:
- in the event that we sell or buy any business or assets, in which case we will disclose your Personal Data to the prospective seller or buyer of such business or assets;
- if substantially all of our assets are acquired by a third party, in which case Personal Data held by it about our clients will be one of the transferred assets; and
- if we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions and other agreements; or to protect the rights, property, or safety of James Brown Management Limited, our clients, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
- 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 documented instructions.
- Where we store your Personal Data
- All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted.
- 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 Personal Data transmitted to us; 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.
- Data security
- 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 documented instructions and they are subject to a duty of confidentiality.
- We have put in place procedures to deal with any suspected ‘personal data breach’ (as defined in the GDPR) and will notify you and any applicable regulator of a breach where we are legally required to do so.
- RETENTION OF PERSONAL DATA
- We will only retain your Personal Data for as long as necessary to fulfil the purposes for which we collected your Personal Data.
- 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 that 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 requirements.
- Further details of the period or periods for which we will retain your Personal Data are set out in our data retention policy, a copy of which is available on written request.
- Your rights
- Under certain circumstances, by law you have the right to:
- Request access to your Personal Data (commonly known as a ‘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 information we hold about you corrected.
- 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 in certain other circumstances.
- 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.
- Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your Personal Data to another party.
- If you want to review, verify, correct or request erasure of your Personal Data, object to the processing of your Personal Data, or request that we transfer a copy of your Personal Data to another person, please contact us using the details provided in paragraph 16
- 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 may refuse to comply with your request in these circumstances.
- 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.
- We try to respond to all legitimate requests within one month. Occasionally it may 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.
- Right to Lodge a Complaint with Information Commissioner’s Office
If you have any complaints about the way in which we process your Personal Data please do contact us using the details provided in paragraph 16 below. Alternatively 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.
This policy was last updated in June 2020.