CAPSTONE GROUP WEB SITE PRIVACY POLICY
We respect your privacy and are committed to protecting your personal data.
This privacy policy will give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you contact us.
It is important that you read this privacy notice so that you are fully aware of how and why we are using your data, your privacy rights and how the law protects you.
Who We Are
We are Capstone Group Ltd of Arden House, 6 Arden Road, London, N3 3AN.
We act as a data controller, which means that we are responsible for deciding how we hold and use personal information about you.
We have appointed data privacy managers who are responsible for overseeing questions in relation to this privacy policy. If you have any questions, including any requests to exercise your legal rights, please contact either of them using the details set out below.
Names: Ben Harshak and James Winston
Email addresses: bdh@capstonegrp.co.uk orjsw@capstonegrp.co.uk
Postal address: Arden House, 6 Arden Road, London, N3 3AN
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- includes title, first name, last name and date of birth.
- includes email address, postal address and telephone numbers.
- includes bank account details.
- includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- includes details about payments to you.
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.
How is your personal data collected?
We use different methods to collect data from and about you including through:
- . You may give us your Identity, Contact and Financial Data by filling in forms on our website or by corresponding with us by phone, email or otherwise.
- As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
- We may receive Identity and Contact Data from publicly available sources such as Companies House, Land Registry and the websites for local councils.
Third-party links
We only use your personal data when the law allows us to. Most commonly, we will process the personal information about you that we collect, store and use for the following purposes:
We use cookies to:
ensure that any information entered is remembered;
We will only use your personal information 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 we need to use your personal information 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
If you fail to provide personal data
Your Rights
By law 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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact Ben Harshak or James Winston in writing.
Sharing and Disclosing Your Personal Information
We will not share or disclose your personal information without your consent, other than for the purposes specified in this Privacy Policy or where the law requires us to do so.
We sometimes need to share your personal information, for the purposes specified in this Privacy Policy, with third parties such as IT and system administration services.
Where this is necessary, all processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this privacy policy, the data protection laws and any other appropriate confidentiality and security measures.
As a result of us disclosing your personal information to any of the parties mentioned above, your personal information may be held by us and additionally by the parties mentioned above.
Safeguarding Measures
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have also put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
How long will you use my personal data for?
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 requirements.
We only process your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws.
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 if unsatisfied with how we have handled your information.
Changes to this Privacy Policy
We reserve the right to update this Privacy Policy at anytime, and we will provide you with a new Privacy Policy when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
If you have any queries or comments about our privacy practices, please contact our data privacy managers at bdh@capstonegrp.co.uk or jsw@capstonegrp.co.uk.
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