We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities if you have a complaint.
This privacy policy does not apply to any third party websites that may have links to our own website.
Clients of this firm should read this policy alongside our general terms and conditions, which provide further information on confidentiality.
Who are we and what do we do?
Seven Deadly Sins Limited is registered in England and Wales. Company Number 09843162. Registered Office: 2 Cattedown Road, Plymouth PL4 0EG
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR).
Key terms
It would be helpful to start by explaining some key terms used in this policy:
We, us, our | Seven Deadly Sins Limited | |
Personal data | Any information relating to an identified or identifiable individual | |
Special category personal data | Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership Genetic data Biometric data (where used for identification purposes) Data concerning health, sex life or sexual orientation |
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Data subject | The individual who the personal data relates to |
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Personal data we collect about you
The table below sets out the personal data we will or may collect in the course of providing services to you.
Personal data we will collect | Personal data we may collect depending on why you have instructed us |
Your name, address and telephone number Information to enable us to check and verify your identity, eg your date of birth or passport details Electronic contact details, eg your email address and mobile phone number Information relating to the matter in which you are seeking our advice or representation Information to enable us to undertake a credit or other financial checks on you Your financial details so far as relevant to your instructions, eg the source of your funds if you are instructing on a purchase transaction Information about your use of our IT, communication and other systems, and other monitoring information, eg if using our secure online client portal | Your National Insurance and tax details Your bank and/or building society details Details of your professional online presence, eg LinkedIn profile
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We collect and use this personal data to provide services to you. If you do not provide personal data we ask for, it may delay or prevent us from providing those services.
How your personal data is collected
We collect most of the above information from you. However, we may also collect information:
- from publicly accessible sources, eg Companies House or HM Land Registry;
- directly from a third party, eg:
- sanctions screening providers;
- credit reference agencies;
- client due diligence providers;
- from a third party with your consent, eg:
- your bank or building society, another financial institution or advisor;
- your employer and/or trade union, professional body or pension administrators;
- your doctors, medical and occupational health professionals;
- via our website—we use cookies and similar technologies on our website (for more information on cookies, please see our [insert link] cookie policy)
- via our information technology (IT) systems, eg:
- via our case management, document management and time recording systems;
How and why we use personal data
Under data protection law, we can only use your personal data if we have a proper reason, eg:
- you have given consent—where we need your consent, we will ask for it separately of this privacy policy and you can withdraw consent at any time;
- to comply with our legal and regulatory obligations;
- to fulfil our contract with you or take steps at your request before entering into a contract; or
- for our legitimate interests or those of a third party.
A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.
The table below explains what we use your personal data for and why.
What we use your personal data for | Our reasons | |
Providing services to you | To fulfil our contract with you or to take steps at your request before entering into a contract | |
Preventing and detecting fraud against you or us | For our legitimate interest, ie to minimise fraud that could be damaging for you and/or us | |
Conducting checks to identify our clients and verify their identity Screening for financial and other sanctions or embargoes Other activities necessary to comply with professional, legal and regulatory obligations that apply to our business, eg under health and safety law or rules issued by our professional regulator | Depending on the circumstances: —to comply with our legal and regulatory obligations —for our legitimate interests | |
To enforce legal rights or defend or undertake legal proceedings | Depending on the circumstances: —to comply with our legal and regulatory obligations —for our legitimate interests, ie to protect our business, interests and rights | |
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies | To comply with our legal and regulatory obligations | |
Ensuring internal business policies are complied with, eg policies covering security and internet use | For our legitimate interests, ie to make sure we are following our own internal procedures so we can deliver the best service to you | |
Operational reasons, such as improving efficiency, training and quality control | For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price | |
Ensuring the confidentiality of commercially sensitive information | Depending on the circumstances: —for our legitimate interests, ie to protect trade secrets and other commercially valuable information —to comply with our legal and regulatory obligations | |
Statistical analysis to help us manage our business, eg in relation to our financial performance, client base, services range or other efficiency measures | For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price | |
Protecting the security of systems and data used to provide services, preventing unauthorised access and changes to our systems | Depending on the circumstances: —for our legitimate interests, ie to prevent and detect criminal activity that could be damaging for you and/or us —to comply with our legal and regulatory obligations | |
Updating and enhancing client records | Depending on the circumstances: —to fulfil our contract with you or to take steps at your request before entering into a contract —to comply with our legal and regulatory obligations —for our legitimate interests, eg making sure we can keep in touch with our clients about existing and new services | |
Statutory returns | To comply with our legal and regulatory obligations | |
Ensuring safe working practices, staff administration and assessments | Depending on the circumstances: —to comply with our legal and regulatory obligations —for our legitimate interests, eg to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you | |
Marketing our services | Depending on the circumstances: —for our legitimate interests, ie to promote our business —consent | |
Credit reference checks via external credit reference agencies | For our legitimate interests, ie to ensure our clients are likely to be able to pay for our services | |
External audits and quality checks, | Depending on the circumstances: —for our legitimate interests, ie to maintain our accreditations so we can demonstrate we operate at the highest standards —to comply with our legal and regulatory obligations |
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To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale or in the event of our insolvency In such cases information will be anonymised where possible and only shared where necessary | Depending on the circumstances: —to comply with our legal and regulatory obligations —in other cases, for our legitimate interests, ie to protect, realise or grow the value in our business and assets |
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Where we process special category personal data (see above ‘Key terms’), we will also ensure we are permitted to do so under data protection laws
- we have your explicit consent;
- the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent
- the processing is necessary to establish, exercise or defend legal claims; or
- the processing is necessary for reasons of substantial public interest.
Marketing
We may use your personal data to send you updates (eg by email, text message, telephone, post or social media channels) about our services, including exclusive offers, promotions or new services.
We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. Where this is not the case, we will always ask for your consent.
In all cases, you have the right to opt out of receiving marketing communications at any time by:
- contacting us at spencerglazsher@sdsdrinks.com
- using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts; or
We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
Who we share your personal data with
We routinely share personal data with:
- third parties we use to help deliver our services to you, eg providers of our case management and finance system, IT service providers including cloud service providers such as data storage platforms, shared service centres and financial institutions in connection with invoicing and payments
- third party external advisors or experts engaged in the course of providing services to you, eg experts
- companies providing services for money laundering checks and other crime prevention purposes and companies providing similar services, including financial institutions and credit reference agencies
- other third parties we use to help promote our business, eg marketing agencies;
- third parties approved by you, eg social media sites you choose to link your account to or third party payment providers;
- our insurers and brokers;
- our bank
We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.
We or the third parties mentioned above occasionally also share personal data with:
- our external auditors, eg in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations
- our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations
- law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations
- including a merger, acquisition or asset sale or in the event of our insolvency—usually, information will be anonymised but this may not always be possible and the recipient of any of your personal data will be bound by confidentiality obligations]
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
Where your personal data is held
Personal data may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see ‘Who we share your personal data with’).
Some of these third parties may be based outside the UK. For more information, including on how we safeguard your personal data when this occurs, see below: ‘Transferring your personal data abroad’.
How long your personal data will be kept
We will not keep your personal data for longer than we need it for the purpose for which it was collected or as required by law.
Following the end of the of the relevant retention period, we will delete or anonymise your personal data.
Transferring your personal data abroad
It is sometimes necessary for us to transfer your personal data to countries outside the UK and EEA. This may include countries which do not provide the same level of protection of personal data as the UK.
We will transfer your personal data outside the UK only where:
- the UK government or European Commission has decided the recipient country ensures an adequate level of protection of personal data (known as an adequacy decision); or
- there are appropriate safeguards in place (eg standard contractual data protection clauses published or approved by the relevant data protection regulator), together with enforceable rights and effective legal remedies for you; or
- a specific exception applies under data protection law.
You can contact us (see ‘How to contact us’ below) if you would like a list of countries benefiting from a UK or European adequacy decision or for any other information about protection of personal data when it is transferred abroad.
Your rights
You have the following rights, which you can exercise free of charge:
Access | The right to be provided with a copy of your personal data | |
Rectification | The right to require us to correct any mistakes in your personal data | |
Erasure (also known as the right to be forgotten) | The right to require us to delete your personal data—in certain situations | |
Restriction of processing | The right to require us to restrict processing of your personal data—in certain situations, eg if you contest the accuracy of the data | |
Data portability | The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations | |
To object | The right to object: —at any time to your personal data being processed for direct marketing (including profiling); —in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims. | |
Not to be subject to automated individual decision making | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you |
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The right to withdraw consent | If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time You may withdraw consents by emailing us at spencerglazsher@sdsdrinks.com Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn |
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If you would like to exercise any of those rights, please:
- email, call or write to us—see below: ‘How to contact us’; and
- provide enough information to identify yourself and any additional identity information we may reasonably request from you;
- let us know what right you want to exercise and the information to which your request relates.
Keeping your personal data secure
We have implemented appropriate technical and organisational measures to keep your personal data confidential and secure from unauthorised access, use and disclosure. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.
We require our business partners, suppliers and other third parties to implement appropriate security measures to protect personal data from unauthorised access, use and disclosure.
We also have procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are required to do so.
How to complain
Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You may also have the right to lodge a complaint with the Information Commissioner (the UK data protection regulator) Please contact us if you would like further information.
Changes to this privacy policy
This privacy policy was published on 28 August 2023 and replaces previous policies.
We may change this privacy policy from time to time. When we do we will publish the updated version on our website and ask for your consent to the changes if legally required.
Updating your personal data
We take reasonable steps to ensure your personal data remains accurate and up to date. To help us with this, please let us know if any of the personal data you have provided to us has changed, eg your surname or address—see below ‘How to contact us’
How to contact us
Individuals in the UK
You can contact us and/or our Data Protection Officer by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:
Our contact details | Our Data Protection Officer’s contact details |
2 Cattedown Road, Plymouth PL4 0EG 07889209486 | 2 Cattedown Road, Plymouth PL4 0EG 07889209486 |