Introduction
We take the privacy of the management of data and website users seriously. Please read the following information carefully. This privacy notice contains information about what data we collect and store about you and why. It also tells you who we share this information with, the security mechanisms we have put in place to protect your data and how to contact us if you have a complaint. If you have any requests concerning your personal information or any queries about these practices, please contact us by e-mail at info(at)kristijanaturnbull.com
We collect, use and are responsible for personal information about you. When we do this, we are the “controller” of this information for the purposes of the General Data Protection Regulation and other applicable data protection laws.
We are committed to safeguarding the privacy of our website visitors and service users; in this policy, we explain how we will handle your personal data.
Personal data collected
We may process data about your use of our website and services “site usage data.” The site usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is in Google Analytics tracking system and Hotjar. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is consent OR our legitimate interests, namely monitoring and improving our website and services.
We may process information contained in any enquiry you submit to us regarding or services “enquiry data” this may include your name and email address, plus any details you provide to us to support your enquiry. The enquiry data may be processed for the purposes of contacting you either by phone or an email address provided by you to discuss further the counseling services we offer. The legal basis for this processing is consent.
We may process information in our secure client portal relating to the progress of your legal case, “client data”. The transaction data may include your contact details, your case details and your contract with us. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our business. Our use of your information is subject to your instructions, GDPR and current the Data Protection regulations and our duty of confidentiality. Therefore, we keep information passed to us confidential and will not disclose it to third parties except as authorised by you or required by law. However, if on your instruction, we are working with other professional service providers (such as expert witnesses or other professional advisors) we will assume that we may disclose any relevant information about your matter to them.
We may process information contained in or relating to any communication that you send to us at the email adress. The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
We process “call data,” the call data is captured by monitoring activity throughout our website using a third-party provider (Mediahawk) to improve our Digital Marketing using a Cookie (See Cookie Policy). We track which sources are effective at helping visitors find our website and make calls to us. We use IP addresses, geo-location data, caller telephone number, and voice recordings.
In addition to the specific purposes for which we may process your personal data set out in this Section , we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person.
Please do not supply any other person’s personal data to us, unless we prompt you to do so.
Use and disclosure of personal information
We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.
In addition to the specific disclosures of personal data set out in this Section , we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
Retaining and deleting personal data
Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
Site Usage data –cookies will be held for a maximum of 90 days but are refreshed each time you visit the site
Enquiry data – will be held for a maximum of 18 months if the enquiry doesn’t progress into a case the personal details supplied will be deleted.
Call data – call recordings will be held for a 30-day period and used for training and quality control.
Client data and Correspondence data – We are required to keep our file of papers (except for any of your papers which you ask to be returned to you) for six years. We keep the file upon the understanding that we have your authority to destroy it six years after the date of the final bill we send you.
Your options and consent
You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to the supply of appropriate evidence of your identity for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address.
We may withhold personal information that you request to the extent permitted by law.
You may instruct us at any time not to process your personal information for marketing purposes.
In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
Your rights
Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
You have the right to object to our processing of your personal data for direct marketing purposes including profiling for direct marketing purposes. If you make such an objection, we will cease to process your personal data for this purpose.
You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
To the extent that the legal basis for our processing of your personal data is consent, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
You may exercise any of your rights in relation to your personal data by written notice to us at info(at)kristijanaturnbull.com
How to make a complaint
We hope that you are happy with our service and that we can resolve any issues or complaints that arise. Please get in touch if you have any concerns (see “Our details” below).
The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where the alleged infringement of data protection laws occurred.
About cookies
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. To find more information about cookies, manage or delete the cookies on your devices, please visit: www.allaboutcookies.org
Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
Cookies that we use
We use cookies for the following purposes:
(a) authentication – we use cookies to identify you when you visit our website and as you navigate our website, cookies used for this purpose are: identify cookies;
(b) status – we use cookies to help us to determine if you are logged into our website, cookies used for this purpose are: identify cookies;
(c) personalisation – we use cookies to store information about your preferences and to personalise the website for you, cookies used for this purpose are: identify cookie;
(d) security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally cookies used for this purpose are: identify cookies;
(e) advertising – we use cookies to help us to display advertisements that will be relevant to you, cookies used for this purpose are: identify cookies;
(f) analysis – we use cookies [to help us to analyse the use and performance of our website and services, cookies used for this purpose are: identify cookies; and
(g) cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally, cookies used for this purpose are: identify cookies.
We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.
Managing cookies
Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
Blocking all cookies will have a negative impact upon the usability of many websites.
Security
This Site takes precautions to protect our users’ information. When users submit sensitive information via the Site we shall endeavour to ensure that your information is protected both online and off-line. If you have any questions about the security at our Site, please contact info(at)kristijanaturnbull.com.
Links
This web site could contain links to other sites. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of these third-party sites.
This privacy statement applies solely to information collected by this Web site.
Amendments
We may update this policy from time to time by publishing a new version on our website.
You should check this page occasionally to ensure you are happy with any changes to this policy.
We will not update you of every little change to this policy but significant changes will be notified via email.