1. INTRODUCTION
1.1. Welcome to Noon Edwards's privacy policy. Noon Edwardsrespects your privacy and is ommitted to protecting your personal data. Thisprivacy policy will inform you as to how we look after your personal data whenyou visit our website (regardless of where you visit it from) and tell youabout your privacy rights and how the law protects you when you become a client.
1.2. Please note that data protection provisions for any personal data we handle on our client’s customers will be dealt with in a separate data sharing arrangement, annexed to our main Terms of Business.
1.3. We as Noon Edwards Limited are the controller and responsible for your personal data (collectively referred to as "Noon Edwards", "we", "us" or "our" in this privacy policy).
1.4. We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below:
Full name of manager: Stephen Noon
Email address: steve@noonedwards.co.uk
Postal address: 9Dry Close, Cranbrook, Devon, EX5 7EN
Telephone number: 07388927395
1.5. 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.
1.6. This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.
3. THE DATA WE COLLECTABOUT YOU
4. HOW IS YOUR PERSONAL DATA ISCOLLECTED?
5. HOW WE USE YOUR PERSONAL DATA
6. MARKETING
7. COOKIES
8. DISCLOSURES OF YOUR PERSONALDATA
10. DATA SECURITY
11. DATA RETENTION
13. GLOSSARY
2. IMPORTANTINFORMATION
2.1. This privacy policy aims to give you information on how Noon Edwards collects and processes your personal data based on different types of interaction.
2.2. Thiswebsite is not intended for children and we do not knowingly collect datarlating to children.
2.3. It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
2.4. Wekeep our privacy policy under regular review. This version was last updated in October 2024. Historic versions can be obtained by contacting the data privacymanager using the details above.
2.5. 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.
2.6. This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
3. THE DATE WECOLLECT ABOUT YOU
3.1. Personal data, or personal information, 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) or data about corporate entities, like a company.
3.2. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
a) Identity Data includes first name, maiden name, last name, marital status, title, date of birth and gender.
b) Contact Data includes billing address, email address and telephone numbers.
c) Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
d) Technical Data includes internet protocol (IP) address, login data (if applicable), 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 used to access the website.
e) Usage Data includes information about how you use our website, products and services.
f) Marketing and Communications Data includes emails, document views, email link clicks and opens, and your preferences in receiving marketing from us and our third parties and your communication preferences.
3.3. Aggregated Data. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.
3.4. Special Categories. 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.
3.5. Data not provided. 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 services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
4. HOW IS YOURPERSONAL DATA COLLECTED?
4.1. We use different methods to collect data from and about you including through:
a) Direct interactions. You may give us your Identity, Contact Data by filling informs or by corresponding with us by webchat, post, phone, email or otherwise. This includes personal data you provide when you:
I. apply for our products or services;
II. filling out the contact form on our website;
III. subscribe to our publications;
IV. request marketing to be sent to you;
V. enter a competition, promotion or survey;
VI. give us feedback or contact us.
b) Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see section 7 on ‘COOKIES’.
5. HOW WE USE YOURPERSONAL DATA
5.1. Wewill only use your personal data when the law allows us to. Most commonly, wewill use your personal data where we need to perform the contract we are aoutto enter into or have entered into with you, where it is necessary for ourlegitimate interests (or those of a third party) or where we need to compywith a legal obligation. The meaning of Lawful Basis is further defined in the glossary.
5.2. Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
5.3. We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Purpose/Activity
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new client
(a) Identity
(b) Contact
Performance of a contract with you
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(a) Identity
(b) Contact
(c) Transaction
(f) Marketing and Communications
Performance of a contract with you
Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
(a) Identity
(b) Contact
(f) Marketing and Communications
Performance of a contract with you
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our records updated and to study how clients use our products and services)
To enable you to partake in a prize draw, competition or complete a survey
(a) Identity
(b) Contact
(e) Usage
(f) Marketing and Communications
Performance of a contract with you
Necessary for our legitimate interests (to study how clients use our products and services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Identity
(b) Contact
(d) Technical
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(a) Identity
(b) Contact
(e) Usage
(f) Marketing and Communications
Necessary for our legitimate interests (to study how clients use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, client relationships and experiences
(d) Technical
(e) Usage
Necessary for our legitimate interests (to define types of clients for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
(a) Identity
(b) Contact
(e) Usage
(f) Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our business)
5.4. 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.
6. MARKETING
6.1. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
a) Promotional offersPromotionaloffers from us. We may use your Identity, Contact, Technical, and Usage Data toform a view on what we think you may want or need, or what may be of interestto you. This is how we decide which products, services and offers may berelevant for you (we call this marketing). You willreceive marketing communications from us if you have requested information fromus or purchased goods or services from us and you have not opted out ofreceiving that marketing.
b) Opting out. You can ask us or third parties to stopseding you marketing messages at any timeby following the opt-out links on any marketing message sent to you, or bycontacting us at any time. Whereyou opt out of receiving these marketing messages, this will not apply topersonal data provided to us as a result of purchases or other transactions.
7. COOKIES
7.1. Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.
7.2. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive. We use the following cookies:
a) Analytical, tracking or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website or our client’s website when they are using it. This helps us to improve the way website works, for example, by ensuring that users are finding what they are looking for easily. Tracking cookies
b) Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
7.3. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.
8. DISCLOSURES OFYOUR PERSONAL DATA
8.1. We may share your personal data with the parties set out below for the purposes set out in the table ‘Purposes for which we will use your personal data’ above:
a) External Third Parties as set out in the Glossary;
b) Specific third parties listed in the table Purposes for which we will use your personal data; and
c) Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way asset out in this privacy policy.
8.2. 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 instructions.
9. INTERNATIONALTRANSFERS
9.1. Your personal data may be stored or transferred to countries outside the EEA for the purposes described in this policy and pursuant to providing the services to you. When we store or transfer your personal data outside the EEA, we will do so in accordance with applicable law and we will ensure a similar degree of protection is afforded to it by implementing the appropriate safeguards listed below. Transfers of personal data will only be made:
a) to a country recognised by the European Commission as providing an adequate level of protection; or
b) to a country which does not offer adequate protection but whose transfer has been governed by the standard contractual clauses of the UK GDPR or by implementing other appropriate cross-border transfer solutions to provide adequate protection.
By using our services, you understand that your personal data may be transferred to our facilities and those third parties with whom we share it as described in this policy.
10. DATA SECURITY
10.1. Wehave put in place appropriate security measures to prevent your personal datafrom being accidentally lost, used or accessed in an unauthorised way, alteredor disclosed. In addition, we limit access to your personal data to thoseemployees, agents, contractors and other third parties who have a business needto know. They will only process your personal data on our instructions and theyare subject to a duty of confidentiality.
10.2. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
11. DATA RETENTION
11.1. We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
11.2. 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, regulatory, tax, accounting or other requirements.
11.3. Bylaw we must keep basic information about our clients (including Contact, Transaction and Identity Data) for six years after they cease being clients for tax purposes.
12. YOUR LEGAL RIGHTS
12.1. Under certain circumstances, you have rights under data protection laws in relation to your personal data as follows (please check the Glossary for further information on each right):
a) Request access to your personal data.
b) Request correction of your personal data.
c) Request erasure of your personal data.
d) Object to processing of your personal data.
e) Request restriction of processing your personal data.
f) Request transfer of your personal data.
g) Right to withdraw consent.
If you wish toexercise any of the rights set out above, please contact us.
12.2. Fees. 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 could refuse to comply with your request in these circumstances.
12.3. Specific InformationSpecificInformation. 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.
12.4. Response timeResponsetime. We try to respond to all legitimate requests within one month. Occasionally it could 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.
13. GLOSSARY
LAWFUL BASIS
LegitimateInterest means the interest of our business in conducting and managing our business to enable us to give you the best service or product and the best and most secure experience. We make sure we consider and balance any potential impact on you(both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
THIRD PARTIES
In addition to any third parties specifically mentioned throughout this document, External Third Parties can be summarised as follows:
a) Service providers acting as processors based in the UK who provide IT and system administration services.
b) Professional advisers, acting as processors, including lawyers, bankers, auditors and insurers based in the UK, who provide consultancy, banking, legal, insurance and accounting services.
c) Analytics providers, such as Google, based outside of the UK and who act on our behalf as a processor. A link to their privacy policy can be found here.
d) Accounting software, like Xero, based in the US and who act on our behalf as a processor. A link to their privacy policy can be found here.
e) HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS
You have the right to:
a) 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.
b) 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.
c) 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.
d) 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.
e) 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:
i. if you want us to establish the data's accuracy;
ii. where our use of the data is unlawful but you do not want us to erase it;
iii. 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
iv. you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
f) 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.
g) 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.
