The Fine Print
PRIVACY POLICYWe respect the privacy of visitors to our website www.azorra.co.uk (“Site”) or anyone who engages with us to use the products or services that we offer (whether through the Site or otherwise) (our “Services”) or whose personal information we may process as a result of providing the Services whether to them or another person, or who applies to work with us and we are committed to protecting your personal data.
The purpose of this Privacy Policy is to explain how we will use any personal data we collect about you, the rights you have over any personal data we hold about you, and to tell you about the policies and procedures that we have in place to respect your privacy and keep your personal data secure.
This Privacy Policy is intended to enable you to understand how your personal information may be processed by us when you use the Site and/or our Services and/or when we provide the Services to our clients. We advise you to read and understand its terms. Please note that when using the Site it should be read in conjunction with our Website Terms of Use and our Cookie Policy.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below.
1. Important information and who we are
2. What personal information do we collect about you?
3. How is your personal data collected?
4. How and why do we use your personal data?
5. Where do we transfer your personal data?
6. How long do we keep your personal data?
1. Important information and who we are
The Site and our Services are operated by Azorra Limited (“we”, “us” or “our”).
The data controller responsible for your personal information processed via the Site or in relation to the Services is Azorra Limited, a limited liability company registered in England and Wales with company number 09862720 whose registered office is at Aston House, Cornwall Avenue, London, N3 1LF.
How to contact us?
If you have any comments or questions about this Privacy Policy or our data processing practices, please address them to us at hello@azorra.co.uk or address the letter for the attention of our Data Protection Manager to the registered address above.
Your details and any changes
We need to ensure that the data that we hold about you is accurate and current. Please let us know if your personal data changes during your relationship with us.
Third Party Links
We sometimes provide you with links to other websites or mobile applications, but these websites and mobile applications are not under our control. We are only responsible for the privacy practices and security of our Site and Services. We are not responsible for the privacy policies, content or security of any linked websites or mobile applications. We recommend that you check the privacy and security policies of each and every website and mobile application that you visit.
2. What personal information we hold about you
Personal data, or personal information, for the purposes of this Privacy Policy means any information about an individual from which that person can be identified.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:-
(a) Site Visitors
Where you complete the “Contact us” form – your name, email address and content of your enquiry.
Such information as is collected by the cookies on our Site. Please see Cookie Policy.
Where you open an account on our Site (as such feature may be made available from time to time) your login details, username and password, details of any transactions you may make on the Site.
Information about the pages or sections you have visited on our Site, the website or mobile application you were referred from and when you visited or used our Site (“Usage Data”).
Your marketing preferences.
(b) Individual clients enquiring about or using our Services:
Name, job title and details of your occupation and self-employment business.
Contact information including email address, home or business address and telephone number.
Payment information.
Information that you provide to us as part of the provision of our Services to you which will depend on the matters we are instructed to act on for you and may involve limited personal information (for example in relation to commercial transactions) or larger amounts of personal information (for example in relation to employment matters) and may also include personal information about other people involved in the relevant matter.
Such information as we may be require in order for us to comply with Know Your Client and/or Anti Money Laundering regulations which may include a copy of your passport and utility bill We may request and/or verify this information through you or through online tools or both.
Your marketing preferences.
(c) Persons whose personal data we process when providing Services to others
We process personal information relating to individuals where we provide Services to others, such as individual clients and corporate clients. We will process a variety of different personal information depending on the nature of our Services including name, job title and contact details, bank details, age, date of birth, years of service with your employer, details about your employment contract and employment records. Examples of where this situation may arise is in relation to the personal information relating to our clients’ or prospective clients’ employees, workers or contractors, details of people on the other side of the transaction (e.g. commercial contracting parties, dispute opponents, buyer from or sellers to our clients and, in each case, their employees, workers, advisors or contractors).
(d) Potential consultants or employees:
Name and job title.
Contact information including email address.
CV, your education, employment history and industry experience, covering correspondence and similar information that you may provide to us.
Other information relevant to our recruitment practices.
(e) Suppliers and service providers
Name and job title.
Contact information including email address.
From time to time we may also collect and use Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Site feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
Where we process Special Categories of Personal Data in relation to individuals, we will usually only be doing so because it is necessary in connection with legal proceedings including prospective legal proceedings, obtaining legal advice or necessary to establish, exercise or defend legal rights or, in respect of recruitment, with a candidate’s consent.
We use different methods to collect data from and about you including through:
Direct interactions: You may give us your personal data by filling in the Contact Us form on our Site or otherwise contacting us by post, phone, text message, email, social media, online, in person in connection with our business or our Services.
Automated technologies or interactions: As you interact with our Site we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this data by using cookies, server logs, and other similar technologies. Please see our Cookie Policy for further details.
Information received from third parties: We may receive personal information about you from third parties such as from our clients (see section 2(c) above) or from Companies House, social media accounts or other public records.
3. How is your personal data collected
4. How and why do we use your personal data
All personal data that we obtain about you will be used in accordance with current data protection law and this Privacy Policy. We, or third party data processors acting on our behalf, will only use your personal data in the following circumstances:-
As necessary, to perform a contract with you or our client, such as a contract for our Services.
As necessary, to comply with a legal obligation.
As necessary, for our legitimate interests in operating our business and providing our Services in a way that ensures they operate safely, securely and in a commercially suitable way
As necessary to protect your vital interests or those of another person in a life or death situation.
As necessary to perform a task in the public interest.
With your consent.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent at any time by contacting hello@azorra.co.uk.
We will not use any personal data which you provide to us or which we receive from third parties to send direct marketing communications to you unless you have specifically consented to the same and the form of that consent meets all legal requirements.
Purposes for which we will use your personal data
We have set out below, in a table format, the ways we, or our third party processors acting on our behalf, plan to process 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.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at hello@azorra.co.uk if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
How do we obtain your consent?
Where our use of your personal information requires your consent, you can provide such consent:
at the time we collect your personal information following the instructions provided; or
by informing us by e-mail, post, SMS or phone using the contact details set out in this Privacy Policy or available on our Site.
Where you have opted in to receive marketing communications from us we will send you information that we reasonably believe will be helpful or interesting to you from time to time. We will not share your information for marketing purposes with any third party without your consent.
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 receive an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact hello@azorra.co.uk.
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 or request your consent 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.
Other third party disclosures of personal information
We will also disclose your personal data to third parties in the following circumstances:
where we sell, transfer or merge parts of our business or our assets or propose to do so we may share your personal information with prospective buyers or partners. 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 as set out in this privacy policy;
if we or substantially all of our assets are acquired by a third party, in which case personal data held by us will be one of the transferred assets;
if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, any lawful request from government or law enforcement officials and as may be required to meet national security or law enforcement requirements or prevent illegal activity;
in order to enforce or apply our Terms of Business or any other agreement or to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity; or
to protect the rights, property, or safety of us, our clients or other persons. This may include exchanging personal data with other 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 instructions.
Save as expressly detailed above in this section, we will never share, sell or rent any of your personal data to any third party without notifying you and/or obtaining your consent.
Third Party contractors and other controllers
As mentioned above, we may appoint sub-contractor data processors as required to help us to deliver the Services, such as but not limited to marketing service agencies. Where we do so, they will process personal information on our behalf and at our direction. We conduct an appropriate level of due diligence and put in place necessary contractual documentation in relation to any sub-contractor to ensure that they process personal information appropriately and according to our legal and regulatory obligations.
Further, we may appoint external data controllers in common with us where necessary to deliver the Services, such as but not limited to, barristers, freelance consultant solicitors and external law firms. Where we do so, we will comply with our legal and regulatory obligations in relation to the personal information including but without limitation (where necessary) putting appropriate safeguards in place to ensure any personal information is processed according to our legal and regulatory obligations.
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PURPOSE/ACTIVITY |
LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST |
WHO DO WE SHARE YOUR DATA WITH? |
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Verification of identity |
(1) Legal obligation |
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Provision of Services |
(1) Legal obligation (2) Performance of a contract with you or others (3) Legitimate Interests of us or others to use your personal information to provide our Services in the best possible way |
Third parties with whom we work in connection with the provision of Services to you including (but not limited to):-
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Fulfilment of requests made on the Site or in relation to Services |
(1) Performance of a contract with you or others (2) Legitimate Interests of us or others to use your personal information to provide our Services or respond to your requests in the best possible way |
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Records of prospective clients |
(1) Legitimate interests to develop our products/services and grow our business |
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Enforce our contracts |
(1) Performance of a contract (2) Legitimate Interests in connection with the operation of our business |
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To manage our business relationships and transactions including, but not limited to:-
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(1) Legal obligation (2) Performance of a contract with you or others (3) Legitimate Interests of us or others to provide the best possible Service |
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Business administration and compliance with all applicable laws |
(1) Legal obligation (2) Legitimate Interests of us or others to ensure our business administration is performed in the best way possible |
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Use of data analytics to improve our Services and Site or marketing and deliver relevant content |
(1) Legitimate interests to improve our Services and Site and ensure we provide the best possible products and services for our clients, to keep our Site updated and relevant and to inform our marketing strategy (2) Consent in relation to cookies Note where your personal information is completely anonymised we do not require a legal basis to use it because the information is not deemed to be personal data. |
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To administer an online account on our Site |
(1) Performance of a contract (2) Legitimate Interests to administer the account and provide the best possible Service |
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Recruitment |
(3) Legal obligation in connection with our recruitment obligations (e.g. as regards equality opportunities) (4) Legitimate Interests to ensure we recruit the most suitable candidates and ensure compliance with our equal opportunity policies (5) Consent in relation to the personal data you provide |
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Marketing or making suggestions about goods or services that may be of interest |
(1) Performance of a contract (2) Legitimate Interests to promote our Services (where consent is not legally required for us to contact you) (3) Consent where we are legally required to have your consent to contact you to market our goods or Services |
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To send you information which you have requested |
(1) Legitimate Interests to provide the best possible Service (2) Consent to receive such information |
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Performance of contract with our suppliers and service providers |
(1) Legal obligation (2) Performance of a contract (3) Legitimate Interests for effective operation of our business and to keep records of agreements and correspondence in relation to our suppliers and service providers or details or prospective suppliers and service providers |
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5. Where do we transfer your data
If you are based within the EEA or UK, your personal data may be transferred to, and processed in a location outside of the UK/EEA if our third party processors and service providers or their systems are based there.
Some countries outside the UK/EEA do not have laws that protect your privacy rights as extensively as those in the United Kingdom. However, if we do transfer your personal data to other territories, we will put in place appropriate safeguards to ensure that your personal data is properly protected and processed only in accordance with this Privacy Policy and in accordance with all relevant laws which apply to the personal data of citizens within the UK/EEA..
6. How long do we keep your personal data?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including the purposes of satisfying any legal, accounting or reporting requirements.
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.
Where you visit the Site, we will retain relevant personal information in accordance with our Cookie Policy.
Where we process personal information we have processed as part of providing the Services to any client or in respect of any enquiry, we will retain relevant personal information for at least six years from the date of our last interaction with that client and in compliance with our obligations under the UK General Data Protection Regulation and EU GDPR (or similar legislation around the world) or for longer where we are required to do so according to our regulatory obligations or professional indemnity obligations.
We will always retain your personal data in accordance with data protection law and never retain your personal data for longer than is necessary. If you have any questions about our retention policy contact hello@azorra.co.uk.
7. How do we protect your personal data
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 instructions and they are subject to a duty of confidentiality.
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.
We cannot guarantee the security of your personal data when you transmit it to us. For example, if you email us your personal data, you should be aware that email is not a secure transmission method. As such, you acknowledge and accept that we cannot guarantee the security of your personal data transmitted to us and that any such transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to prevent unauthorised access.
Where we have given you (or where you have chosen) a password which enables you to access one of our Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
8. What are your legal rights
You may contact our Data Protection Manager by email at hello@azorra.co.uk at any time, to:
request that we provide you with a copy of the personal data which we hold about you;
request that we update any of your personal data which is inaccurate or incomplete;
request that we delete any of your personal data which we are holding;
request that we restrict the way that we process your personal data;
request that we provide your personal data to you or a third-party provider of services in a structured, commonly-used and machine-readable format;
object to us processing personal data based on our legitimate interests; or
object to us processing your personal data for direct marketing purposes.
No fee usually required
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.
What we may need from you
Your request must include your name, email address and postal address and we may request proof of your identity. Please allow at least seven working days for us to process your request.
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.
Time limit to respond
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.
Objection to public interest/legitimate interest processing
Where you object to processing personal data based on public interest or legitimate interests we can continue to process such data if we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or where the processing is taking place for the establishment, exercise or defence of legal claims.
Withdrawing your consent
Where we are processing your personal data based on your consent, you may change your mind and withdraw your consent at any time.
You can withdraw your consent to receive marketing communications by clicking on the unsubscribe link in an email.
You can also withdraw your consent to receive marketing communications or any other consent you have previously provided to us by contacting us at hello@azorra.co.uk.
The consequence of you withdrawing consent might be that we cannot do certain things for you (e.g. continue to send you newsletters or provide you with updates).
Right to lodge a complaint with a supervisory authority
You may also make a complaint to a supervisory authority for data protection matters. In the UK, this would be the UK Information Commissioner’s Office https://ico.org.uk. If you live in another EEA country, you may complain to the supervisory authority in your country. Alternatively you may seek a remedy through local courts if you believe your rights have been breached.
Changes to our Privacy Policy
We reserve the right to change our Privacy Policy from time to time. Any such changes will be posted on this page so that we can keep you informed about how we process your personal data. We recommend that you consult this page frequently so that you are aware of our latest Privacy Policy and can update your preferences if necessary. Your continued use of our Site and Services shall constitute your acceptance of any revised Privacy Policy.
This Privacy Policy was last updated on 09 February 2022