PRIVACY POLICY

1. WHO WILL HOLD YOUR INFORMATION?
Your information will be held by Broughton, Ramsden & Page (“BRP” or “we”).  Our office address is Eagle Tower, Cheltenham GL50 1TA. For the Purposes of the Data Protection Act 1998 (the “Act”) the data controller is Broughton, Ramsden & Page.

2. THE INFORMATION ABOUT YOU WHICH WE COLLECT
2.1 The information about you which we will collect may include:

2.1.1 Personal contact details such as name, address, contact telephone numbers and email address and any other information provided at the time of registering on our Website or via the “Settings” pages;

2.1.2 Information such as your gender, job title and profession;

2.1.3 Information to assist in the operation of our services including where available your IP address, operating system and browser type. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual;

2.1.4 We may ask you to you to complete surveys that we use for research purposes, although you do not have to respond to them;

2.1.5 If you contact us, we may keep a record of that correspondence;

2.1.6 Details of your visits to our Website, including but not limited to, traffic data, location data, information and data that you upload to our Website and the resources that you access;

2.1.7 Cookie information (see clause 6 below);

3. THE INFORMATION WE HOLD ABOUT YOU

3.1 We may receive information about you directly from you when you submit information to us through our Website (for example by filling in forms on the Website or indicating that you would like to join our mailing list). We may also ask you for information when you report a problem with our Website.
3.2 We may collect information about your computer and browsing actions by the use of Cookies (see clause 6 below).
3.3 If you contact us by telephone or in writing, we may keep a record of that correspondence or phone call.
3.4 In addition, we may receive your personal information from our direct marketing activities.
3.5 We may monitor or record communications with us in which you take part:
3.5.1 to assist us with the development of our services;
3.5.2 to train our staff;
3.5.3 if so requested by order of the Court, regulatory body or law enforcement organisation.

4. PURPOSES FOR WHICH WE HOLD AND USE YOUR INFORMATION
4.1 We may use your information for a number of purposes which are outlined below:
4.1.1 The provision of services to you:

4.1.1.1 To administer and maintain our records;

4.1.1.2 To ensure that our service continues to be the most appropriate service for your needs and that content from our website is presented in the most effective manner for you and your computer;

4.1.1.3 To manage your user account;

4.1.1.4 To allow you to participate in interactive features of our service, when you choose to do so;
4.1.1.5 To verify your identity and to respond to any query that you may raise with us; and
4.1.1.6 To fulfil any contractual obligations we have with you.
4.1.2 We reserve the right to send all customers of our services email communications from time to time regarding updates and changes to our services and any technical, administrative and legal notices important to our website which we consider essential.
4.1.3 Marketing:
4.1.3.1 We may use your data to provide you with information about our services or products which may be of interest to you and we may contact you about these by [post or telephone].
4.1.3.2 We may use your data to contact you for market research purposes
4.1.3.3 We do not pass your personal information to third parties for any Marketing Activities.
4.1.3.4 [From the information on your Website it does not look like you have third party advertisers on the Website, further given your services it would seem unlikely that you would pass personal data to any third party for marketing purposes – however please confirm.]
4.1.4 Other purposes:
4.1.4.1 Your information may be used by us for the purpose of research and statistical analysis and internal customer service monitoring;
4.1.4.2 We may disclose your personal information to any member of our firm, which means our subsidiaries, or  any holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006;
4.1.4.3 We may disclose your personal data to third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect our rights, property, or safety or that of our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.
4.1.4.4 We may disclose your personal data in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets and their advisers.  If our business is sold your details will be passed onto the new owners of the business.
4.1.4.5 We may employ the services of other parties for dealing with various matters in connection with the Website and the services provided on the Website. The providers of such services may have access to your personal data.
4.1.5 The period of use of the personal data supplied by you will not be longer than we deem necessary but may, be unlimited.

5. KEEPING INFORMATION UP TO DATE AND SECURE
5.1 If any of the information that you have provided to us changes, for example if you change your email address or other contact details or if you wish to cancel your registration with us, please let us know by writing to us at the address below.
5.2 We are committed to protecting the security of your personal information.  We have in place a level of security appropriate to the nature of the data and the harm that might result from a breach of security. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

6. WHERE WE STORE YOUR DATA
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, in the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

7. COOKIES
7.1 This website uses “cookies” and other tracking technologies.  Cookies are small pieces of information which are sent by a website to your web browser and remain on your computer until they are deleted. They help us to improve our site and to deliver a better and more personalised service. They enable us:
7.1.1 To estimate our audience size and usage pattern.
7.1.2 To store information about your preferences, and to allow us to customise our site according to your individual interests.
7.1.3 To speed up your searches.
7.1.4 To recognise you when you return to our site.

7.2 You can restrict or block cookies that are set by our website through your browser settings. The help function should guide you through this. Alternatively, you can visit http://www.aboutcookies.org for more information.
7.3 Web beacons are a type of tracking device and are a transparent image file. Web beacons enable us to track website usage information, such as the number of times a given web page has been viewed. Web beacons are invisible to you and (unlike cookies) are not placed on your computer.
7.4 Web beacons may be used in association with cookies to understand how visitors interact with the pages and content on the pages of the Website.  We may use web beacons to track usage information and to compile information about how our users use different products and services and when they click through to offers shown on the website. Web beacons may also be used to track whether you have opened an HTML email. When the email is opened a part of the code that makes up the HTML page calls a web server to load the web beacon which then generates a record showing that the email has been viewed. Web Beacons may also recognize when the email was opened, how many times it was forwarded and which URL’s (links within the email) were clicked. For the purposes of this privacy policy “Cookies” shall mean cookies and all other tracking devices including web beacons.
7.5 Most web browsers automatically accept Cookies, but you can usually change your browser to limit or prevent cookies. Cookies in themselves do not identify the individual user, but rather the computer used. Users may have the opportunity to set their computers to accept all cookies, to notify them when a cookie is issued, or to not receive cookies at any time.  Different browsers may address Cookies differently. If you set the browser to not accept cookies, it may result in certain personalized services not being provided to users of that computer. Unless you have adjusted your browser settings so that it will refuse cookies, our system will issue Cookies as soon as you visit the Website.
7.6 Cookies are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

Third Party Applications using Cookies:

Google Analytics
GoogleAnalytics (GA) is tracking software used to provide information about your session when visiting the site and uses cookies to store and persist this information. It does not collect personal data about website visitors and only uses first-party cookies, meaning that any data used by cookies set for any given domain is only sent to servers for that domain. The data cannot be altered or retrieved by any service on another domain.

Disabling or rejection information: http://www.google.com/intl/en/policies/privacy/

8. YOUR RIGHTS
8.1 You may have certain rights under the Data Protection Act in relation to the information that we hold about you.  These rights include the rights set out below:
8.1.1 You are entitled to have access to your personal data. You may request by writing to us (at the address given below), details of your information which we hold and the purposes for which it is held.  We will provide this information within 40 days of your request, subject to any routine processing continuing between that time and the time of response. You may be charged a reasonable fee (as permitted by the Act) for this information.
8.1.2 You are entitled to request that we stop using information about you for the purpose of direct marketing (i.e. the communication to you (by whatever means) of any advertising or marketing material);
8.1.3 You are entitled to require us to ensure that no decision taken by or on behalf of us and which significantly affects you is based solely on the automated processing of your information, for the purpose of evaluating such matters as, for example, your creditworthiness, reliability or conduct; and
8.1.4 You are entitled to require a correction of errors in the personal information held about you. If we disagree that information is inaccurate you are entitled to apply to ask the court for an order that such erroneous information be rectified, blocked, destroyed, or erased.

9. YOUR CONSENT AND CHANGES TO THIS PRIVACY POLICY
By submitting your information you consent to the use of that information as set out in this policy. If we change our privacy policy we will post the changes on this page and may place notices on other pages of the website, so that you may be aware of the changes.

10. CONTACT DETAILS
If you would like to contact us with any queries or comments regarding our privacy policy, please send an email or write to: The Data Protection Officer, Broughton, Ramsden & Page,  Russell Street, Cheltenham GL51 9HF.