The law on Data Protection is changing due to advances in technology in recent years. The Data Protection Act 1998 will be replaced by the new EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”) coming into effect on 25 May 2018.
Sterling Partners Limited understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, sterlingpartners.co.uk (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
- Definitions and Interpretation
In this Policy, the following terms shall have the following meanings:
|“Account”||means an account required to access and/or use certain areas and features of Our Site;|
|“Cookie”||means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 13, below;|
|“Cookie Law”||means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;|
|“personal data”||means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and|
|“We/Us/Our”||means Sterling Partners, a limited company registered in England and Wales under company number 06974542, whose registered address is Grove House, 774-780 Wilmslow Road, Didsbury, Manchester M20 2DR. and has another trading address of Units 15 & 16, 7 Wenlock Road, London N1 7SL. Independent Financial advice is through Sterling Wealth Ltd authorised and regulated by Financial Conduct Authority registration number 653104. Bookkeeping and payroll services are through Plusbooks registered in England and Wales with company number 09983011.|
- Information About Us
- For the purpose of GDPR (or an equivalent binding legislation), we are the ultimate data controller in relation to data collected by us from your use of our Site. This means we are responsible for deciding how we hold and use personal data about you. We are registered as Data Controllers with the Information Commissioner’s Office (ICO).
- Our Site is operated by IRIS Software Group Limited, a limited company registered in England and Wales under company number 6295385, whose registered address is Riding Court House, Riding Court Road, Datchet SL3 9JT.
- Our Data Protection contact point is Saeid Mokhtassi, and can be contacted by email at firstname.lastname@example.org, by telephone on 0161 446 2112, or by post at Grove House, 774-780 Wilmslow Road, Didsbury, Manchester M20 2DR.
- We are regulated by Institute of Chartered Accountants (ICAEW) in England and Wales.
- Our Financial Services in Sterling Wealth are regulated by Financial Conduct Authority registration number 653104.
- Our bookkeeping services in PlusBooks are regulated by The Institute of Certified Bookkeepers (ICB) in England and Wales.
- We are a member of the Chartered Institute of Taxation (CIT) and ICAEW.
- Approved employer for trainee development by Association of Chartered Certified Accountants (ACCA).
- What Does This Policy Cover?
- Your Rights
- As a data subject, you have under certain circumstances the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
- The right to be informed about Our collection and use of personal data;
- The right of access to the personal data We hold about you (see section 12);
- The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);
- The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);
- The right to restrict (i.e. prevent) the processing of your personal data;
- The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
- The right to object to Us using your personal data for particular purposes; and
- Rights with respect to automated decision making and profiling.
- If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
- For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
- As a data subject, you have under certain circumstances the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
- What Data Do We Collect?
- business/company name
- contact information such as email addresses and telephone numbers;
- aggregate demographic information such as post code, preferences, and interests;
- IP address;
- web browser type and version;
- operating system;
- a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;
We do not collect any ‘Special Categories of Personal Data’ about you which includes details about your race or ethnicity, religious or beliefs, sex life and orientation, political views, trade union membership, health information and genetic and biometric data). We also do not collect any information from children nor do we collect any information about criminal convictions and offences.
- How Do We Use Your Data?
- All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.
- Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
- Providing and managing your Account;
- Providing and managing your access to Our Site;
- Personalising and tailoring your experience on Our Site;
- Supplying Our services to you (please note that We require your personal data in order to enter into a contract with you);
- Personalising and tailoring Our services for you;
- Replying to emails from you;
- Fraud prevention and IT security;
- Intra-business transfers;
- Supplying you with emails that you have opted into such as our Newsletter (you may unsubscribe or opt-out at any time by using the unsubscribe option supplied);
- Market research in order to offer new services or improve on our current services;
- Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;
- Third parties whose content appears on Our Site may use third party Cookies. Please refer to section 13 for more information on controlling Cookies. Please note that We do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties.
- You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
- We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
- We will delete the personal data you shared with us after one year if you do not become our client.
- When you become a client, how long each type of personal data will be retained will be service-specific and we will give you details in our privacy notices and Engagement Letters or contracts.
- How and Where Do We Store Your Data?
- We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
- Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). It may also be processed by staff when they travel on business abroad. You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR including:
- Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
- Steps We take to secure and protect your data include:
- Encrypted and highly secure use of cloud services;
- Provision of a single digital storage place for all client data;
- Microsoft Office 365 Message Encryption to allow for email encryption;
7.5 Unfortunately, internet in general provides a best effort service meaning data can get lost and transmission of information is not completely secure. However, we do our best to protect your personal data and cannot guarantee the security of your data where it is transmitted via the internet. Upon receipt of your information, we will use strict procedures and security measures to try to protect it.
- Do We Share Your Data?
- We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you.
- We may sometimes use third party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any personal data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR.
- In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.
- What Happens If Our Business Changes Hands?
- In the event that any of your data is to be transferred in such a manner, you will be contacted in good time and informed of the changes.
- How Can You Control Your Data?
- In addition to your rights under the GDPR, set out in section 4, when you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and by managing your Account. FIND OUT more!
- Once you become a client, we will ask you to use our cloud service of Iris OpenSpace which provides a secure encrypted online collaboration platform accessible from anywhere and acting as a single storage place for all communication. You can access this platform using Our site.
- You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
- Your Right to Withhold Information
- You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
- Where we need to collect personal data by law, or under the lawful basis 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 trying to enter into with you 9for example, to provide you with an answer to an enquiry). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at any time.
- How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details using the contact details below in section 14.
- By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. Third party Cookies are used on Our Site for advertising. For more details, please refer to section 6, above, and to section 13.6 below. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
- All Cookies used by and on Our Site are used in accordance with current Cookie Law.
- Before Cookies are placed on your computer or device, you will be shown a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended. You will be given the opportunity to allow only first party Cookies and block third party Cookies.
- Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in section 13.6. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 13.10, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
- The following first party Cookies may be placed on your computer or device:
|Name of Cookie||Purpose||More Information|
|ASP.Net SessionId||Server cookie which automatically creates a new ID for each user in order to maintain state. These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website.||Strictly Necessary|
|Standard analytics cookie (tracks unique/returning visits plus ecommerce). These cookies collect information about how visitors use a website, e.g. which visitor s go to most often, and if they get error messages from webpages. These cookies do not collect information that identifies a visitor. The information collected is all aggregated and anonymous. These cookies are only there to improve how a website works.||Performance Cookies
Used by Google Analytics
|cookiepref||Stores whether the cookie alert bar has been dismissed.
These cookies allow the website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. For instance, a website may be able to provide you with local weather reports or traffic news by storing in a cookie the region in which you are currently located. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise, to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
|Uit, uid, uvc, psc, pid||These cookies are used to deliver adverts more relevant to you and your interests, they are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.||Advertising or Targeting Cookies
Social book marking cookie
Twitter cookie to tell Twitter that the tweet botton exists on the site and other various Twitter preferences
- Our Site may use analytics services provided by Google. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to improve Our Site and the services offered through it. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.
- The analytics service(s) used by Our Site use(s) Cookies to gather the required information.
- In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
- You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
- It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
- Contacting Us