Website Privacy Policy

Introduction
1. Quastels LLP (“Quastels”, “we” or “us”), respect your privacy and are committed to protecting your personal data. This privacy policy sets out how we look after your personal data when you visit our website www.quastels.com (this “website”), regardless of where you visit it from, and tells you about your privacy rights and how the law protects you.
2. We keep our privacy policy under regular review. This version was last updated on Tue 19 Oct 2021.
3. 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.
4. This notice only relates to the processing of personal data provided by you as a result of visiting this website. In the event that we process your personal data in a different context we will provide you with a separate notice.
About us and this privacy policy
1. This privacy policy aims to give you information on how Quastels LLP collects and processes your personal data through your use of this website.
2. This website is not intended for children and we do not knowingly collect data relating to children.
Controller
1. Quastels LLP is the controller and responsible for this website.
2. 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.
3. 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.
Contact details
1. If you have any questions about this privacy policy or our privacy practices, please contact us by email at: privacy@quastels.com.
2. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator 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.
The data we collect about you
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).
2. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
  1. “Technical Data” includes internet protocol (IP) address, 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 you use to access this website.
  2. “Usage Data” includes information about how you use our website.
3. 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.
How we collect personal data
We use different methods to collect data from and about you including through:
1. Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data and Usage 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 our cookie policy for further details.
2. Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
  1. Technical Data from the following parties:
    1. analytics providers such as Google based outside the UK;
    2. advertising networks; an
    3. search information providers.
How and why we use your personal data
1. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
  1. where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  2. where we need to comply with a legal or regulatory obligation.
2. Generally, we do not rely on consent as a legal basis for processing your personal data. You have the right to withdraw consent to marketing at any time by contacting us.
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. These lawful bases include:
  1. Legitimate interest. The interest of our business in conducting and managing our business to enable us to give you the best service 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.
  2. Comply with a legal obligation. Processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
4. 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 if you need details about the specific legal ground that we are relying on to process your personal data where more than one ground has been set out in the table (Table 7.4 below).
5. Who we share your personal data with.
  1. We may share personal data with third parties we use to help us run our business, e.g. website hosts and website analytics providers.
  2. We or third parties mentioned above may occasionally also need to share personal data with:
    1. external auditors, e.g. in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations;
    2. professional advisors (such as website designers), in which case the recipient of the information will be bound by confidentiality obligations;
    3. law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations; and
    4. other parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency, usually information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations.
6. Cookies. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.
7. Change of purpose. 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. 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. 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.
Data security
1. We have implemented appropriate and reasonable administrative, physical and technological security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized 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.
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.
Data retention
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. For more information and specified data retention periods please contact us at privacy@quastels.com.
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.
Your legal rights
1. Under certain circumstances, you have rights under data protection laws in relation to your personal data including:
  1. The right to be informed. We will give you information about how we use your personal data at the time we collect it from you (for example, our cookies banner that you will see when visiting our website for the first time) or through privacy notices such as this one.
  2. The right to access your personal data. You have the right to get a copy of your personal data and details of how we use it (commonly known as a “data subject access request”). You can ask for details of the personal data we hold about you and check that we are lawfully processing it by using our details above in “Contact Details”. We may need proof of your identity. We will also need you to tell us which information and uses of your data you want to know about (for example, which of our services were involved and when we might have used the data). We may also ask you to fill in an optional application form to help us confirm your identity and trace the information you need. Please download our Subject Access Request Form for more details.
  3. The right to have your data corrected. You have the right to have your data corrected if it is wrong or incomplete. We will do our best to make sure your personal data is accurate and up to date. However, we rely on you to check that some of the information we hold about you is accurate and up to date. Please let us know about any changes to your information. We may need to verify the accuracy of the new data you provide to us.
  4. The right to object to processing of your personal data. You have the right to object to some uses of your personal data, such as for marketing. However, if the law allows us to continue using your data, we may do so.
  5. The right to have your data deleted. You have to right 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.
  6. The right to request restriction of processing of your data. You have the right to ask us to suspend the processing of your personal data if:
    1. you feel that it is not accurate and needs to be checked;
    2. you disagree with our legal reasons for using your data and want us to reconsider using it;
    3. our use of the data is unlawful but you do not want it to be deleted; or
    4. 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.
  7. The right to request transfer of your personal data. You have the right to ask us to transfer your personal data to another organisation. 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.
  8. The right to withdraw your agreement to use personal data. If you have agreed we may use your personal data in a certain way, you can withdraw that agreement at any time. 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.
2. If you wish to exercise any of the rights set out above, please contact us.
3. 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 could refuse to comply with your request in these circumstances.
4. What we may need from you. 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.
5. Time limited to respond. 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.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
Administering and protecting our business and this website including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data.	(i) 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
Using data analytics to improve our website, services, and customer relationships and experiences.	(i) Technical (ii) Usage	Necessary for our legitimate interests. We may use your data to study how customers use our website, to improve our services, and to grow our business.
Retaining and evaluating information on your recent visits to our website and how you move around different sections of our website for analytics purposes. This helps us to understand how people use our website so that we can make it more intuitive or to check our website is working as intended	(i) Technical (ii) Usage	Necessary for our legitimate interests We may use your data to make improvements to our website and Cookie Policy.
Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, e.g. to record and demonstrate evidence of your consents where relevant	(i) Technical (ii) Usage	Necessary to comply with a legal obligation. We need to use your personal data in the event that we are audited.

Table 7.4 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