Fitzpatrick Referrals is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.
Fitzpatrick Referrals may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 24 May 2018.
1.1 This website is operated by Fitzpatrick Referrals Ltd, a company incorporated in England and Wales with registered number 05287667 and with registered offices at Halfway Lane, Eashing, Godalming, Surrey, GU7 2QQ (“Fitzpatrick Referrals“, “we”, “us” or “our”). Fitzpatrick Referrals is responsible for this “Website” and its contents (www.fitzpatrickreferrals.co.uk/).
1.2 Fitzpatrick Referrals respects your privacy and is committed to treating any information that we obtain about you with as much care as possible and in a manner that is compliant with all applicable data protection legislation including the EU General Data Protection Regulation 2016/679 (“GDPR”) and any national implementing laws in relation to the same (collectively, “Data Protection Legislation”).
1.3.1 what personal data we may collect about you in connection with: (i) your online interaction with us (including via our Website, email, or social media channels); (ii) our in-person interactions with you (such as at one of our sites or at an event); and (iii) any other channels related or ancillary to the foregoing (collectively, the “Channels”);
1.3.2 how we collect, store, disclose, transfer, protect and otherwise process that information and for what purposes; and
1.3.3 other important information, such as the lawful bases by which we process your personal data, how long we might retain your personal data, and the rights you have in relation to the personal data we hold about you.
1.4 In this Notice, terms defined in the GDPR, including “data subject”, “personal data”, and “processing”, have the same meaning when used in this Notice. The words “include”, “including”, “such as” and similar words and phrases shall be construed to mean “including without limitation”.
1.5 This policy is intended to be communicated to you in a concise, transparent, intelligible and easily accessible manner, but we appreciate that you may have queries or want to seek clarification as to its terms. If so, please email [email protected] or write to The Data Controller, Fitzpatrick Referrals Limited, Halfway Lane, Eashing, Godalming, Surrey, GU7 2QQ and we will endeavour to respond as soon as possible.
1.6 Fitzpatrick Referrals reserves the right to make changes to this policy in order to reflect any changes in Data Protection Legislation and best practice from time to time. We will endeavour to notify you of such changes but you are advised to check an updated version of this policy at www.fitzpatrickreferrals.co.uk/privacy-policy each time you interact with us through the Channels.
2. Personal data
How you provide it and how we collect and use it:
Personal data is any information that can be used to identify a specific individual, such as your name, job title, email address, home address, phone number and credit card information.
You may choose to provide personal data when you visit us or our affiliates at one of our sites or through our Website. If you choose not to provide us with your personal data you may not be able to access some of the services offered on our Website, such as newsletters or bulletins. Below are some of the ways in which you may provide us with your personal data and the types of personal data you may submit. We also explain how we (or any of our associated companies) may use the personal data in different ways according to the purpose for which it was provided. For example, if you provide personal data to register for a newsletter or a text messaging service, or to purchase goods or services, we will use it to register you for or provide you with those goods or services. We may also obtain personal data from reputable third parties, such as credit agencies.
We may also use your personal data to provide you with information about our services and other offerings that may be of interest to you. We also may send information or offers to selected groups of Website users on behalf of other businesses. When we do this, we do not give those businesses your name or address.
2.2 Contacting us
2.2.1 Contacting us through our website
If you communicate with us through any link on our Website, we may ask you for your personal data so we (or any of our associated companies) can respond to your questions and comments. You may also choose to provide additional information.
2.2.2 Contacting us via telephone
We may record telephone calls you make to Fitzpatrick Referrals to: (i) ensure compliance with regulatory practice and to establish facts and evidence for client transactions; (ii) train staff; and (iii) prevent, detect, investigate and prosecute fraud. We do this in the interest of offering a good service to our clients and to protect the company. If you object to this, alternative communication methods are available. Your call recording may be shared with other organisations if they have a legal right to it.
2.3 Newsletters and other communications
On our Website, you may sign up to receive newsletters and other communications about our services. To sign up, we may ask you for additional personal data such as your date of birth, postcode, email address and mobile telephone number. This personal data is used by us (or our associated companies) to send you the communications you request.
2.4 Other website features
We offer Website visitors various features for their use, which we may change from time to time. We may ask you to submit certain personal data so we can provide you with these features.
2.5 Other data we may collect automatically
2.5.1 From the website
When you visit the Website, we may automatically collect certain personal data that we then aggregate so that it is not linked to a single, identifiable individual. This information provides us with statistics such as how many users visited our site and which pages were accessed. By collecting this information, we learn how to best tailor this Website to our visitors. We collect this information either through “log files”, “cookie” technology or with “web beacons”, as explained below.
2.5.2 From CCTV
We may record CCTV images of people entering, approaching or passing our buildings, so as to (i) help staff and visitors feel safer; (ii) act as a deterrent to offenders; (iii) allow the collection of evidence to help find and convict offenders; (iv) prevent, detect, investigate and prosecute fraud.
There are clear signs outside the relevant buildings to advise you that CCTV is in operation.
Any recording of CCTV images may be shared with other organisations if they have a legal right to it.
2.6 Log files
Log files are web server files (such as the domain name or IP address, URL, the http response code, the Website from where you visit us or the date and duration of your visit) that are automatically created when an Internet user visits a site. Once you stop using our Website, we process and use this information only to enable further connections, for billing purposes, to detect disruptions to telecommunication equipment and to detect abuse of our telecommunication services. We delete this information routinely.
This information is used to create general aggregated profiles of our Website user base and is not used to create personalised user profiles. In case of disruption or misuse, we reserve the right to file a report with law enforcement agencies. We do not use this information for any other purpose(s) and do not share this information with any third parties, except as set out in the section titled “personal data”.
The majority of browsers are initially set up to accept cookies. The toolbar on most browsers will have a feature to tell you how to stop accepting new cookies, how to receive notification of new cookies, and how to disable any existing cookies. Please note, however, if you do disable, reject or stop cookies, you may not be able to take full advantage of all our Website features and services we would like to offer you.
2.8 We do not process:
2.8.1 any special categories of personal data (including 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); and
2.8.2 any information about criminal convictions and offences,
and you should not provide us with any such information through any of the Channels.
2.9 Keeping your data
We will not retain your personal information longer than is necessary to carry out the purpose for which it was given. We will hold onto the information you provide as needed to be able to provide services to you. We may also keep trend data from, for example, news update mailings, emails and phone calls.
If legally required or if it is reasonably necessary to meet regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our Terms and Conditions, we may also retain some of your information for a limited period of time as required, even after it is no longer needed to provide services to you.
3 The lawful bases by which we process your personal data
3.1 Your consent
By accepting the terms of this policy, you give us your express, freely given consent to process any of your personal data in accordance with the terms of this Notice. You may withdraw your consent given under this paragraph (in whole or in part) at any time by contacting [email protected]. You can also unsubscribe from different types of emails by following the unsubscribe link displayed on the bottom of each email. The withdrawal of your consent shall not affect the lawfulness of processing based on consent before withdrawal or the lawfulness of processing based on other lawful grounds as set out in 3.2.
3.2 Other lawful grounds
Without prejudice to the consent given by you under paragraph 3.1 above, Fitzpatrick Referrals may process your personal data in any circumstances where such processing is necessary:
3.2.2 to comply with any applicable law or regulation; or
3.2.3 for the purposes of the legitimate interests pursued by us or third parties. These legitimate interests include the purposes identified above but also include other general commercial interests and our internal administrative purposes.
4 Your rights as a data subject
4.1 Subject to any conditions or requirements set out in the GDPR or other applicable law or regulation, Fitzpatrick Referrals hereby informs you that you may have the following rights in relation to the personal data we hold about you:
4.1.1 the right to request a copy of your personal data held by us;
4.1.2 the right to correct any inaccurate or incomplete personal data held by us;
4.1.3 the right to request that we erase your personal data;
4.1.4 the right to request that we restrict the processing of your data (as set out in the GDPR);
4.1.5 the right to have your personal data transferred to another organisation;
4.1.6 the right to object to certain types of processing of your personal data by us; and
4.1.7 the right to complain.
4.2 In order to make an enquiry about any of these rights please email [email protected] or write to The Data Controller, Fitzpatrick Referrals Limited, Halfway Lane, Eashing, Surrey, GU7 2QQ. Please indicate your country of residence in your correspondence.
5 Transfer of your information to other countries
Information collected or received by Fitzpatrick Referrals in connection with the Online Services may be transferred to other countries and jurisdictions within the EEA or which the EU Commission has approved as having an adequate level of protection.