This page explains how we use any personal information we collect from you through our website.
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This website might contain links to third-party websites. Clicking on them may allow third-parties to collect or share data about you. We do not have any control over third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you decide to visit.
When we contact you by email we might use third-party communications and client-related software.
This website is not intended to be used by children and we do not knowingly collect data related to children.
The data that might be collected might include personal data, personal information, and information that an individual might be identified (this does not include data where the identity has been removed (anonymous data).
We may collect, use, store, and transfer different kinds of personal data about you which might be grouped together as follows:
Identity Data includes your full name, maiden name, first, middle and last names, username or similar identifier, marital status, title, date of birth and gender, company names and job title.
Contact Data included addresses, email addresses and telephone numbers
Financial Data includes bank account and payment card details, insurance, pension details, source of funds and source of wealth.
Transactional Data includes details about payments to and from you, other details of legal services and other services to you, that you have purchased from the firm and services you have supplied to us.
Technical Data includes data such as browser type, version, time zone, setting and location, operating systems an platform, etc
Case Data includes all information, documents, and records regarding your case or matters the firm is dealing with.
Profile Data includes responses to questionnaires, notes to inquiries, to survey responses, purchases made by you and usage data as to how you use our legal services.
Marketing Data includes your interactions with emails, newsletters, etc.
We do not collect any Special Category Personal Data (such as details about your race etc.) nor do we collect any information about offences (save in relation to information received from you, or your matter, or in relation to compliance checks.)
Your Failure to Provide Personal Data
Where we need to collect personal data by law (for anti-money laundering, financial sanctions, proceeds of crime act, compliance and risk assessments, sources of funds and sources of wealth, etc) and under the firm’s terms and conditions of business and you fail to provide the data requested, we will not be able to perform the contract for services. Thus, if you fail to provide the requested information we will have to cancel or terminate our retainer, we will notify you if this is the case at the time, but we may not be able to state the reason why, due to statutory provisions and regulation.
Prior to you being on-boarded for any of the firm's services, you, will asked to provide information and certified documentation, so that the firm can comply with its legal and regulatory requirements. These legal and regulatory requirements include undertaking due diligence and KYC (know your client), which includes source of funds and source of wealth checks and banking checks.
To enable us to undertake these tasks we will ask you to complete a questionnaire, ask you to provide primary documents and or certified copies of these documents. You can certify copies of primary documents with a solicitor or at the post office. Or the originator of the document could certify it e.g. (payslips or your mortgage provider). This will be at your own cost (this is a cost not recoverable from us).
We also ask you to complete electronic bio-metric identification and address verification checks (which will also include a Political Exposed Person (PEP) check, Sanctions Check, there might also be a credit screen included in the check.) You will be asked to undertake a source of wealth and source of funds check to include open banking check in relation to all your accounts in all jurisdictions.
If you have a business or an entity, we will have to identify and verify the business and individuals, who are directors, persons of significant control, owners controllers, persons who have influence, referrers, compliance officers, accountants, counterparts and third parties.
If there are any discrepancies with the information held by Companies House we have reporting responsibilities, and we are required to report any discrepancies with Company House.
We are also required to undertake counter party checks and third party checks.
If you mention another person or entity to include a friend, family member, business or entity associate, solicitor, barrister, expert and etc, you should notify them prior to providing us with their details, and you should provide them with a copy of this privacy policy. You will be presumed to have provided them with a copy of this privacy policy prior to you providing their details to us and it will be presumed that you have obtained their consent to share their data and for us to undertake our checks on them.
If you wish someone to attend mediation, you should provide them with a copy of this privacy policy and inform them that we will have to conduct checks in relation to them and seek their consent. Once you provide us with details of another person or entity we will contact them to undertake our checks and we will inform them that you have provided their details.
If you are a relevant person for AML auditing or other AML services, we will conduct checks on the entity, the Ultimate Beneficial owners, the owners, and controllers, the referring staff, other staff members and accountants (not inclusive list). The checks will include Source of Funds and could include Source of Wealth checks as well as Know Your Client and Know Your Business and Due Diligence Checks. We will also ask you to complete questionaires.
Our checks will have to be completed to our satisfaction before we enter into a relationship with you.
We are able to charge an admin fee plus vat** on undertaking the due diligence and KYC in relation to each individual, business or entity.
We may need to undertake checks on several people, all of which we have to be satisfied with.
If you or others are uncooperative with the checks we will not be able to proceed.
If there is a conflict of interest we will not be able to inform you of the reason.
You are not entitled to the results of these checks, or the checks in relation to others, as this could be a breach of the law.
Prior to onboarding there is no business relationship between this firm and you. So during pre-onboarding you are not a client of the firm.
** vat is currently charged at 20%
This might occur:
Direct interactions with you: you may give us your identity, contact, case details, and financial data, during meetings, completing various forms, during telephone conversations, in correspondence, or documents you provide to us in person or produce or supply, or forward to us by email or otherwise. This can include personal data that you provide when you:
We may need to transfer your personal information outside the United Kingdom and/or the European Economic Area (EEA) in order to provide our services as set out in this privacy policy. We use third party software providers to provide certain IT Services, Case Management Systems, Newsletter Services, Email Services, Social Media Services, Anti-money laundering, Sanctions compliance and risk checks and Cloud Backup Services - which may mean that your personal information is shared with them.
We may also have to share your personal information with third parties:
We may also have to share your personal information with government agencies, courts, regulators, other third parties and in relation to debt collection and fee recovery.
We will take reasonable measures to ensure those third-party legal service providers are compliant with data protection law.
Third parties or publicly available sources. The firm might receive personal data about you from various third parties and public sources
This website uses Mouseflow: a website analytics tool that provides session replay, heatmaps, funnels, form analytics, feedback surveys, and similar features/functionality. Mouseflow may record your clicks, mouse movements, scrolling, form fills (keystrokes) in non-excluded fields, pages visited and content, time on site, browser, operating system, device type (desktop/tablet/phone), screen resolution, visitor type (first time/returning), referrer, anonymized IP address, location (city/country), language, and similar meta data. Mouseflow does not collect any information on pages where it is not installed, nor does it track or collect information outside your web browser. If you'd like to opt-out, you can do so at https://mouseflow.com/opt-out. If you'd like to obtain a copy of your data, make a correction, or have it erased, please contact us first or, as a secondary option, contact Mouseflow at privacy@mouseflow.com.
For more information, see Mouseflow’s Privacy Policy at https://mouseflow.com/legal/company/privacy-policy/
For more information on Mouseflow and GDPR, visit https://mouseflow.com/legal/gdpr/.
For more information on Mouseflow and CCPA/VCDPA visit https://mouseflow.com/legal/ccpa.
The Firm will only use your personal data when the law allows us to. Usually we will use your personal data:
Generally, we do not rely on consent as a legal basis for processing your personal data.There are six lawful bases for using data:
Kindly, note that the firm might process your personal data for more than one lawful ground depending on the purpose for which the firm is using your data. Which could include:
The above is not an exhaustive list of purposes, and more than one basis will apply. Generally, we do not solely rely on consent.
When you provide us with personal data, you are consenting to its collection and use in accordance with this privacy notice. If you provide us with personal data on behalf of someone else, you are confirming that you have given them the information in this privacy notice and that they have agreed for us to use their personal data in the way we describe in this privacy policy.
Your data can be used for another purpose if the firm feels that it is reasonably necessary to use it for another purpose. We can provide you with an explanation for the new purpose and how that is compatible with the original purpose. 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 might process your personal data without your knowledge or consent, in compliance with rules, where this is required and permitted by law, and or where exemptions apply.
The length of time we hold your data will depend on the type of relationship we have with you, and the time necessary to fulfil that purpose, including any legal, accounting or reporting requirements and legal requirements our insurers, and legal requirements.
We retain your personal data for no longer than is necessary for which it was provided. What this means in practice will vary between different types of data. In determining the relevant retention periods, we take into account factors:
We will securely destroy your personal data when it is no longer needed.
We are in the process of digitalising paper files. The paper files will be destroyed after they have been digitalised without further notice to you.
In many situations where you are a client it could be six years from the conclusion of your matter or it could be longer.
Compliance information/ documentation will be destroyed after 5 years of the firm ceasing work with you.
We might have to share your personal data with certain parties as identified in this privacy notice.
We require all third parties to respect the security of your personal data in accordance with the law.
We may change this policy wording 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.
Please keep us informed if your personal data changes during your relationship with us.
Accessing your personal information
You have the following rights:
If you would like to do so or if you have any queries about this policy, please write to: Data Protection Manager, Alexander Christian Solicitors, Harrow Business Centre, 429-433 Pinner Road, North Harrow, HA1 4HN.
The firm will try to respond to all legitimate requests within one month. Where it is likely to take longer or there are multiple requests we will update date further.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for date protection issues
www.ico.org.uk
We would however appreciate the opportunity to hear your concerns before you approach the ICO, so please contact us initially.
You may wish to consider our Client Due Diligence Page on this website
