Privacy Policy

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation (GDPR), which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.

Key terms

The key terms used in this policy:

We, us, our                A Dandy Wren Ltd

Personal information  Any information relating to an identified or identifiable individual

Personal information we collect about you

We may collect and use the following personal information about you:

  • Your name and contact information, including email address and telephone number and company details if applicable
  • Information to enable us to check and verify your identity, e.g. your date of birth
  • Your billing information, transaction and payment card information
  • Your professional or personal online presence, e.g. LinkedIn profile, if you share it with us
  • Your contact history, transaction and instruction history with us
  • Your nationality and immigration status and information from related documents, such as your passport or other identification, and immigration information, e.g. if you are a potential tenant applying for a tenancy
  • Information to enable us to undertake Anti Money Laundering and Terrorist Financing electronic checks on you
  • Information about how you use our website, IT, communication and other systems
  • Your responses to surveys, competitions and promotions

This personal information is required to provide our services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing services to you.

How and why we use your personal information

Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:

  • To comply with our legal and regulatory obligations;
  • For the performance of our contract with you or to take steps at your request before entering into a contract;
  • For our legitimate interests or those of a third party; or
  • Where you have given consent.

When we use and process your personal information for our legitimate interest, we will consider and balance any potential impact on you and your rights under data protection and any other relevant laws. Our legitimate business interests do not automatically override your interests – we will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your valid consent or are otherwise required or permitted to by law).

The explanations below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for

Our reasons for doing so

To provide services to you For the performance of our contract with you or to take steps
steps at your request before entering into a contract

To prevent & detect fraud against you or A Dandy Wren For our legitimate interests or those of a third party, i.e. to minimise fraud that could be damaging for us & for you

Conducting checks to identify our customers & identity To comply with our legal and verify their regulatory obligations

Screening for financial and other sanctions or embargoes

Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business eg under health and safety regulation or rules issued by our professional regulator

Gathering and providing information required by or relating to To comply with our legal and regulatory obligations audits, enquiries or investigations by regulatory bodies

Ensuring business policies are adhered to, e.g. policies covering For our legitimate interests or those of a third party, i.e. to security and internet use make sure we are following our own internal procedures so we can deliver the best service 

Operational reasons, such as improving efficiency, training & For our legitimate interests or those of a third party, i.e. deliver quality control the best service for you

Preventing unauthorised access and modifications to systems For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you

Updating and enhancing customer records For the performance of our contract with you or to take steps at your request before entering into a contract. To comply with our legal and regulatory obligations. For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders & new products

Statutory returns To comply with our legal and regulatory obligations

Ensuring safe working practices, staff admin & assessments To comply with our legal and regulatory obligations. For our
legitimate interests or those of a third party, e.g. to make sure
we are following our own internal procedures & working
efficiently so we can deliver the best service to you

Marketing our services to:  For our legitimate interests or those of a third party i.e. to
— existing and former customers;  i.e. to promote our business to existing former customers and
— third parties who have previously registered with us or contacts. For our legitimate interests, when such information is  
expressed an interest in our services;  in the public domain
— third parties with whom we have had no previous dealings

We do not collect, use or process special category personal information, such as racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic and biometric data, data concerning health, sex life or sexual orientation. 

Marketing communications

We may use your personal information to send you updates (by email, telephone calls, SMS or post) about our services, including exclusive offers.

We have a legitimate interest in processing your personal information for marketing purposes (see above ‘How and why we use your personal information’). This means we do not usually need your consent to send you marketing communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and never sell or share it with other organisations for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by:

You have the right to opt out of receiving marketing communications at any time by:

  • contacting us at info@adandywren.com

Who we share your personal information with

We routinely share personal information with:

  • Third parties we use to help deliver our services to you
  • Credit reference agencies;
  • Our banks;
  • Other companies within our group, to provide you with the same or closely related services;

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers (where possible) to ensure they can only use your personal information to provide services to us and to you.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

Where your personal information is held

Information may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).

How long your personal information will be kept

We will keep your personal information while you have an account with us or we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:

  • to respond to any questions, complaints or claims made by you or on your behalf;
  • to show that we treated you fairly;
  • to keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information typically this will be for 6 years.

When it is no longer necessary to retain your personal information, we will delete or anonymise it.

Your rights

You have the following rights, which you can exercise free of charge:

Access:
The right to be provided with a copy of your personal information (the right of access)

Rectification:
The right to require us to correct any mistakes in your personal information

To be forgotten:
The right to require us to delete your personal information—in certain situations

Restriction of processing:
The right to require us to restrict processing of your personal information—in certain circumstances, eg if you contest the accuracy of the data

Data portability
The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations

To object
The right to object:

  • at any time to your personal information being processed for direct marketing (including profiling);
  • in certain other situations to our continued processing of your personal information, eg processing carried out for the purpose of our legitimate interests.

How to complain

We hope that we can resolve any query or concern you may raise about our use of your information. (See How to contact us, below.)

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.

Changes to this privacy policy

This privacy notice was updated in August 2021.

We may change this privacy notice from time to time.

How to contact us

Please contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.

Our contact details are shown below:

A Dandy Wren

Registered Office Address:
13a Canonbury Yard, Building Two

190 New North Road
London
N1 7BJ

info@adandywren.com