Privacy Statement

Group Privacy Statement

Introduction

Langham Hall and the Langham Hall Group (as defined and referred to in the Important Information section of the web site) are committed to maintain the privacy and confidentiality of personal data.

We endeavour to make sure that any personal data we collect about you will be held and processed strictly in accordance with the data Protection Act 1998 (DPA) and, on and from 25 may 2018, the European General Data Protection Regulation (GDPR).  The terms “Personal Data”, Data Controller” and “processing” have the meanings given to them by the GDPR (which can be accessed here (  http://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX%3A32016R0679). Unless otherwise indicated.

Circumstances under Which Langham Hall Collects Personal Data

Langham Hall collects and processes your Personal Data in a number of ways. 

A. Marketing - You are browsing our website, enquiring about our services; receiving our marketing communications or otherwise interacting with us as a prospective, current or former customer other than in connection with ongoing services we are providing to you or your organisation;

B. Client - You are a client of Langham Hall;

C. Potential Employee - You are applying for or enquiring about a job at Langham Hall;

D. Employee - You are an employee or contractor of Langham Hall;

E. Supplier - You are a supplier or service provider to Langham Hall.

A. Marketing

Scope

This Privacy Statement demonstrates how Langham Hall handles the Personal Data you provide to us, or which we collect about you, in the following ways (Your Data):

  • By you submitting information to us through our website , for example, through the “Contact Us”  page (Website User Data);

  • through your use of our other marketing resources, such as events which we run or sponsor (Marketing Data);

  • from what we learn about you from your visit to our websites (Website Background Data); and/or

  • by you otherwise interacting with us a prospective, current or former customer, (for example, where you provide your business card to us) (Prospect Data).

Identity & Contact Details of Data controller

For the purposes of the DPA and the GDPR, Langham Hall is the controller of Your Data.  If you have any queries about our use of Your Data, please contact us at data-processing@langhamhall.com or at the address below and we will do our best to deal with your  query as soon as possible.

Langham Hall UK LLP
5 Old Bailey,
London
EC4M 7BA.

FAO: Data Processing

What We Use Your Data for

Data

Purpose

Legal Basis

Marketing Data 

Prospect Data

To keep you informed of any activities undertaken by us which we believe may be of interest to you and this use may include sending you email and postal marketing from time to time

Consent – this will be  requested either when you submit Your Data to us or, if we have received Your Data indirectly, by way of an email sent prior to us sending you any marketing communications.

Website Background Data

Website analytic purposes.  For further details on the technology we use in order to analyse our website’s performance, please see our cookies policy here.

Consent – this will be obtained when you click on the banner at the top of our website to accept certain cookies.

Legitimate interest of Langham Hall (see our cookies policy for further information)

Marketing Data

Prospect Data

To provide you with the newsletter(s) or information you have requested

Performance of a contract

Marketing Data

Website Background Data

Prospect Data

 

To respond to requests for information from regulated bodies or government agencies

Compliance with a legal obligation

Website User Data

Prospect Data

To respond to an enquiry you have submitted

Legitimate interest  – it may be necessary for us to process Your Data in order to reply or respond to your enquiry

Who we share Your Data with

Please note that we may on occasion be required to share your information with the following categories of recipients:

  • Langham Hall offices and our associated firms. A full list of all of the entities within the Langham Hall group is listed on our website.

  • Third parties who provide services on our behalf. For example, we use third parties such as MailChimp to provide marketing automation services. A full list of all our third party service providers is available on request.

We have taken steps to ensure that all such entities keep Your Data confidential and secure and only use it for the purposes that we have specified and have informed you of.  Our service providers are subject to data processing agreements which are, or are in the process of being updated to become, compliant with the requirements set out in the GDPR.  Further details regarding any third parties who are located outside the EEA are set out below.

In relation to any other third parties, we will only disclose your information in the following circumstances:

  • where you have given your consent;

  • where we are required to do so by law or enforceable request by a regulatory body;

  • where it is necessary for the purpose of, or in connection with legal proceedings or in order to exercise or defend legal rights; and

  • if we sell our company, go out of business, or merge with another company.

International Transfers

In certain circumstances, we may transfer Your Data to countries outside the EEA, which may not adhere to the same levels of data protection to which countries within the EEA are subject.  Any such transfers are, at all times, made in accordance with the DPA and the GDPR.  Details of the circumstances and mechanisms in place to ensure compliance are set out below:

  • Langham Hall Group Companies in the Channel Islands, Hong Kong  and the US

We have offices in Jersey, Guernsey and the US.  Our central servers are located in the UK. The European Commission has ruled that Jersey, Guernsey and the US (limited to the Privacy Shield framework) offer adequate levels of data protection in their domestic legislation and transfers to these jurisdictions are, therefore, permitted under the DPA and GDPR.

We also have offices in Hong Kong & Singapore. All Personal Data used by this office is held on Langham Hall’s central servers located in the UK.

  • IT Resource Manager (“ITRM”)

We use ITRM to manage our website.  ITRM is based in the United Kingdom and use a data centre based in the United Kingdom to host our website.  The Langham Hall website does not have any marketing automation services built in and as such; Your Data is not stored here.  ITRM’s privacy policy can be viewed here.

  • MailChimp

We use MailChimp to provide marketing automation services. If you have consented to Langham Hall using Your Data to send you marketing communications, Your Data may be transferred to MailChimp’s servers in the United States.  The company that operates MailChimp, The Rocket Science Group LLC, participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. Transfers of Personal Data to MailChimp in the United States are therefore made subject to appropriate safeguards in accordance with the DPA and the GDPR. MailChimp’s privacy policy can be viewed here.

 

Retention Period

Your Data will be stored for a maximum period of 6 years, after which time it will be destroyed if it is no longer required for the lawful purpose(s) for which it was obtained. If you consent to marketing, any information we use for this purpose will be kept with us until you notify us that you no longer wish to receive this information. unless we request your consent to store it for a longer period.

Your Rights in relation to Your Data

  • Under the GDPR, you will have the following rights in relation to how we process Your Data:

    • Right to request access – you may obtain confirmation from us as to whether or not Your Data is being processed and, where that is the case, access to Your Data.

    • Right to rectification and erasure – you have the right to obtain rectification of inaccurate personal data we hold concerning you and to obtain the erasure of Your Data without undue delay in certain circumstances.

    • Right to restriction of processing or to object to processing – you may require us to restrict the processing we carry out on Your Data in certain circumstances or to object to us processing Your Data.

    • Right to data portability – you have the right to receive Your Data in a structured, commonly used and machine-readable format.

    • Right to withdraw consent – where you have provided your consent to us processing Your Data, you have the right to withdraw your consent at any time. This can be done by emailing data-processing@langhamhall.com at any time or by clicking the “unsubscribe” link on any marketing communications you receive from us.

    • Right to lodge a complaint – you may lodge a complaint with any supervisory authority in the EU. The supervisory authority for the United Kingdom is the Information Commissioner’s Office.

For further information on your rights, please see the Information Commissioner’s website here.

Additional Information

  • There is no statutory or contractual requirement for you to provide Your Data to us and you are not obliged to do so. Please note, however, that we may not be able to provide you with the services you have requested, such as to receive our newsletter, if you do not provide your contact details.  As set out in our cookies policy, our website may not be able to function fully if you do not agree to certain cookies being set on your computer.

  • We do not undertake automated decision-making or profiling on Your Data.

  • We keep our privacy policy under constant review and may change it from time to time to reflect our practices or to remain compliant with relevant legislation. We will notify you of any material changes to our privacy policy via a notification on our website. Your continued use of this website or our other marketing services, following the posting of changes to these terms, will mean you accept these changes.

Security of personal information

  • We recognise the need to ensure that personal information gathered via this website remains secure. Our site has security measures in place to protect against the loss, misuse and alteration of the personal information under our control. Our security measures include the use of a hardware firewall to prevent unauthorised access. You acknowledge that although we exercise adequate care and security there remains a risk that information transmitted over the Internet and stored by computer may be intercepted or accessed by an unauthorised third party.

Data obtained indirectly

  • In some circumstances, we may obtain Personal Data about you from other sources.  This information may include your name, contact details and job title, which we obtain from third party sources such as Preqin, organisers of events we sponsor or other publicly available sources, such as your company’s website.

B. Client  

Please note that we are in the process of updating our policy regarding client Personal Data in order to ensure that it is compliant with the GDPR before May 2018.  Please contact the Langham Hall relationship manger responsible for your matter or contact us at data-processing@langhamhall.com for further information.

C. Potential Employee

Please note that we are in the process of updating our policy regarding job candidate Personal Data in order to ensure that it is compliant with the GDPR before May 2018. 

D. Employee

Please refer to the privacy policy set out in your employee handbook for information on how we protect Personal Data relating to our employees and contractors.

E. Supplier

Please note that we are in the process of updating our policy regarding supplier Personal Data in order to ensure that it is compliant with the GDPR before May 2018.