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Privacy Policy 

1.         Introduction

 1.1 We are London Executive Offices Ltd (referred to as LEOweus and our in this Privacy Policy), a company incorporated in England with company registration number 03584248 and whose registered office address is 33 St. James's Square, London, SW1Y 4JS.

1.2 The information set out in this Privacy Policy is provided to individuals whose personal data we process (you or your) as data controller, in compliance with our obligations under Articles 13 and 14 of the General Data Protection Regulation 2016/679 (GDPR).

1.3 To make this information clear, we have divided the data we receive into the following groups and corresponding Schedules, where each of which refers to: the particular category of information we collect and retain; from where we obtain the information from; the purpose and legal basis of processing and to whom we will (if applicable) disclose the information:

Schedule 1       Data about our clients, and all individuals in respect of whom we have acquired personal information in connection with any products or services offered by us (including directors, shareholders, consultants, employees or other personnel of our clients)

Schedule 2       Data about our suppliers and supplier personnel

Schedule 3       Data about individuals who apply for employment or work experience with us

Schedule 4       Data about our directors and staff, consultants, those on work experience, temporary staff, former directors and staff, next of kin, spouses, beneficiaries

 1.4 In addition to the above, individuals who interact with us in any of the above capacities should also refer to the following:

Schedule 5         Data collected about staff and visitors to our offices/premises

Schedule 6         Data collected through recording of telephone calls

2.         Data controller details

2.1 We are the data controller in relation to the processing of the personal information that you provide to Our contact details are as follows:

2.1.1 Address: 33 St. James's Square, London, SW1Y 4JS

2.1.2 Telephone number: 020 3008 8888

2.1.3 Email address: dataprotection@leo.co.uk (please include “Personal Data Request” in your subject heading to ensure it receives the correct attention).

2.2 Our Data Protection Officer is Louise Willer

3.         International transfers

 We will not transfer personal data relating to you to a country which is outside the European Economic Area (EEA) unless:

3.1 the country or recipient is covered by an adequacy decision of the Commission under GDPR Article 45;

3.2 appropriate safeguards have been put in place which meet the requirements of GDPR Article 46 (for example using the European Commission’s Standard Model Clauses for transfers of personal data outside the EEA); or

3.3 one of the derogations for specific situations under GDPR Article 49 is applicable to the transfer. These include (in summary):

3.3.1 the transfer is necessary to perform, or to form, a contract to which we are a party:

3.3.1.1 with you; or

3.3.1.2 with a third party where the contract is in your interests;

3.3.2 the transfer is necessary for the establishment, exercise or defence of legal claims;

3.3.3 you have provided your explicit consent to the transfer; or

3.3.4 the transfer is of a limited nature and is necessary for the purpose of our compelling legitimate interests.

4.         Retention of personal data

 Our retention and deletion policy can be found here.

 5.         Your rights in respect of your personal data

5.1 You have certain rights under existing data protection laws, including the right to (upon written request) access a copy of your personal data that we are processing. From 25 May 2018, in accordance with the GDPR:

5.1.1 you will have the following rights:

5.1.1.1 right to access: the right to request certain information about, access to and copies of the personal information about you that we are holding (please note that you are entitled to request one copy of the personal information that we hold about you at no cost, but for any further copies, we reserve the right to charge a reasonable fee based on administration costs); and

5.1.1.2 right to rectification: the right to have your personal information rectified if it is inaccurate or incomplete; and

5.1.2 in certain circumstances, you will also have the following rights:

5.1.2.1 right to erasure/right to be forgotten: the right to withdraw your consent to our processing of the data (if the legal basis for processing is based on your consent) and the right to request that we delete or erase your personal information from our systems (however, this will not apply if we are required to hold on to the information for compliance with any legal obligation or if we require the information to establish or defend any legal claim);

5.1.2.2 right to restriction of use of your information: the right to stop us from using your personal information or limit the way in which we can use it;

5.1.2.3 right to data portability: the right to request that we return any information you have provided in a structured, commonly used and machine-readable format, or that we send it directly to another company, where technically feasible; and

5.1.2.4 right to object: the right to object to our use of your personal information including where we use it for our legitimate interests or for marketing purposes.

5.2 Please note that if you withdraw your consent to the use of your personal information for purposes set out in our Privacy Policy, we may not be able to carry out our contractual obligations to you or provide you with access to all or certain parts of our services.

5.3 If you consider our use of your personal information to be unlawful, you have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office. Please see further information on their website: ico.org.uk

6.         Automatic decision making

6.1 We do not make decisions based solely on automated data processing, including profiling.

 Security

6.2 We keep your information protected by taking appropriate technical and organisational measures to guard against unauthorised or unlawful processing, accidental loss, destruction or damage. For example:

6.2.1 where appropriate, data is encrypted when transiting on our system or stored on our databases;

6.2.2 we have implemented safeguards in relation to access and confidentiality in order to protect the information held within our systems; and

6.2.3 we frequently carry out risk assessments and audits to monitor and review threats and vulnerabilities to our systems to prevent fraud.

6.3 However, while we will do our best to protect your personal information, we cannot guarantee the security of your information which is transmitted via an internet or similar connection. It is important that all details of any username, password and/or other identification information created to access our servers are kept confidential by you and should not be disclosed to or shared with anyone.

7.         Changes to this Privacy Policy

 We may amend this Privacy Policy from time to time, for example to keep it up to date, to implement minor technical adjustments and improvements or to comply with legal requirements. We will always update this Privacy Policy on our website, so please try to read it when you visit the website (the “last updated” reference tells you when we last updated our Privacy Policy).

 

Last updated May 2018