PRIVACY POLICY
Updated: 3rd January 2023
This privacy policy applies between you, the User of this Website, and Sypro Financial Consultancy Limited, the owner and provider of this Website. Sypro Financial Consultancy Limited takes the privacy of your information very seriously. This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website.
This privacy policy should be read alongside, and in addition to, our Terms and Conditions, which can be found here >
Please read this privacy policy carefully.
Definitions and interpretation
1. In this privacy policy, the following definitions are used:
Data
collectively all information that you submit to Sypro Financial Consultancy Limited via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;
Cookies
a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies);
Data Protection Laws
any applicable law relating to the processing of personal Data, including but not limited to the GDPR, and any national implementing and supplementary laws, regulations and secondary legislation;
GDPR
the UK General Data Protection Regulation;
Sypro Financial Consultancy Limited, we or us
Sypro Financial Consultancy Limited, a company incorporated in England and Wales with registered number 13073386 whose registered office is at Kings Lodge, London Road, West Kingsdown, Sevenoaks, Kent, TN15 6AR;
UK and EU Cookie Law
the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011 & the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2018;
User or you
any third party that accesses the Website and is not either (i) employed by Sypro Financial Consultancy Limited and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Sypro Financial Consultancy Limited and accessing the Website in connection with the provision of such services; and
Website
the website that you are currently using,
www.syprofinancial.co.uk, and any sub-domains of this site unless expressly excluded by their own terms and conditions.
2. In this privacy policy, unless the context requires a different interpretation:
a. the singular includes the plural and vice versa;
b. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;
c. a reference to a person includes firms, companies, government entities, trusts and partnerships;
d. "including" is understood to mean "including without limitation";
e. reference to any statutory provision includes any modification or amendment of it;
f. the headings and sub-headings do not form part of this privacy policy.
Scope of this privacy policy
3. This privacy policy applies only to the actions of Sypro Financial Consultancy Limited and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.
4. For purposes of the applicable Data Protection Laws, Sypro Financial Consultancy Limited is the "data controller". This means that Sypro Financial Consultancy Limited determines the purposes for which, and the manner in which, your Data is processed.
Data collected
5. We may collect the following Data, which includes personal Data, from you:
a. name;
b. job title;
c. profession;
d. contact Information such as email addresses and telephone numbers;
e. IP address (automatically collected);
f. a list of URLs starting with a referring site, your activity on this Website (such as clicks, internal links, pages visited, scrolling, searches and timestamps), and the site you exit to (automatically collected);
g. information about your browser, network, and device (automatically collected);
in each case, in accordance with this privacy policy.
How we collect Data
6. We collect Data in the following ways:
a. data is given to us by you; and
b. data is collected automatically.
Data that is given to us by you
7. Sypro Financial Consultancy Limited will collect your Data in a number of ways, for example:
a. when you contact us through the Website, by telephone, post, e-mail or through any other means;
b. when you register with us and set up an account to receive our products/services;
c. when you complete surveys that we use for research purposes (although you are not obliged to respond to them);
d. when you elect to receive marketing communications from us;
e. when you use our services;
in each case, in accordance with this privacy policy.
Data that is collected automatically
8. To the extent that you access the Website, we will collect your Data automatically, for example:
a. we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.
b. we will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, headed "Cookies".
Our use of Data
9. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:
a. internal record keeping;
b. transmission by email of marketing materials that may be of interest to you;
in each case, in accordance with this privacy policy.
c. To share with Squarespace, our website analytics provider, to learn about site traffic and activity,
10. We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed "Your rights" below).
11. For the delivery of direct marketing to you via e-mail, we'll need your consent, whether via an opt-in or soft-opt-in:
a. soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under "soft opt-in" consent, we will take your consent as given unless you opt-out.
b. for other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we'll provide.
c. if you are not satisfied with our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed "Your rights" below.
12. When you register with us and set up an account to receive our services, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
13. We may use your Data to show you Sypro Financial Consultancy Limited adverts and other content on other websites. If you do not want us to use your data to show you Sypro Financial Consultancy Limited adverts and other content on other websites, please turn off the relevant cookies (please refer to the section headed "Cookies" below).
Who we share Data with
14. We may share your Data with the following groups of people for the following reasons:
a. our employees, agents and/or professional advisors - information is only every shared with employees of the company in the normal routine of their role to process the information for the required request;
b. External Third Parties Service
· Providers who provide IT and system administration services.
· HM Revenue & Customs, regulators and other based in the United Kingdom who require reporting of processing activities in certain circumstances.
in each case, in accordance with this privacy policy.
Keeping Data secure
15. We will use technical and organisational measures to safeguard your Data, for example:
a. access to your account is controlled by a password and a user name that is unique to you.
b. we store your Data on secure servers.
17. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address info@syprofinancial.co.uk
18. If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
Data retention
19. We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
20. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
by law we have to keep basic information about our customers (including contact, identity, financial and transaction data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Your legal rights below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your rights
21. You have the following rights in relation to your Data:
a. Right to access - the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is "manifestly unfounded or excessive." Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
b. Right to correct - the right to have your Data rectified if it is inaccurate or incomplete.
c. Right to erase - the right to request that we delete or remove your Data from our systems.
d. Right to restrict our use of your Data - the right to "block" us from using your Data or limit the way in which we can use it.
e. Right to data portability - the right to request that we move, copy or transfer your Data.
f. Right to object - the right to object to our use of your Data including where we use it for our legitimate interests.
22. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: info@syprofinancial.co.uk
23. If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner's Office (ICO). The ICO's contact details can be found on their website at https://ico.org.uk/.
Our data protection registration number is: ZA829215
24. It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.
No fee required – with some exceptions
25. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
26. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
27. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Links to other websites
28. This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.
Changes of business ownership and control
29. Sypro Financial Consultancy Limited may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Sypro Financial Consultancy Limited. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us.
30. We may also disclose Data to a prospective purchaser of our business or any part of it.
31. In the above instances, we will take steps with the aim of ensuring your privacy is protected.
Cookies
32. This Website may place and access certain Cookies on your computer. Sypro Financial Consultancy Limited uses Cookies to improve your experience of using the Website and to improve our range of services. Sypro Financial Consultancy Limited has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.
33. All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.
34. Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling Sypro Financial Consultancy Limited to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.
35. This Website may place the following Cookies:
Type of Cookie
Purpose
Strictly necessary cookies
These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
Analytical/performance cookies
They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies
These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting cookies
These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
36. You can find a list of Cookies that we use in the Cookies Schedule below.
37. You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.
38. You can choose to delete Cookies at any time; however, you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.
39. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.
40. For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.
General
41. You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.
42. If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.
43. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
44. This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.
Changes to this privacy policy
45. Sypro Financial Consultancy Limited reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations. You may contact Sypro Financial Consultancy Limited by email at info@syprofinancial.co.uk.
Cookies
Below is a list of the cookies that we use. We have tried to ensure this is complete and up to date, but if you think that we have missed a cookie or there is any discrepancy, please let us know.
Strictly necessary
We use the following strictly necessary cookies:
Analytical/performance
We use the following analytical/performance cookies:
Description of Cookie
Purpose
Session Cookies
We use this session cookie to remember you and maintain your session whilst you are using our website. More details can be found here https://support.squarespace.com/hc/en-us/articles/360001264507#toc-functional-and-required-cookies
Functionality
We use the following functionality cookies:
Description of Cookie
Purpose
Analytical Cookies
We use this cookie to help us analyse how users use the website
Targeting
We use the following targeting cookies:
Description of Cookie
Purpose
Functional Cookies
We use this cookie to identify your computer and analyse traffic patterns on our website
Description of Cookie
Purpose
Targeting Cookies
We use this cookie to enable us to show you adverts while you are browsing our website and other websites on the internet
Queries or concerns
To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact our data representative Ryan Wakeman on info@syprofinancial.co.uk
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England, UK.
Attribution
This privacy policy and cookies policy was created using a document from Rocket Lawyer (https://www.rocketlawyer.com/gb/en)