Introduction

Argyll Covenant Advisory Limited, also trading as Argyll Covenant, is strongly committed to protecting Personal Data.  This privacy statement sets out how and why we collect and use Personal Data from individuals, our clients, suppliers or others in operating our business.  Personal Data means information relating to individuals who can be identified or who are identifiable, directly or indirectly, from the information in question.  Our aim is to only collect and process Personal Data lawfully, fairly and in a transparent manner.  We will only use Personal Data as set out in this statement or as stated when collected.

Policy key definitions:

  • Argyll”, “our”, “us”, or “we” refer to Argyll Covenant Advisory Limited (Company number 8670455 and registered address 207 Regent Street, London, W1B 3HH)
  • you”, “your” refer to the person(s) who are the subject of the Personal Data.
  • GDPR” means the General Data Protection Regulation.
  • DPA” means the Data Protection Act 2018
  • ICO” means the Information Commissioner's Office.
  • Cookies” mean small text files stored on a user’s computer or device.

Why we process your personal information

Under the GDPR we control and/or process Personal Data electronically using the following lawful bases:

  • Legal obligation – to comply with the legal and regulatory obligations to which we are subject as a business.
  • Contract – to comply with our contractual duties to you.
  • Consent – where you have freely given consent at the time your personal data was provided to us.
  • Legitimate interests – to pursue the legitimate interests of our business including to provide our services, to develop or protect our business, or to keep people informed about relevant products and services.   We are required to balance your interests against ours in the use of your data and we would not process your data where our interests are overridden by your own.

Your individual rights

The GDPR provides the following rights for individuals:

  • The right to be informed
  • The right of access
  • The right to rectification
  • The right to erasure
  • The right to restrict processing
  • The right to data portability
  • The right to object
  • The right not to be subject to automated decision making and profiling.

More details on your rights can be found on the ICO’s website at:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/

If we feel we have a legal right not to deal with any request from you, or to action it in different way to how you have requested, we will inform you of this at the time.

If you have provided consent for the processing of your data you have the right (in certain circumstances) to withdraw that consent at any time which will not affect the lawfulness of the processing before your consent was withdrawn.

You have the right to lodge a complaint to the ICO if you believe that we have not complied with the requirements of the GDPR or DPA with regard to your Personal Data.  The ICO can be contacted through their website at:

https://ico.org.uk/global/contact-us/

Internet cookies

Our website uses cookies, as most websites do, to help provide you with the best experience we can. Cookies are small text files that are placed on your computer or mobile phone when you browse websites. 

We do not use cookies to:

  • Collect any personally identifiable information
  • Collect any sensitive information
  • Pass data to advertising networks
  • Pass personally identifiable data to third parties

If the settings on your internet browser are adjusted to accept cookies, we take this, and your continued use of our website, to mean that you consent to this.  Should you wish to remove or not use cookies from our site you can change your browser settings, however doing so may mean that our site will not work as you would expect.

Data security and protection

We ensure the security of any Personal Data we hold by using secure data storage technologies and procedures in how we store, access and manage that information.  

Your Personal Data is stored on secure, cloud-based servers located in the European Economic Area (‘EEA’).  We may transfer data outside the UK and EEA to third parties who perform certain functions such as marketing to support the operation of our business, in which case we will ensure that all Personal Data is subject to sufficient protections and any such transfer is lawful.  Marketing messages may contain mechanisms to track ‘click through’ activity.  Any email marketing messages we send you will include a method to easily withdraw your consent (unsubscribe).

If in the future we intend to process your Personal Data for a purpose other than that for which it was collected we will provide you with information on that purpose and any other relevant information at that time.

Changes to this policy

We will keep this privacy statement under review and may make changes from time to time to ensure Argyll remains compliant with the GDPR.

Data controller and contact information

Argyll Covenant Advisory Limited is the controller and processor of data for the purposes of the DPA and GDPR.

We are not required to appoint a Data Protection Officer.  You should address any questions or concerns as to how your data is processed to us using the following contact details:

Data Protection
+44(0)1189 001201
dataprotection@argyllcovenant.com

You should also make contact with us as soon as possible if you become aware of any unauthorised disclosure of your Personal Data, so that we may investigate and fulfil our own regulatory obligations.