PRIVACY NOTICE

Komodo Law is committed to protecting and respecting your privacy.

This privacy notice sets out how we use your personal data when you visit our website, when you make contact with us or when you engage us to provide you with legal services. It tells you about your privacy rights and how the law protects you.

There’s a lot of information here, but we want you to be fully informed about your rights and how we use your personal data. We’re providing information in sections so that you can click through and easily find what you need:

DEFINITIONS

‘We’ or ‘Us’ means Komodo Law, a company incorporated in England and Wales (company number 16094295).

Personal data means electronic or hard copy that identifies you personally or which relates to you when you are identifiable.

Special categories of personal data means sensitive information relating to you, such as health records, racial or ethnic origin, sexual orientation, religious beliefs, criminal convictions, trade union membership and genetic or biometric data.

CONDITIONS FOR PROCESSING DATA

We are only entitled to hold and process your data where the law allows us to. The current law on Data Protection sets out different reasons for which we may collect and process your personal data, including:

Contractual Obligations - the main reason for processing your personal data is so that we can provide you with legal services under the contractual agreement we have in place with you.
Legitimate Interests - in specific circumstances, we need your data to pursue our legitimate interests in a way which would reasonably be expected as part of running our business and which doesn’t materially affect your rights, freedoms or interests. This may include meeting our obligations to our Regulators or external auditors.
Legal Compliance - if the law requires us to, we may need to collect and process your personal data. For example, we can pass on information about people involved in fraud or other criminal activities.
Consent - in some situations we can collect and process your data with your consent, such as clicking a box to agree to receive email newsletters.

WHAT SORT OF DATA WE COLLECT

We may collect, use, store and transfer different kinds of personal data about you, grouped together as follows:

Identity data - includes full name, previous names, title, date of birth, gender, employment details and documents evidencing your identify, such as passport, driving licence and utility bills
Contact data - includes your residential address, phone number and email address
Financial data - includes bank account and payment card details
Transaction data - includes details about payments to and from you, and other details of services you have engaged us to provide
Technical data - includes IP address, login data, browser information, time zone and location and other technology you use to access our website
Profile data - includes the legal matters we assist you with, your interests, preferences, feedback and survey responses
Usage data - includes information about how you use our website and services
Marketing and communications data - includes your preferences relating to how or if you receive marketing or other communications from us and our third parties

WHEN DO WE COLLECT YOUR DATA?

We normally collect your data when you provide it to us or when it is provided to us by others during your case. You may give us your data via online forms, email, phone, post or in person. We also collect personal data when you apply for a job with our team.
We may automatically collect technical data as you interact with our website, as explained in our Cookie Policy (insert link).

HOW DO WE USE YOUR DATA?

We use your personal data to provide you with legal advice, assistance or, where appropriate, representation and for reasons directly associated with those services. This includes:

To deliver our services
To manage our relationship and communicate with you
To provide you with advice or guidance about our services
To make and manage payments
To respond to, investigate and resolve complaints
To train our colleagues and measure the quality of our services

Where applicable, we use personal data in relation to recruitment or employment, where you have applied for a job or become a member of our team.

We also use data to communicate with our Regulators and to obey laws, regulations and codes of conduct as they apply to us.

We may also use your data to let you know about other services we offer, but only where you’ve given us consent to do this.

HOW DO WE PROTECT YOUR DATA?

We take protecting your data very seriously. The data you give us may be subject to Legal Professional Privilege and is often sensitive and confidential. With this in mind, we treat your data with the utmost care and take all appropriate steps to keep it safe. We have clear data protection and information security policies and procedures which are regularly assessed, with ongoing monitoring of our systems for potential breaches, cyber attacks or vulnerabilities, together with penetration testing to identify ways in which security could be further strengthened.

HOW LONG WILL WE KEEP YOUR DATA?

We’ll only keep your personal information for as long as is necessary for the purposes for which it was collected.

We use the following data retention periods, which are reviewed periodically, to make sure we’re only keeping personal information and other data for as long as it’s needed:

Information in a case file or related matter, or instructions such as information in our case management system, will usually be kept for 6 years after the case or matter ends, unless there is a requirement to keep it for longer (e.g. information is required for related cases) or where we have another legal basis to process that information. This is because we are required to keep case files by our Regulators and / or the SRA. This also protects you in the event that you may be unhappy with our services and want to make a complaint even after our relationship ends.
Information obtained for compliance with crime or fraud prevention must be retained by us to meet our legal or regulatory obligations for 5 years from the closure of a case or matter, or from the end of our business relationship with a relevant person, whichever is later.
Enquiries, where we don’t take on your case, are kept for 18 months.
Complaints files are kept for 6 years from the date that the complaint is concluded.
Financial information and any financial transactions are kept for 7 years, to comply with HMRC requirements (except for cardholder data which is not retained by us after payments are processed).
HR records - unsuccessful applicants’ data will be kept for 6 months from application. Information related to employees will be kept for 7 years after employment ceases.

WHO DO WE SHARE YOUR PERSONAL DATA WITH?

We sometimes share your information with trusted third parties. We’ll only do this where it’s necessary to provide you with legal services or for the effective operation of our business (such as with other legal professionals, experts, translators, tech providers).

We apply a strict policy to third party recipients or data processors to keep your information safe, which includes:

Limiting information to only that required by them to perform their specific services
That they may use your data only for the exact purposes we specify
Us working closely with them to ensure that your privacy is respected and protected at all times
Where we stop using their services, any of your data held by them will be deleted or rendered anonymous

WHERE IS YOUR DATA PROCESSED?

Personal information that we collect may be shared with an organisation located outside the UK or EEA. It may also be processed by us or by one of our suppliers outside of the UK or EEA. When these circumstances apply, we always take measures to ensure your data is protected. Your data will only be transferred outside of the UK or EEA when we are satisfied that the country is recognised as having an adequate level of data protection or where there is another arrangement in place to offer protection of your data.

WHAT ARE YOUR RIGHTS?

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing processing it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we’re relying on a legitimate interest (or those of a third party) and there’s something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

CONTACT DETAILS

Komodo Law is the Data Controller and is responsible for your personal data. If you have any questions in relation to this Privacy Notice, please contact James Richardson at claims@komodo.law.

COMPLAINTS

If you have a question or complaint about our use of your personal data please contact that you feel hasn’t already been adequately addressed by us, you have the right to lodge a complaint with the Information Commissioner’s Office. You can contact them by calling 0303 123 1113 or by visiting www.ico.org.uk/concerns (please note that we can’t be responsible for content on external websites).

LINKS TO OTHER WEBSITES

Our website may contain links to other websites; we have no control over content on those other websites so we can’t be responsible for the protection and privacy of any information you provide while visiting those websites. You should exercise caution and look at relevant privacy notifications or statements applicable to external websites.

CHANGES TO THIS NOTICE

We don’t intend to process personal information for any reason other than those stated in this notice. If this changes, we’ll update this Privacy Notice here. Internet and privacy best practice continues to evolve, so we reserve the right to revise this notice at any time, and we’ll place an updated version on this webpage. Continued instructions to us will signify your agreement to any such changes.