Privacy policy

Purpose of this privacy notice

This privacy notice aims to give you information on how GE FLS collects and processes your personal data through your use of this website and in the course of its business. It tells you the specific ways we use and disclose that information. We take your privacy extremely seriously and never sell your data or pass it on to any third party for sales or marketing use. This privacy policy is effective with respect to any data that we have collected, collect about and/or from you according to our terms and conditions of business.

The firm’s website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

This policy explains when and why we collect personal information about you, how this information is used, the conditions under which it may be disclosed to others and how it is kept secure.

This is our main privacy policy. We may provide additional, specific privacy information to you as you interact with us in different ways (e.g. that we will only use certain information for specific purposes). To the extent that any of that information differs from what we say below, those specific statements will apply in those circumstances.

This policy may change from time to time so please check this page occasionally to ensure that you’re happy with any changes.

Controller

GE FLS is the controller and responsible for your personal data (collectively referred to as “GE FLS”, “we”, “us”, or “our” in this privacy notice). Our registered office is 19 Railton Rd, Guildford, Surrey GU2 9LX.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details

• Full name of legal entity: Gregorian Emerson Family Law Solicitors
• Name and title of DPO: Richard Gregorian, Principal
• Email address: [email protected]
• Telephone number: (01483) 826470

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed.

Through your use of this website, we may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Usage Data includes information about how you use our website.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

When you use our website, our services, interact with us online, or by phone, email or otherwise, the categories of information that we collect about you include the following personal information, to include all information that you give to us through engaging in correspondence with us by phone, email or otherwise.

The basic personal information we may ask for, or you may choose to give us, includes your name, your address, email address and phone number. We may retain details of any enquiry you make to us and records of any correspondence with us. We may also ask for, or you may choose to give us, other information for specific purposes in order to carry out your instructions.

We will seek to minimise the information we ask for to that which is needed to perform the relevant function or service at the time but always required for your retainer.

Personal information we collect about you: we automatically collect the following information when you interact with us: e.g. details of transactions you carry out through the site, and your visits to our site, including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources you access. We also automatically collect technical information, including anonymous data collected by the hosting server for statistical purposes, the Internet protocol (IP) address used to connect your computer or device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.

Personal information we may receive from other sources: we obtain certain personal information about our clients from third parties such as the court, Cafcass, police and social services but again always pursuant to your representation and instructions.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

We use different methods to collect data from and about you including through:

• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy below for further details.
• Third parties or publicly available sources. We may receive Technical Data from analytics providers such as Google based outside the UK.

We also will collect your personal information when you consult with us, send us an email, or communicate with us in any way which represents a voluntary giving by you of information for the purposes of the contract. That information may include your or your contact’s name, physical address, email address, IP address, phone number as well as details including occupation, location, history and other demographic information. By giving us this information you agree to this information being collected, used, disclosed and transferred within the UK or outside the UK if your case requires it. You also agree to this information being stored by us as described in our terms and conditions, cookie policy and this privacy policy.

We will only use your personal data when the law allows us to. Most commonly, we will use your data (a) where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests, and (b) where we need to comply with a legal or regulatory obligation. We process your personal data primarily on the basis of legitimate interest as a business but only if necessary for the purpose we collect it for. We will also process data on the basis of contractual and transactional obligation when necessary. In particular, we may process your data in order to make calls, emails and other types of communications to you and third parties in connection with your case. It will also be used in relation to account activity such as email, written and verbal communications and agreements and financial activities such as billing communications but most importantly to perform obligations under contract with you or third parties where necessary to pursue that contract.

Generally we do not rely on consent as a legal basis for processing your personal data.

We use your data to collect money owed to us by you including sending you emails, invoices, receipts, notes of delinquency and alerting you if we knew a different credit card number. We use third parties for secure debit and/or credit card transaction processing and we send billing information to those third parties to process your orders and credit card payments.

We also use your data to communicate with you about your instructions and provide support and representation in accordance with our terms and conditions. We will communicate with you to enforce compliance with our terms and conditions and applicable law. We will also communicate and utilise your data in order to meet legal requirements such as comply with court orders, valid discovery requests, subpoenas and other appropriate legal mechanisms. We will also use your information to provide information to representatives and advisers including lawyers and accountants to help comply with legal accounting or other security requirements and in accordance with your instructions. We will use it to prosecute and defend a court arbitration or similar legal proceeding and respond to lawful requests by public authorities including to meet national security or law enforcement requirements.

Most importantly we will use your data in obtaining advice from Gavin Emerson where that has been agreed in advance.

We may disclose personal information and use personal data acquired from and provided by yourself or for any of your requests and to send you appropriate and useful communication.

We will retain personal information we process on behalf of our clients as long as needed to provide our services or to comply with legal obligations, resolve disputes and prevent abuse and enforce agreements.

We do not disclose information obtained about you from our website or from you in any other way except when we need to do so in order to complete the transaction (e.g. when arranging for a courier company to deliver or collect goods) or to pursue your instructions.

You may withdraw your consent for us to use your information in any of these ways at any time. Please see the section below on withdrawing your consent for further details.

Set out below is an explanation of how we use information about visitors to the website:

• We may use your Technical Data to administer and protect our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). Such use would be necessary for our legitimate interests (for running our business, provision of administration and IT services, to prevent fraud and in the context of a business reorganisation exercise), and to comply with a legal obligation.
• We may use your Usage Data and Technical Data to deliver relevant website content to you and measure or understand the effectiveness of the content. Such use would be necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform market strategy).
• We may use your Usage Data and Technical Data to use data analytics to improve our website, services, marketing, customer relationships and experiences. Such use would be necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Like many other websites, our website uses cookies (including Google Analytics cookies) to obtain an overall view of visitor habits and visitor volumes to our website. ‘Cookies’ are small pieces of information sent to your computer or device and stored on its hard drive to allow our website to recognise you when you visit.

It is possible to switch off cookies by setting your browser preferences. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

We may have to share your personal data with the parties set out below:

• External third parties as set out in the glossary.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We may disclose your information to our third-party service providers, agents, subcontractors and other organisations for the purposes of providing services to us or directly to you on our behalf. Such third parties may include cloud service providers; hosting, email and content providers; marketing agencies and administrative services providers; assessors for our accreditations; payment processing companies (who will process your debit/credit card securely if you purchase goods or services from us) and research companies (who may contact you to gather information relating to your experience of us and our products and services or on topical, policy and strategic issues facing the profession).

When we use third-party service providers, we only disclose to them any personal information that is necessary for them to provide their service and we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions.

We may share personal information with third parties in order to facilitate your instructions to act on your behalf; we may share your contact details with third parties for marketing purposes if you have given consent for this and we may share your details with third parties if this is necessary to fulfil a contract with you. We may transfer your personal information to a third party if we’re under a duty to disclose or share it in order to comply with any legal obligation, to detect or report a crime, to enforce or apply the terms of our contracts or our legal rights or to protect the rights, property or safety of our visitors and customers. We will always take steps with the aim of ensuring that your privacy rights continue to be protected.

We do not transfer your personal data outside the European Economic Area (EEA).

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to our website and any transmission is at your own risk. Once we have received your personal information, we put in place reasonable and appropriate controls to ensure that it remains secure against accidental or unlawful destruction, loss, alteration, or unauthorised access.

Where we collect any sensitive personal information about your ethnic background, sexual orientation, political opinions, religion, trade union membership or criminal record, we will apply additional security controls to protect that data.

Where we have given (or where you have chosen) a password which enables you to access an account, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Our website may contain links to other websites run by other organisations. This policy does not apply to those other websites so we encourage you to read their privacy statements. We cannot be responsible for the privacy policies and practices of other websites even if you access them using links that we provide. In addition, if you linked to our website from a third-party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third-party website and recommend that you check the policy of that third-party website.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

How long will you use my personal data for?

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.

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.

Under certain circumstances, you have rights under the data protection laws in relation to your personal data. Your rights are listed below, and more detail can be found in the glossary below:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

You have a number of rights in relation to your personal information under data protection law. In relation to certain rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal information.

Except in rare cases where additional time may be required, we will respond to you within one month from either (i) the date that we have confirmed your identity, or (ii) where we do not need to do this because we already have this information, from the date we received your request.

Accessing your personal information

Under data protection laws you have a legal right to ask to see a copy of the personal information that we hold about you. Such requests are called subject access requests. If you would like to make a subject access request, please contact Richard Gregorian at the above address. You will also need to provide one form of identification and proof of your address, for example, a driving licence or utility bill, and if appropriate, any particulars about the source or location of the information you are requesting. Further information about subject access requests can be found on the Information Commissioner’s website ico.org.uk.

We may not provide you with a copy of your personal information if this concerns other individuals or if we have another lawful reason to withhold that information.

Correcting and updating your personal information

The accuracy of your information is important to us and we are working on ways to make it easier for you to review and correct the information that we hold about you. In the meantime, if you change your name or address/email address, or you discover that any of the other information we hold is inaccurate or out of date, please let us know by contacting us.

Withdrawing your consent

Where we rely on your consent as the legal basis for processing your personal information, as set out above on how we use your personal information, you may withdraw your consent at any time by contacting us. If you would like to withdraw your consent or object to receiving any direct marketing to which you previously opted-in, you can do so by notifying Richard Gregorian or by writing to us or calling us. If you withdraw your consent, our use of your personal information before you withdraw is still lawful.

If you have provided consent for your details to be shared with a third party, and wish to withdraw this consent, please also contact the relevant third party in order to amend your preferences.

Objecting to our use of your personal information and automated decisions made about you

Where we rely on our legitimate business interests as the legal basis for processing your personal information for any purpose(s), you may object to us using your personal information for these purposes by emailing or writing to us at the address at the end of this policy. Except for the purposes for which we are sure we can continue to process your personal information, we will temporarily stop processing your personal information in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your data for those purposes. Otherwise we will provide you with our justification as to why we need to continue using your data.

You may object to us using your personal information for direct marketing purposes and we will automatically comply with your request. If you would like to do so, please email or write to us at the above address.

Erasing your personal information or restricting its processing

In certain circumstances, you may ask for your personal information to be removed from our systems by emailing or writing to us at the address at the end of this policy. Unless there is a reason that the law allows us to use your personal information for longer, we will make reasonable efforts to comply with your request.

You may also ask us to restrict processing your personal information where you believe it is unlawful for us to do so, you have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings. In these situations we may only process your personal information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings.

Transferring your personal information in a structured data file (‘data portability’)

Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with a contract we’ve entered into with you, as set out above on how we use your personal information, you may ask us to provide you with a copy of that information in a structured data file. We will provide this to you electronically in a structured, commonly used and machine-readable form, such as a CSV file.

You can ask us to send your personal information directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.

Complaining to the UK data protection regulator

We’d like to be able to resolve all your concerns, and we hope that we can do so. Where we haven’t been able to do this, you have the right to complain to the Information Commissioner’s Office (ICO) if you are concerned about the way we have processed your personal information. Please visit the ICO’s website for further details: ico.org.uk.

No fee usually required

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 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

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.

Lawful basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by law). You can obtain further information about how we assess our legitimate interests against any particular impact on you in respect of specific activities by contacting us.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

External third parties

• Service providers acting as processors based in the UK who provide IT and system administration services.
• Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue and Customs, regulators and other authorities acting as processors based in the UK who require reporting of processing activities in certain circumstances.

Your legal rights

• 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 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 to process 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, 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 are relying on a legitimate interest (or those of a third party) and there is 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 to establish, exercise or defend legal claims; or (d) you have objected to our use of our 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 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 services to you. We will advise you if this is the case at the time you withdraw your consent.

Like many websites, the GE FLS website uses cookies — small text files, typically of letters and numbers — to capture limited information about the site’s users. The information is transferred by the website to the cookie file of the browser on the hard drive of the user’s computer.

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