Privacy Policy

Effective Date: 25th May 2018This website may collect some personal data from its users Owner and Data Controller: Nicolle Plumley Advocate, Bellevue House EastBelle Vue, PeelIsle of Man IM5 1UH Owner contact email:nicolle@iomadvocate.co Nicolle Plumley Advocate and operates the website iomadvocate.com and IOM Advocate Nicolle Plumley facebook page for the provision of legal advice and assistance and legal consultancy services in the Isle of Man (the "Service") and is intended for use as isThis Service is provided by Nicolle Plumley Advocate having its business premises at Bellevue House East, Belle Vue, Peel Isle of Man IM5 1UH (“the Business”). Nicolle Plumley Advocate is a registered business name of the Business and is regulated by the Isle of Man Law Society. We are committed to maintaining robust privacy protections for our clients and users of our Service. This privacy policy informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that information All those subject to this privacy policy are referred to as “the client” for the purposes of this policy which is incorporated by reference into the Terms and ConditionsThe terms “we,” “us,” and “our” refer to the Business. “You” and "your" refers to you, the client, as a user of our website or our Service Unless otherwise defined in this privacy policy the terms used have the same meanings as in our Terms and Conditions, which are accessible on the website For a better experience while using our Service, we may require you to provide us with certain personally identifiable information (“personal information”). The information that we request will be retained by us and used as described in this privacy policy By using the Service, you agree to the collection and use of information in accordance with this privacy policy Our approach to personal information We comply with the Data Protection Act 2002 of the Isle of Man and the EU General Data Protection Regulation (“GDPR”) regarding the collection, use, and retention of personal information from European Union member countries. We adhere to the Data Protection Bill 2018 implementing GDPR into Isle of Man domestic law by way of the Data Protection Act 2018, the Data Protection (Application of GDPR) Order 2018, the Data Protection (Application of LED) Order 2018 and GDPR and LED Implementing Regulations 2018 (the “IOM GDPR Legislation”) and uphold the principles of lawfulness, fairness and transparency, notice, choice, accountability for onward transfer, security, data minimisation, data Integrity and confidentiality, purpose limitation, storage limitation, accuracy, access and recourse, enforcement and liability We believe in and uphold the right to the privacy of our clients and users of our Service. We respect your confidentiality and will not disclose any information we have to third parties without your express consent or as is necessary for our legitimate interests. We will endeavour to be open and transparent with you when processing your personal information We will not use or share your information with anyone except as described in this privacy policy Collection and use of personal information We use the data we collect to provide and improve our Service to you. We may process your personal information because it is necessary for the performance of a contract to deliver the legal services requested by you or to take steps to provide you with advice and assistance at your request prior to entering into such a relationship We may collect your personal information in a number of ways, such as:From the information you provide to us when you contact us for advice or use our Service, such as your contact information including your name, residential and business address, phone number, email address, your date of birth, gender, marital status, your passport or other forms of identity details including ID issue and expiration date, your country of birth, domicile, residence, tax residence, nationality or citizenship, financial disclosure documents including information relating to your tax affairs and identification number, credit information, your bank account details, credit card and bank statements, medical history and social security status. You may also provide other optional information through your communications with us or to enable us to provide our Service to you;When you communicate with us or when we communicate with you in person or over the phone, by email or other forms of electronic communication such as when you send us a private message on our facebook or other forms of social media. In this respect, we may monitor, record and store any such communication;Documents and information provided by you at our request to fulfil any legal obligations we have with respect to undertaking due diligence on you and verifying your identity, including your source of wealth and source of funds for payment of our Service;From publicly available sources or from third parties where we need to conduct background checks about you, including information to assess whether you may represent a money laundering or terrorist financing risk or whether you are a Politically Exposed Person or have had previous criminal convictions or regulatory sanctions imposedWhen we collect your personal information, we will: only collect what we need and no morekeep your information securetell you how we will use your informationdelete your information when it is no longer needed only process your information in line with the rules set out in the Data Protection Act 2002 of the Isle of Man and the Isle of Man GDPR Legislation Your rights GDPR gives you enhanced rights to access the data that we hold on you and more control over how your personal information is used. In relation to the personal information we process, you have the following rights: to be informed about what information we hold on you to access the information that we hold on you to rectify any inaccurate information that we hold on you to have any information that we hold on you erased, subject to our legal obligations to retain data for a prescribed period of time to restrict us processing data on you, subject to our legal requirements to move your data to another organisation – data portability to object to your data being collected or used to opt out of automated decision making and profiling to require us not to send you direct marketing communications We will provide you with access to your personal information upon request, unless, and to the extent necessary, that the right of access is restricted Right of access to personal information If we do hold information about you, you can ask us to correct any mistakes. You also have the right, subject to any statutory limitations, to object to processing, to erasure or restriction of processing, and to data portability Accessing, updating or deleting your personal information If you would like to access, update or correct any information that you have provided to us through your use of our Service or otherwise, or if you would like to delete your personal information maintained by us please send an email to nicolle@iomadvocate.co Following your request, we will take reasonable steps to correct, update, amend or delete your personal information. We may not be able to permanently delete your personal information in all instances, such as when the information has been shared with third parties Retaining your personal information In order to meet our regulatory and legal obligations we may retain your personal information for 6 years after the termination of your Service We reserve the right to extend this period where legal claims or other circumstances dictate that it is in our best interests to do so, provided that such retention is legitimate, reasonable and proportionate New uses of personal information From time to time we may use personal information for uses not previously disclosed in our privacy policy. If our practices change regarding previously collected personal information in a way that would be materially less restrictive than stated in the version of our privacy policy in effect at the time that the information was collected, we will make reasonable efforts to provide reasonable notice and obtain consent to any such uses as may be required by law Internal and service related usage We use information, including personal information, for internal and service related purposes and may provide it to third parties to allow us to facilitate the Service. We may use and retain any information we collect to provide and improve our Service Third party service providers The website and facebook page may use third party services to provide features of the website and page or additional functionality. Since these are run by third party services they may add cookies to your computer, especially if you are logged in to a related account The website is hosted by a third party provider, Wix.com, their access is based on providing administrative support to the website and the records management tools including generating invoices to enable us to provide and improve our Service, For more information about our third party service providers privacy policies we encourage you to read the privacy statements made on their websites We may use a third party service, such as Wix.com or Google Analytics, to collect standard internet log information and details of user behaviour patterns. We do this to find out things such as the number of visitors to the various parts of our website. This information is only processed in a way which does not identify you. We do not make, and do not allow the third party service provider to make, any attempt to find out the identities of anyone using our Service Your consent We are legally required in instances where we have no statutory reason to use or hold your information (known as "processing"), to ask you for your explicit consent. We have to provide you with all the information we can about what we will do with your information in order that you can make an informed decision as to whether or not you agree to us having your information Communications We may send email, text messages, private messages on social media such as LinkedIn, Messenger, WhatsApp or other social media messages to the email address, mobile phone number or social media platform you provide to us or contact us by to facilitate our communications to you and improve our Service. Email and other electronic communications are stored securely on our systems and cloud storage and such messages will only be shared with your knowledge and only in order to address your enquiry or request and for the provision or improvement of our Service to you If you choose to provide us with personal information on our social media platform we ask that you also check the platform’s privacy policy and terms of service prior to communicating with us in this way Marketing We may use information, including personal information, to facilitate transmittal of information that may be useful, relevant, valuable, or otherwise of interest to you, and to serve you personalised advertising content that may be relevant to your interests You have the right at any time to prevent us from contacting you for marketing purposes. We may continue to send you administrative emails including, for example, periodic updates to our privacy policy and terms of business Security We value your trust in providing us your personal information and implement security measures designed to protect your information from unauthorised access. All personal information is kept with the highest standards and safeguards in place, including technical security, preventing unauthorised access and maintaining backups We protect your information from potential security breaches by implementing certain technological security measures including encryption, firewalls and secure server software. Emails are stored electronically on our system and cloud storage and all electronic communications and attachments received by us are monitored for viruses or malicious software. We do not routinely store manual records and where possible operate a paperless office system, however, where this is not possible or practicable under the circumstances or we are required to hold any manual records these will be stored onsite or in a third party storage facility with whom we have data protection agreements in place Whilst we continuously aim to use commercially acceptable means to securely store and protect your personal information we cannot guarantee its absolute security and you are reminded before using our Service or providing any information that no method of transmission over the internet or electronic storage is completely secure and reliable By using the Service or providing personal information to us, you acknowledge that you understand and agree to assume these risks and agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Service and provision of the Service to you Special category personal information We are required by law to to put additional measures in place if we plan to process any special category personal data, including ethnic origin or religion To provide and improve our Service to you we may process special category personal information Children’s privacy In order to process the personal information of children, additional measures are required to be put in place. Whilst our Service is not directed to anyone under the age of 13, we may however collect, maintain or use personal information of children under 13 or process personal information of persons under 13 for the provision of our Service or with the consent of a parent or guardian of a child under 13 Websites and Cookies Cookies are small computer files that are used to track your use of a website There are a number of different types of website cookie. They contain no name or address information or any information that will enable anyone to contact you via telephone, email or any other means. The cookies used are listed below: Personalisation Cookies Our website does not make use of any cookies used to personalise your user experience Analytics Cookies These types of cookies are used to monitor how people use our website and how they reached the site. These cookies do not track any personal information and are used to analyse and improve the performance of the Service E-Commerce Our website does not use any e-commerce cookies Ad Management Our website does not make use of ad banner management services Any information we receive from cookies is for the administration of the associated website and we will only use cookies when it is necessary for the efficient operation of that particular website. Any emails or addresses communicated to us are used only for the purpose intended by the sender Whenever you request a page through your browser, data such as: your IP address browser and version operating system time and date the site from which you came is stored in a log file and/or database This information cannot be used to identify specific individuals, and is only used for: website and system administration research and development anonymous user analysis Information supplied via our website will not be disclosed to any unauthorised third party Blocking Cookies If you do not wish to accept any cookies then you can change the cookie policy of your web browser to not accept cookies Please refer to your browser’s or mobile device’s technical information for instructions on how to delete and disable cookies, and other tracking or recording tools. Note that disabling cookies may disable some features available through the Service Links to external websites We are not responsible for the privacy practices or the content of any external website listed or linked to from this site. If you follow a link from this website to another website, you may be supplying information to a third party Jurisdiction By using the Service, your data will be transferred to the Isle of Man and stored by our data storage providers at their server locations By choosing to use the Service or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this privacy policy will be governed by the laws of the Isle of Man and the adjudication of any disputes arising in connection with the Service will be in accordance with the Terms and Conditions Data compliance and contact For any privacy enquiries or to exercise any of your rights, you may contact us at the contact details provided below We may require additional information in order to identify you or verify the information requested. You may also contact the Isle of Man Information Commissioner, the Isle of Man supervisory authority for data protection issues. For more information please visit www.inforights.im Contact us For everything else or if you have any questions or suggestions about our privacy policy or improving our procedures or Services to you, you can contact us: By email: nicolle@iomadvocate.coBy post: Nicolle Plumley Advocate, Bellevue House East, Belle Vue, Peel Isle of Man IM5 1UHBy phone: +44 (0) 7624 246877 Resolving complaints In compliance with the the Data Protection Act 2002 and the Isle of Man GDPR Legislation, we are committed to resolving complaints about your privacy and our collection or use of your personal information If you have any questions about our privacy policy, the information that we collect from you, or our Service or if you believe that our collection or use of your personal information is unfair, misleading or inappropriate, please bring your concern to our attention If you believe that any information we hold on you is incorrect or incomplete, please contact us as soon as possible. We will correct any information which was found to be incorrect promptly You also have the right to make a complaint at any time to the Isle of Man Information Commissioner at: https://www.inforights.im/complaint-handling/how-to-make-a-complaint-to-the-information-commissioner/ Changes to this privacy policy We keep our privacy policy under regular review and we may update our privacy policy from time to time. You are advised to review this page periodically for any changes. We will notify you of any changes by email or by posting the new privacy policy on this page. These changes are effective immediately after they are posted on this page This privacy policy was last reviewed on: 28th October 2019 ©2018 Nicolle Plumley IOM Advocate All rights reserved Nicolle Plumley Advocate Bellevue House East Belle Vue Peel IM5 1UH +447624246877 www.iomadvocate.com