Privacy Policy
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10.01.2023
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Introduction
1.1 Pensions Barrister, a website (“the Site”) owned and controlled by Paul Newman KC, respects the privacy rights of their online visitors and recognises the importance of protecting the information they collect about you. This Privacy Policy is designed to help you understand how Pensions Barrister collects, stores, processes and discloses personally identifiable information about you. For the purpose of this Privacy Policy “Pensions Barrister” refers to Paul Newman KC and any other members of the editorial board of the Site individually and/or collectively.
1.2 This Policy (together with Pensions Barrister’s Terms and Conditions, and any other documents referred to in it) sets out the basis on which Pensions Barrister, contactable at c/o Paul Newman KC, Wilberforce Chambers, 8 New Square, Lincoln’s Inn, London WC2A 3QP and email address info@pensionsbarrister.com, will process any personal data collected from you, or which you provide in the course of using the Site (www.pensionsbarrister.com).
1.3 For the purpose of the UK Data Protection Act 2018 (“DPA’18”) Paul Newman KC is the data controller.
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Your Information
2.1 The personal data of users is processed under the UK General Data Protection Regulation (“GDPR”) and DPA’18 under both the lawful basis of legitimate business interest and specific informed consent.
2.2 All personal data collected through automated means such as Google Analytics, is processed under the legal basis of specific informed consent (for more information on this please see Pensions Barrister’s Cookie Policy)
2.3 All other personal data, including the list set out below in section 2.2, is processed under the lawful basis of legitimate business interest to provide educational and informational resources.
2.4 The provision of all personal data is necessary to facilitate the use of the Site, including uploading posts, pictures and using the forum.
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Information that may be collected about you:
3.1 In the course of using the Site, Pensions Barrister may collect the following information about you:
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Full name.
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Organisation.
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Email address.
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Any information posted on the forum including, but not limited to, photographs, videos, opinions, articles and factual information.
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Your login information (including your username and password).
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Your profile information.
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Your Phone number.
3.2 Other personal information that may be collected about you as a user during the course of using the Site:
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Your Internet Service Provider (“ISP”).
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Your IP address.
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Any referring or exit pages taking you to or from the Site.
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Your web browser type and version.
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Your time zone and location.
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Date/time stamp.
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Click stream data.
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Any browser plug-ins and version used on your browser.
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Your operating system.
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Information collected when you interact with the content on the Site or on third-party sites or platforms, such as social networking sites. This may include information such as “Likes”, profile information gathered from social networking sites or interactions with Pensions Barrister.
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To enhance your user experience or help improve and measure the Site’s effectiveness, Pensions Barrister may embed code from third party sites. Examples of such parties may include Facebook, Twitter, Google, and others. These third parties may collect information about you, including your IP address, through cookies in ways Pensions Barrister does not control.
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How your personal data may be used:
4.1 Pensions Barrister may use your personal data in the following ways:
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To display posts and comments on the forum.
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To deliver support and respond to your queries.
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To ensure that content from this Site is presented in the most optimised and effective manner for you and for your computer.
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To diagnose or fix technology problems.
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To control unauthorised use or abuse of the Site and Pensions Barrister’s educational and information resources, or otherwise detect, investigate or prevent activities that may violate the Site’s policies or be illegal.
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To carry out obligations arising from any interaction entered into between you and Pensions Barrister.
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To allow you to participate in any interactive features on the Site, when you choose to do so.
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To notify you about changes to the Site or any of its resources.
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To administer the Site including data analysis, testing, traffic monitoring, research, statistical and survey purposes.
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To send you marketing information and updates from time to time.
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To provide you with information, or any educational and information resources that you may request or that Pensions Barrister feels may interest you.
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To gather general statistical information which may then be provided to third parties. In such case any information provided to third parties will not allow you as a data subject to be personally identified.
4.2 If you do not wish to be contacted for marketing purposes, please tick any relevant box on which you submit your data or unsubscribe from any marketing communication using the unsubscribe function in the footer of the email. You can also unsubscribe from any marketing communication by sending an email to info@pensionsbarrister.com.
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How your data may be disclosed:
5.1 In order to provide services to you, Pensions Barrister may transfer your personally identifiable information to third parties, parents, affiliates, subsidiaries and service providers, some of which may process and/or store your personally identifiable information outside of the UK or the European Economic Area (“EEA”). However, in such instance all reasonable steps will be taken to ensure that your personal data is treated securely and, where possible, in accordance with this Privacy Policy. Any data transfers that take place outside of the UK or the EEA will be covered by appropriate safeguards, for example Standard Contractual Clauses (“SCC’s”).
5.2 Third parties to which your personally identifiable information may be disclosed to include, but are not limited to:
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Grand Guild Ltd: https://www.thegrandguild.com/privacy
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Facebook: https://www.facebook.com/privacy/policy
5.3 Please note that if you click on, or follow, any links from the Site to external sites, this Privacy Policy will no longer apply. Please check the privacy policies of any such external site before submitting any personal data, as Pensions Barrister cannot accept any responsibility or liability in relation to them.
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Servers
6.1 Information collected through the Site is stored on servers which may be located outside of the UK or the EEA. These servers are encrypted using HTTPS secure access in most areas. By submitting your personal data, you agree to your data being processed and/or stored at a destination outside of the UK or the EEA. Pensions Barrister will take all reasonable steps to ensure that your data is treated securely and, where possible, in accordance with this Privacy Policy.
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6.2 Pensions Barrister takes your privacy seriously, and will take all reasonable steps to protect your personal data, but please beware that any data which you send to the Site is sent at your own risk.
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Data storage
7.1 Pensions Barrister holds personally identifiable information in a combination of hard copy and electronic files for the period necessary to support the Site, comply with their legal obligations, resolve disputes, or otherwise fulfil the purposes outlined in this Privacy Policy.
7.2 Pensions Barrister uses third party information system providers who may store or have access to your personal information. Pensions Barrister may also retain backup information on their servers for some time to comply with applicable law or their internal security policies.
7.3 Pensions Barrister does not always remove or delete all of your information for a number of reasons including due to technical and systems constraints, contractual or legal requirements.
7.4 Pensions Barrister operates a data retention period of 7 years from the date of their last interaction with a user. Once this period has been reached, any posts from a user will be archived and anonymised, meaning that all personal data is removed from the posts. This personal data, along with any other data that identifies the individual, will then be reviewed and securely deleted/destroyed.
7.5 Similarly, as Pensions Barrister is hosted using Wix’s platform, it is important to note that Wix have their own data retention policy. For more information on this, Wix’s privacy policy can be found here https://www.wix.com/about/privacy.
7.6 Pensions Barrister asks you not to send or disclose any special category of personally identifiable information (such as information related to racial or ethnic origin, religion or other beliefs, health, criminal background or trade union membership) on or through the Site or otherwise. If, contrary to this request, you do provide any sensitive information, in doing so you acknowledge that Pensions Barrister will be collecting and handling that information in accordance with this Privacy Policy.
7.7 No method of transmission over the internet, method of electronic storage or other security methods are one hundred percent secure. Therefore, while Pensions Barrister strives to use commercially acceptable means, such as firewalls, password protected databases with limited physical and electronic access, and encryption, to protect your personally identifiable information against unauthorised use, disclosure or modification, they cannot guarantee its absolute security.
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Processing of personal data of those below the age of 13
8.1 The Site is not intended for the use by anyone under the age of 13. Pensions Barrister does not knowingly collect or solicit personally identifiable information from anyone under the age of 13. If you are under the age of 13, you may not attempt to send any information about yourself to Pensions Barrister, including your name, address, telephone number, or email address.
8.2 In the event that Pensions Barrister confirms that they have collected personally identifiable information from someone under the age of 13 without verification of parental consent, Pensions Barrister will delete/destroy that information promptly. If you are a parent or legal guardian of a child under the age of 13 and believe that Pensions Barrister might have any information from or about such child, please contact Pensions Barrister at the email or mailing address provided at the end of this Privacy Policy.
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Data subject rights
9.1 Subject access request - You have the right under the DPA’18 to access the information Pensions Barrister holds about you. If you wish to exercise this right, please send your request to info@pensionsbarrister.com.
9.2 Right to rectification – You have the right under DPA’18 to request the amendment or update of all the information that Pensions Barrister holds about you. If you wish to exercise this right, please send your request to info@pensionsbarrister.com.
9.3 Right to erasure – You have the right under DPA’18 to have all of the information that Pensions Barrister holds about you deleted in line with their statutory and legal responsibilities. If you wish to exercise this right, please send your request to info@pensionsbarrister.com.
9.4 Right to restriction of processing – In line with Article 18 (1) (a) to (d) of GDPR, you have the right under DPA’18 to obtain from the controller restriction of processing. If you wish to exercise this right, please send your request to info@pensionsbarrister.com.
9.5 Right to data portability - You may have the right under DPA’18 to request copy of all of the information Pensions Barrister holds about you if the processing is based on the legal basis of consent or contract, and the processing is being carried out by automated means. If you wish to exercise this right, please send your request to info@pensionsbarrister.com.
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10.Enforcement
10.1 Pensions Barrister cooperates with the appropriate regulatory authorities, including local data protection authorities (the UK Information Commissioner’s Office (“ICO”)), to resolve any complaints regarding that collection, processing and disclosure of personally identifiable information that cannot be resolved between Pensions Barrister and the individual.
10.2 If you have a concern about your privacy, wish to make a complaint or would like to know more about how your personally identifiable information is collected or used, please contact Pensions Barrister at info@pensionsbarrister.com. If you are contacting Pensions Barrister with a complaint, please include contact information and clearly describe your complaint.
10.3 Pensions Barrister will respond to your request or complaint within a reasonable time and will let you know the next steps in resolving your complaint.
10.4 If you are not satisfied with Pensions Barrister’s conduct or response to a request you may have made, you have the right to complaint to the ICO https://ico.org.uk/make-a-complaint/.
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11.Notices and provisions
11.1 Pensions Barrister reserves the right to change this Privacy Policy at any time. These changes will take immediate effect unless you are notified otherwise. They recommend that you refer to this Privacy Policy on an ongoing basis so that you understand Pensions Barrister’s current practice at the time of using this service. Unless stated otherwise in a separate agreement, this Privacy Policy applies to all information Pensions Barrister holds about you.
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12.Contact us
12.1 Pensions Barrister regularly reviews its compliance with relevant data protection laws and this Privacy Policy.
12.2 If you have any questions or want to get in contact with us regarding this Privacy Policy, please feel free to email Pensions Barrister at info@pensionsbarrister.com or write to them at c/o Paul Newman KC, Wilberforce Chambers, 8 New Square, Lincoln’s Inn, London WC2A 3QP.
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