How We Use Your Personal Data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- 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.
- Where we need to comply with a legal or regulatory obligation.
- If you have subscribed for marketing material.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To register you as a new client | Identity
Contact |
Performance of a contract with you |
| To undertake identity and credit checks | Identity
Contact Financial |
Necessary to comply with a legal obligation (for example, under the anti-money laundering legislation) |
| To process instructions and deliver your services including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us (c) Assessing and/or progressing your matter |
Identity | Performance of a contract with you |
| Contact
Financial |
Necessary for our legitimate interests (to recover debts due to us) | |
| Transaction | Necessary for our legitimate interests (to manage your monies and accounts with us) | |
| Marketing and Communications | Necessary for our legitimate interests (to provide you with information about our services which we consider will be of interest or benefit to you) | |
| Processing and delivering our services through an app including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us (c) Assessing and/or progressing your matter |
Identity
Contact |
Performance of a contract with you |
| Financial | Necessary for our legitimate interests (to recover debts due to us) | |
| Transaction | Necessary for our legitimate interests (to manage your monies and accounts with us) | |
| Marketing and Communications | Necessary for our legitimate interests (to provide you with information about our services which we consider will be of interest or benefit to you) | |
| To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey |
Identity | Performance of a contract with you |
| Contact | Necessary to comply with a legal obligation (for example, under the SRA Code of Conduct and the UK GDPR for privacy policy changes) | |
| Profile | Necessary for our legitimate interests (to keep our records updated) | |
| Marketing and Communications | Necessary for our legitimate interests (to undertake analysis to inform our business and marketing strategy) | |
| To enable you to partake in a prize draw, competition or complete a survey | Identity
Contact Profile Usage Marketing and Communications |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
| To make suggestions and recommendations to you about goods or services that may be of interest to you | Identity
Contact Technical Usage Profile |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. If you would like to update your preferences at any time, or if you decide to opt out, please contact us. (Please use “Withdrawal of consent” as the subject heading of your email).
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
Please note that if you opt-out of marketing communications, we may still contact you with non-promotional communications, such as those about ongoing business relations or administrative messages.
Third-party marketing
We will not share your personal data with any company outside Wolferstans and those suppliers who work with us to provide the services we provide to you.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by contacting us (please use “Withdrawal of consent” as the subject heading of your email) or by clicking on the unsubscribe link which you will find clearly marked in each marketing communication.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of the client contract between us, a product/service purchase, product/service experience or other transactions.
Cookies
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. For more information about the cookies we use, please see our Cookie Policy.
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.