Privacy Policy
Goodwille Ltd, under company number 02126896 and with registered office address of 20 Red Lion Street, London WC1R 4PS (“Business”, “we”, “us”, “our”), is registered with the Information Commissioner’s Office (“ICO”) under the registration number Z7104359.
We will process your personal data in accordance with this policy, in the course of providing our services and advice in the areas of Governance, Finance, Human Resources, Payroll and Virtual Offices, including access to our website (“Services”).
Our contact details
Here at Goodwille Ltd, we are the processor of your personal data, which means that we have direct legal obligations under the data protection laws and that we are subject to regulation by supervisory authorities.
We respect and value your privacy and are committed to protecting your personal data. Your personal data will be kept confidential and will never be sold to third parties.
We will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
Name: Alexander Goodwille
Address: 20 Red Lion Street, London WC1R 4PS
Phone Number: +44 (0)20 7795 8100
E-mail: data.protection@goodwille.com
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review.
This version was last updated on 28th February 2023.
We may update this privacy policy from time to time. When we change this policy in a material way, we will update the version date. For significant changes to this policy, we will try to give you reasonable notice unless we are prevented from doing so.
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.
The type of personal information we collect
We aim to collect personal data only to the extent necessary for us to provide our services to our clients and for any other agreed purposes.
Where personal data is required for us to provide services to our clients, we request that these entities provide all necessary information to relevant individuals (known as “data subjects”) about our use of personal data.
Our clients may therefore refer data subjects to this Privacy Notice. We generally collect personal data directly from our clients or from third parties acting on their instructions.
Such personal data may be used for the following purposes:
- To provide professional and governance services: We will process personal data in order to perform such services and/or provide advice. We will be required to process sensitive personal information when setting up the services in order to comply with Anti-Money Laundering legal obligations.
- To provide financial services: We may have to process personal data in order to perform financial services and/or provide advice. We will process financial data.
- To provide HR/Payroll Services: We will process personal data in order to perform HR and payroll services to our clients and their employees. We will also process financial data and personal sensitive data.
- Managing, administering and developing our business: We process personal data in order to manage our relationship with clients, develop our business and services, maintain and develop our IT systems, manage and host events, and to administer and manage our website, systems and applications.
- Providing information about our services to our clients: unless the relevant individual has opted-out, we may use client or audit entity business contact details to provide information about our services and activities and events that may be of interest.
- Compliance with legal obligations: we are subject to various legal obligations that may require us to process and/or retain personal data held on our client files.
Certain services will require us to process special categories of personal data such as race or ethnic origin, physical and mental health, criminal records, and political, religious and philosophical beliefs. We will only process such personal data with the individual’s consent or as required by law.
How we obtain personal information and why we have it
Most of the personal information we process is provided to us directly by you or your employer.
We also receive personal information indirectly, from the following sources in the following scenarios:
| Third parties or publicly available sources | o Companies House and other public registers; o diligence platforms; and o Social Media primarily LinkedIn. |
| Contact Data | o your employer (which may be collected via your employers’ HR department); and o websites, where it is publicly available |
| Financial Data | o from third parties such as credit rating agencies; o from providers of technical, payment and delivery services; and o websites, where it is publicly available. |
| Transaction Data | o from providers of technical, payment and delivery services. |
Who we share your information with
We may share this information with:
- people within our organization who are involved in carrying out the processing described above;
- our subsidiaries or associated offices;
- our suppliers and service providers to facilitate the provision of Services, including couriers, translators, IT consultants, web hosting providers, consultants for example, in order to protect the security or integrity of our business, including our databases and systems and for business continuity reasons;
- successor or partner legal entities on a temporary or permanent basis for the purpose of a joint venture, collaboration, financing, sale, merger, reorganisation, change of legal form, dissolution or similar event relating to a Business. In the case of a merger or sale, your personal data will be permanently transferred to a successor company;
- public authorities where we are required by law to do so; and
- any other third party where you have provided your consent.
We will also share your personal information if we think this is necessary to in order to protect the rights, property, or safety of our business, our employees, our partners, or our customers. This includes sharing information for the purposes of fraud protection and credit risk reduction or where it is required by government and/or law officials or is required by law.
Lawful Basis for Processing
Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing your information are:
- With your consent. You are able to remove your consent at any time. You can do this by contacting protection@goodwille.com
- We have a contractual obligation.
- We have a legal obligation.
- We have a legitimate interest.
How we store your personal information
Your information is securely stored.
We will implement technical and organisational security measures in order to prevent unauthorised access to your personal data. However, please be aware that the transmission of information via the internet is never completely secure. Whilst we can do our best to keep our own system secure, we do not have full control over all processes involved in, for example your use of our website or sending confidential material to us via email, and we cannot therefore guarantee the security of your information transmitted to us on the web.
How long we retain your personal information
We will only keep records of your personal information for as long as is reasonably necessary for the purposes for which we have collected it, and in order to comply with any statutory or regulatory obligations in relation to retention of records.
We respect requests to stop processing your personal data for marketing purposes. This includes keeping a record of your request indefinitely so that we can respect your request in future.
We may keep an anonymized form of data, which will no longer refer to you and therefore is not considered to be personal data, for statistical purposed without time limits.
Your data protection rights
Under data protection law, you have rights including:
Your right of access – You have the right to ask us for copies of your personal information.
Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
Your right to object to processing – You have the the right to object to the processing of your personal information in certain circumstances.
Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
Please contact us at data.protection@goodwille.com if you wish to make a request.
International transfers of your personal data
Your personal information may be stored and processed outside of the country where it is collected, including outside of the European Economic Area. When transferring information to others, within the EEA or otherwise, we ensure that appropriate and suitable safeguards and technical measures are in place to protect your personal data. To do this, we make use of standard contractual clauses that have been approved by the European Commission, or we implement other similar measures required by laws around the world.
If you would like further information about this, please contact us at data.protection@goodwille.com.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites and or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly. For more information about the cookies we use, please refer to our Cookie Policy.
Third Party Links
The website may include links to third-party websites, plug-ins and application. 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 policy of every website you visit.
How to complain
If you have any concerns about our use of your personal information, you can make a complaint to us at data.protection@goodwille.com.
You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk
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