Privacy Notice

Dolleymores Privacy Notice

This privacy policy will inform you as to how we look after your personal data when you engage us to act for you or your business.

1. Important information and who we are

Purpose of this privacy policy

This privacy notice aims to give you information on how Saunders & Dolleymore LLP, trading as “Dolleymores” collects and processes your personal data when you become our client and also any data you may provide when you sign up for news items (e.g. a newsletter) or provide feedback to us or submit an enquiry via our website http://www.dolleymores.com/contact/

Controller

Saunders & Dolleymore LLP, a limited liability partnership registered in England and Wales under registration number OC343684 trading as Dolleymores, is the controller and responsible for your personal data (collectively referred to as Dolleymores, “we”, “us” or “our” in this privacy notice).

We have appointed a data privacy manager 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 data privacy manager using the details set out below.

Contact details

If you have any questions about this privacy notice or our privacy practices, please contact our data privacy manager in the following ways:

Full name of legal entity: Saunders & Dolleymore LLP

Email address: privacy@dolleymores.com

Postal address: 9 Rickmansworth Road, Watford, Hertfordshire, WD18 0JU, UK

Telephone number: +44(0) 1923 238311

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 opportunity to deal with your concerns before you approach the ICO so please contact us in the first instance.

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 15^th November 2018.

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.

2. The data we collect about you

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 (anonymous data).

The data may concern your representative (e.g. an employee) or your client, or an inventor, designer, licensor, licensee, assignor or assignee you identify for the performance of the services we have agreed to supply to you. By agreeing to this Privacy Notice you confirm that this data is provided with the permission of the individual being identified.

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

Identity Data includes first name, middle name, last name, title, nationality, job title, country of residence and contact address.
Contact Data includes billing address, correspondence address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and details of services you have purchased from us.
Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

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.

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 our professional services). In this case, we may have to cancel our engagement with you and cease to provide our services, but we will notify you if this is the case at the time.

3. How is your personal data collected?

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

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- make enquires with us prior to using our services or submit an enquiry via our website;
- meet us at a conference or seminar;
- become our client and sign our terms of engagement;
- subscribe to our publications (e.g. news items);
- request marketing to be sent to you;
- give us feedback or contact us.
Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
- Technical Data from the following parties:
  (a) analytics providers such as Google based outside the EU;
Identity and Contact Data from other professional services providers such as patent attorneys, trade mark attorneys, solicitors and accountants based inside and outside the EU.
Identity and Contact Data from publicly available sources such as Companies House, the UK Intellectual Property Office, the European Patent Office and the EU Intellectual Property Office based inside the EU and intellectual property organisations outside the EU including the World Intellectual Property Organisation. .
Identity and Contact Data of fellow attendees from conference organisers inside and outside the EU.

4. 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 obligation.

Please refer to the Glossary set out below, to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data. 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 log and respond to an enquiry by telephone , email or otherwise	(a) Identity (b) Contact	Legitimate interests (to respond to potential clients and grow our business)
To perform and deliver our professional services to you in accordance with our client retainer letter and terms of engagement and also including: (a) Management of payments, fees and charges (b) Collection and recovery of money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to recover debts due to us)
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 (c) Advising you of developments in the law or other news	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated, to study how clients use our services and to provide you with information)
To enable you to partake in a complete a survey	(a) Identity (b) Contact (c) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how client use our services, to develop them and grow our business)
To administer and protect our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To use data analytics to improve our website, services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of clients for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
Advising you of services which may benefit you	(a) Identity (b) Contact (c) Transaction (d) Marketing and Communications	Necessary for our legitimate interests (to develop our services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing.

Marketing communications from us

We may use your Identity, Contact and Transaction 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 services may be relevant for you.

You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

Third-party marketing

We do not share your personal data with any third party for marketing purposes.

Opting out

You can ask us to stop sending you marketing messages at any time by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of you engaging us to provide our professional services.

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.

5. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table (Purposes for which we use your personal data) above.

External Third Parties as set out in the Glossary.
Specific third parties such as:
- trade mark and patent attorneys firms based inside and outside the EEA who may make your personal data available to their national/regional Intellectual Property organisations;
- accountancy practices or solicitors;
- The Intellectual Property Regulation Board and the Legal Ombudsman;
- Intellectual Property organisations including the UK Intellectual Property Office, the World Intellectual Property Organisation, the European Patent Office and the European Union Intellectual Property Office. These organisations may publish your personal data and may make this personal data available to third parties;
- Intellectual Property searching agencies, translation agencies, patent draughtsmen, investigation agencies and consular and notarial service providers.
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 policy.

We require all third parties in the European Economic Area 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.

6. International transfers

Depending on the services provided to you, it may involve transferring your data outside the European Economic Area (EEA) so that the third party can perform and deliver their Intellectual Property services to you. This data is transferred on the basis that it is necessary for the performance of our contract with you and processed in line with our written instructions.

Depending on your instructions, we may be required to transfer personal data outside of the EEA to a country that is regarded by the EC as not having adequate levels of data protection. We shall inform you of this at the time and by confirming your instructions to us to proceed, you are also providing your consent to such transfer of your personal data.

Please contact us if you want further information when transferring your personal data out of the EEA.

7. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

8. Your legal rights

You have rights under data protection laws in relation to your personal data to:

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.

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 could 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.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

9. Glossary

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/product 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 to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

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

THIRD PARTIES

Internal Third Parties

External Third Parties

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

November 2020

Dolleymores