PRIVACY POLICY – QUBIC TRUSTEES LIMITED

Qubic Trustees Limited (we or us) are committed to protecting and respecting your privacy. Qubic Trustees Limited is a company incorporated in England with company registration number 06890768 and whose registered address is 3rd Floor, 2 St James Gate, Newcastle Upon Tyne NE1 4AD.

This Privacy Policy was last updated on 25 May 2018.

1. SCOPE OF POLICY

This policy (together with our website Terms of Use http://www.qubictrustees.co.uk/legal/terms/) describes how and when we collect and process personal data. It applies to personal data collected by us and provided to us by yourself or others. Please read the following carefully to understand our practices regarding your personal data and how we will treat it. It also explains your rights in relation to your personal data and how to contact us or the relevant supervisory authority in the event you have any queries or a complaint.

By visiting www.qubictrustees.co.uk or contacting us, Qubic Tax Limited or Qubic Tax Advisory Limited, you are accepting and consenting to the practices described in this policy.

For the purpose of the General Data Protection Regulation (GDPR), which applies across the European Union including the UK, the data controller is Qubic Trustees Limited.

2. HOW WE COLLECT INFORMATION

We may collect and process the following data about you:

• 2.1 Information you give us. You may give us information about you by filling in forms on our website www.qubictrustees.co.uk or by corresponding with us by e-mail or otherwise. This includes information you provide when you create an account or report a problem with our website. The information you give us may include your name, address, e-mail address and phone number (including mobile number), financial and credit information and personal description.
• 2.2 With regard to each of your visits to our website we may automatically collect the following information:
• 2.2.1 technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), your login information, browser type and version, time zone setting, browser plug-in-types and versions, operating system and platform;
• 2.2.2 information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products or services you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number;
• 2.2.3 details of your use of our website and the resources that you access.
• 2.3 In the course advising, acting for you or considering if we may act, we may ask you to provide us with information including:
• 2.3.1 your name, address, e-mail address, phone number (including mobile number), financial and credit information. We may also collect information to check your identity (such as your date of birth, passport or driving licence details) and to undertake a credit or other financial check on you;
• 2.3.2 information relating to the matter on which you are seeking our advice or services. To the extent that it is relevant to the subject matter on which we are instructed such information may include but is not limited to, your financial details, including your National Insurance number, employment status, tax details, business details, pension arrangements, banking details and details of your assets and liabilities.
• 2.4 Information we receive from other sources. We may collect information with your consent from third parties acting on your behalf including from your accountant, financial advisor, legal representative, bank or building society or other financial institution and your employer.
• 2.5 We may also collect information about you from other third parties sources such as credit reference agencies, sanctions screening providers and from publically accessible sources such as Companies House.
• 2.6 If you provide us with personal information about someone else, you are responsible for ensuring that you comply with any obligations under applicable data protection laws in relation to such disclosure. Where required by data protection laws, you must ensure that you have provided the required notices and have obtained the individual’s explicit consent to provide us with the information and that you explain to them how we process data in accordance with this privacy Policy.

If you contact us, we may keep a record of that correspondence.

3. USES MADE OF THE INFORMATION

We use information held about you in the following ways:

• 3.1 Information you give to us. We will use this information:
• 3.1.1 to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
• 3.1.2 to identify our clients, verify their identity, to screen for applicable financial sanctions or other embargoes as well as any other processing required in order to comply with any legal or regulatory obligations we may have;
• 3.1.3 to ensure the confidentiality of commercially sensitive information, which will be carried out for our legitimate interests or those of a third party (i.e. to protect commercially valuable information) and/or to comply with any legal or regulatory obligations we may have;
• 3.1.4 to provide you with marketing information about goods or services we feel may interest you (whether provided by us, Qubic Tax Limited, Qubic Tax Advisory Limited or any other party which now or in the future legitimately uses the Qubic name and mark and is described by us as being a firm which is part of the Qubic network). If you are an existing or former client, we will only contact you by electronic means (e-mail) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a potential customer we will contact you by electronic means only if you have consented to this. The basis of processing data in this manner will be for our legitimate commercial interests or with your consent;
• 3.1.5 to provide information required by or relating to audits, enquiries or investigations by regulatory or governmental bodies, which will be carried out in order for us to comply with any legal or regulatory obligations we may have;
• 3.1.6 to carry out anonymised statistical analysis to help us manage our practice, for example in relation to our client base and areas of work. This will not amount to automated individual decision making or profiling. The basis of this processing will be for our legitimate interests of managing the efficiency of our practice;
• 3.1.7 to carry out credit reference checks via external credit reference agencies. Such checks will not be automated individual decision making or profiling. We will notify any natural persons before such checks are carried out, which shall be carried out for the purpose of our legitimate credit control interests and/or with the consent of the individual in question;
• 3.1.8 to carry out external audits and quality checks, for example in relation to Investors in People accreditation, which will be carried out on the basis of our legitimate interests in maintaining high standards of practice and/or to comply with any legal or regulatory obligations we may have;
• 3.1.9 to undertake internal testing of our website, IT systems and services to test and improve their security, provision and performance, which will be carried out for our legitimate interests of detecting and preventing criminal activities and/or to comply with any legal and regulatory obligations we may have;
• 3.1.10 to notify you about changes to our service;
• 3.1.11 to ensure that content from our site is presented in the most effective manner for you and for your computer.
• 3.2 Information we collect about you. We will use this information:
• 3.2.1 to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• 3.2.2 to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
• 3.2.3 to allow you to participate in any interactive features of our service, when you choose to do so and if provided by us;
• 3.2.4 as part of our efforts to keep our site safe and secure;
• 3.2.5 to measure or understand the effectiveness of marketing we provide to you and others and to deliver relevant marketing to you;
• 3.2.6 to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
• Any analysis of data will not be automated individual decision making or profiling. The basis of this processing will be our legitimate commercial interests including managing the efficiency and security of our website and the practice of our firm.
• 3.3 Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).

4. COOKIES

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you and other users with a good experience when browsing our site and also allows us to improve our site.

A cookie is a small file of letters and numbers that we store on users' browsers or the hard drive of users' computers if users agree. Cookies contain information that is transferred to users' computers' hard drive. We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our site. They include, for example, cookies that enable users to log into secure areas of our site or make use of e-billing services.
• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our site when they are using it. This helps us to improve the way our site works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise users when they return to our site. This enables us to personalise our content for users, greet users by name and remember users' preferences.
• Targeting cookies. These cookies record users' visits to our site, the pages users have visited and the links users have followed. We will use this information to make our site and the advertising displayed on it more relevant to users' interests. We may also share this information with third parties for this purpose.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

Users can block cookies by activating the setting on their browser that allows users to refuse the setting of all or some cookies. However, if users use their browser settings to block all cookies (including essential cookies) users may not be able to access all or parts of our website. Except for essential cookies, all cookies will expire after 12 months.

Our site may, from time to time, contain links to and from the websites within the Qubic network (which presently includes Qubic Tax Limited, Qubic Tax Advisory Limited and Qubic Trustees Limited). Qubic Tax Limited, Qubic Tax Advisory Limited and Qubic Trustees Limited are separate legal entities which do not act as agents for and cannot bind one another. Each entity is liable only for its own acts or omissions and not those of any other firm. Our site may also contain links to and from the websites of one of our partner networks, advertisers or affiliates. If you follow a link to any of the aforementioned websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

5. DISCLOSURE OF YOUR INFORMATION

We may share your data with selected parties including:

• 5.1 Qubic Tax Limited, Qubic Tax Advisory Limited and any other third party which now or in the future legitimately uses the Qubic name and mark and is described by us as being a firm which is part of the Qubic network, for the purposes set out in this Privacy Policy;
• 5.2 Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
• 5.3 Our service providers and agents (including their subcontractors) or third parties which process information on our behalf (e.g. internet service and platform providers, payment processing providers and those organisations we engage to help us send communications to you) for the purpose of providing you with the information and services you have requested or which we believe is of interest to you;
• 5.4 Analytics and search engine providers that assist us in the improvement and optimisation of our site;

We may disclose your personal information to third parties:

• 5.5 In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
• 5.6 If Qubic Trustees Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• 5.7 If we are under a duty to disclose or share your personal data to any third party including government departments, our firm’s regulatory authority or law enforcement agencies in order to comply with any legal or regulatory obligation we may have or in order to enforce or apply our website terms and conditions (http://www.qubictrustees.co.uk/legal/terms/) and the terms of engagement, to our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

6. SECURITY AND STORAGE INFORMATION

We will keep your information secure by taking appropriate technical and organisational measures against its unauthorised or unlawful processing and against its accidental loss, destruction or damage. Any payment transactions will be encrypted using SSL technology. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information on our behalf will do so only in an authorised manner and are subject to a duty of confidentiality. In the event of a suspected data breach we will notify you and any applicable regulator where we are legally required to do so.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

7. WHERE WE STORE YOUR PERSONAL DATA

Information we collect or you provide to us is stored on our secure servers or those of our IT service providers (and their sub processors), at destinations within the European Economic Area (“EEA”).

8. YOUR RIGHTS

You have the following rights, which you can exercise free of charge:

• the right to be told how we use your personal data and obtain access to your personal data;
• the right to require us to correct any mistakes in your personal data;
• the right to require us to delete your personal data in certain situations;
• the right to require us to restrict processing of your personal data (e.g. for direct marketing purposes; e.g. where you contest the accuracy of the data);
• the right to receive, where technically feasible, your personal data in a structured commonly used and machine-readable format and/or to require us to transmit your personal data in that form to a third party;
• the right to object at any time to your personal data being processed for direct marketing;
• the right to object in certain circumstances to our continued processing of your personal data (e.g. processing carried out for the purpose of our legitimate interests)
• where the processing of your personal data is based on your consent, the right to withdraw that consent;
• the right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you;

For further information on each of those rights, including the circumstances in which they apply, please see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation (https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/).

If you would like to exercise any of those rights, please:

• e-mail, call or write to us (How to Contact Us (below));
• provide us with: (i) sufficient information to identify you (e.g. you full name, address and any client reference number); and (ii) proof of your identity and address (e.g. a certified true copy of your passport or driving licence and a recent credit card or utility bill); and
• let us know what right you want to exercise.

We will keep your personal information for the duration of our business relationship. We will also keep your personal data after we have finished acting for you in order to respond to any questions, complaints or legal disputes in relation to the business relationship, to demonstrate that we have treated you fairly and to keep any records required by law. We will also retain your personal data for our legitimate business purposes. We will not retain your data for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of data in accordance with our data retention, marketing and destruction policies, confirmation of which are available on request.

9. CHANGES TO OUR PRIVACY POLICY

We may change this Privacy Policy from time to time. Any changes we may make to our privacy policy in the future will be posted on this page. Please check back frequently to see any updates or changes to our privacy policy, printing a copy for your records for these purposes.

10. HOW TO COMPLAIN

We hope that we can resolve any query or concern you may raise about the use of your personal data.

The General Data Protection Regulation also gives you the right to lodge a complaint with the supervisor authority responsible for data protection matters, which in the UK is the Information Commissioner's Office (the “ICO”). The ICO may be contacted at https://ico.org.uk/ or by telephone (0303 123 1113).

11. HOW TO CONTACT US

Please contact us by post, e-mail or telephone if you have any questions about this privacy policy or the information we hold about you. Our contact details are:

E-mail: info@qubictrustees.co.uk

Registered address: 3rd Floor, 2 St James Gate, Newcastle Upon Tyne NE1 4AD

Telephone: 0191 232 2001