Privacy Policy

Contents

1. Introduction
2. Who we are
3. Collection of personal data
4. Lawful basis for the processing of personal data
5. Storage of personal data
6. Security measures
7. Your rights as a data subject
8. Contact us
9. Complaints

1. Introduction

We appreciate the trust you place in us when sharing your personal data. The security of that data is very
important to us. In this document, we will explain how we collect, use and protect your personal data.

We will also explain what rights you have with regards to your personal data and how you can exercise those
rights.

2. Who We Are

Stormcatcher Law, Stormcatcher Business Lawyers and Lawplan are trading names of Law Plan Services Limited, registered in England. Registered No: 10443305. Registered Office 58 Doods Park Road, Reigate, Surrey RH2 0PY

If you have questions about how we process personal data, or would like to exercise your data subject rights,
please email us at knowledge@stormcatcher.co.uk.

3. Collection of personal data

We collect personal data from you for one or more of the following purposes:

1. To provide you with information that you have requested or which we think may be relevant to a subject in
   which you have demonstrated an interest;
2. To initiate and complete commercial transactions with you, or the entity that you represent, for the
   purchase of products and/or services;
3. To fulfil a contract that we have entered into with you or with the entity that you represent;
4. To ensure the security and safe operation of our websites and underlying business infrastructure, and
5. To manage any communication between you and us.

The table in Section 4 below provides more detail about the data that we collect for each of these purposes, the
lawful basis for doing so, and the period for which we will retain each type of data.

Technical information

In addition, and in order to ensure that each visitor to any of our websites can use and navigate the site
effectively, we collect the following:

• Technical information, including the Internet Protocol (IP) address used to connect your device to the
  Internet;
• Your login information, browser type and version, time zone setting, browser plug-in types and versions;
• Operating system and platform;
• Information about your visit, including the Uniform Resource Locators (URL) clickstream to, through, and
  from our site.

Our cookies policy, which can be viewed from the all pages of our web site, describes in detail how we use
cookies.

To manage the cookies and similar technologies used (tracking pixels, web beacons, etc.) and related consents, we use the consent tool “Real Cookie Banner”. Details on how “Real Cookie Banner” works can be found at https://devowl.io/rcb/data-processing/.

The legal basis for the processing of personal data in this context are Art. 6 (1) (c) GDPR and Art. 6 (1) (f) GDPR. Our legitimate interest is the management of the cookies and similar technologies used and the related consents.

The provision of personal data is neither contractually required nor necessary for the conclusion of a contract. You are not obliged to provide the personal data. If you do not provide the personal data, we will not be able to manage your consents.

In Section 7 below, we identify your rights in respect of the personal data that we collect and describe how you
can exercise those rights.

4. Lawful basis for the processing of personal data

The table below describes the various forms of personal data we collect and the lawful basis for processing this
data. Our business architecture, accounting and systems infrastructure and compliance organisation means that
all personal data is processed on common, group-wide platforms. We have processes in place to make sure that
only those people in our organisation who need to access your data can do so. A number of data elements are
collected for multiple purposes, as the table below shows. Some data may be shared with third parties and, where
this happens, this is also identified below.

When we process on the lawful basis of legitimate interest, we apply the following test to determine whether it
is appropriate:

The purpose test – is there a legitimate interest behind the processing?

Necessity test – is the processing necessary for that purpose?

Balancing test – is the legitimate interest overridden, or not, by the individual’s interests, rights or
freedoms?

5. Storage of personal data

Stormcatcher is a UK-domiciled organisation whose primary offices are in the UK.

• Our website and web applications are hosted in the EU and are accessed only by our EU-based staff.
• We use a wide range of Cloud Service Providers (CSPs) as part of our processing environment. Unless we
  specifically state otherwise, we are, in respect of all these CSPs, the data controller.
• Unless we specifically state otherwise all of the CSPs that we use utilise EU-located processing facilities.
• We resell products supplied by organisations who may be outside the EU. This may mean that our resale
  partner will have access to information about data subjects who purchase their products.
• We operate a data retention policy in respect of all data, whether paper-based or digital and those aspects
  of it which relate to personal data are contained in the table at 4, above.

6. Security Measures

We have what we believe are appropriate security controls in place to protect personal data. Risk assessment,
including assessing risks to the rights and freedoms of data subjects, is at the heart of our information
security management system (ISMS). We do not, however, have any control over what happens between your device
and the boundary of our information infrastructure. You should be aware of the many information security risks
that exist and take appropriate steps to safeguard your own information. We accept no liability in respect of
breaches that occur beyond our sphere of control.

7. Your Rights as a Data Subject

As a data subject whose personal information we hold, you have certain rights. If you wish to exercise any of
these rights, please email privacy@stormcatcher.co.uk or use the
information supplied in the Contact us section below. In order to process your request, we will ask you to
provide two valid forms of identification for verification purposes. Your rights are as follows:

• The right to be informedAs a data controller, we are obliged to provide clear and transparent information about our data
  processing activities. This is provided by this privacy policy and any related communications we may
  send you.
• The right of accessYou may request a copy of the personal data we hold about you free of charge. Once we have verified your
  identity and, if relevant, the authority of any third-party requestor, we will provide access to the
  personal data we hold about you as well as the following information:
  1. The purposes of the processing
  2. The categories of personal data concerned
  3. The categories of personal data concerned
  4. The recipients to whom the personal data has been disclosed
  5. The retention period or envisioned retention period for that personal data
  6. When personal data has been collected from a third party, the source of the personal data
   If there are exceptional circumstances that mean we can refuse to provide the information, we will
  explain them. If requests are frivolous or vexatious, we reserve the right to refuse them. If answering
  requests is likely to require additional time or occasions unreasonable expense (which you may have to
  meet), we will inform you.
• The right to rectificationWhen you believe we hold inaccurate or incomplete personal information about you, you may exercise your
  right to correct or complete this data. This may be used with the right to restrict processing to make
  sure that incorrect/incomplete information is not processed until it is corrected.
• The right to erasure (the ‘right to be forgotten’)Where no overriding legal basis or legitimate reason continues to exist for processing personal data, you
  may request that we delete the personal data. This includes personal data that may have been unlawfully
  processed. We will take all reasonable steps to ensure erasure.
• The right to restrict processingYou may ask us to stop processing your personal data. We will still hold the data, but will not process
  it any further. This right is an alternative to the right to erasure. If one of the following conditions
  applies you may exercise the right to restrict processing:
  1. The accuracy of the personal data is contested
  2. Processing of the personal data is unlawful
  3. We no longer need the personal data for processing but the personal data is required for part of a
     legal process
  4. The right to object has been exercised and processing is restricted pending a decision on the status
     of the processing
• The right to data portabilityYou may request your set of personal data be transferred to another controller or processor, provided in
  a commonly used and machine-readable format. This right is only available if the original processing was
  on the basis of consent, the processing is by automated means and if the processing is based on the
  fulfilment of a contractual obligation.
• The right to objectYou have the right to object to our processing of your data where
  • Processing is based on legitimate interest;
  • Processing is for the purpose of direct marketing;
  • Processing is for the purposes of scientific or historic research;
  • Processing involves automated decision-making and profiling.

8. Contact Us

Any comments, questions or suggestions about this privacy policy or our handling of your personal data should be emailed to knowledge@stormcatcher.co.uk

9. Complaints

Should you wish to discuss a complaint, please feel free to contact us using the details provided above. All complaints will be treated in a confidential manner.

Should you feel unsatisfied with our handling of your data, or about any complaint that you have made to us about our handling of your data, you are entitled to escalate your complaint to a supervisory authority within the European Union. For the United Kingdom, this is the Information Commissioner’s Office (ICO), who is also our lead supervisory authority. Its contact information can be found at https://ico.org.uk/global/contact-us/.