Privacy Notice, Cookie Notice & Data Retention Policy

splittingup.com (the “Website”) is brought to you by Splittingup.com Limited.

Splittingup.com Limited respects your privacy and is committed to protecting your personal data. This Privacy Notice (together with our terms and conditions)  will inform you as to how we look after your personal data when you visit our Website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This Privacy Notice is only in relation to this Website only. Should you wish to engage with any recommended service provider through our Website, please note that any personal data given will be regulated by the recommended service provider’s own privacy policy.

Please also use the Glossary to understand the meaning of some of the terms used in this Privacy Notice.

1. Important information and who we are
2. The data we collect about you
3. How is your personal data collected?
4. How we use your personal data
5. Disclosures of your personal data
6. Cookies
7. International transfers
8. Data security
9. Data retention
10. Your legal rights
11. Glossary
12. Data retention policy

1. Important information and who we are

Purpose of this Privacy Notice

This Privacy Notice aims to give you information on how Splittingup.com Limited collects and processes your personal data through your use of our Website, including any data you may provide through the Website when you request a consultation or email us directly or contact us using our online form.

Our Website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this Privacy Notice together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.  This Privacy Notice supplements other notices and privacy policies and is not intended to override them.

Data Controller

Splittingup.com Limited is a company registered in England and Wales. Our company registration number is 11940344 and our registered address is 12 West Road Ponteland, Newcastle upon Tyne, Northumberland, NE20 9SU.

Splittingup.com Limited is the controller and responsible for your personal data (collectively referred to as “Splittingup.com Limited”, “we“, “us” or “our” in this privacy notice) with ICO registration number ZB060515.

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: Splittingup.com Limited

Email address: joanne@splittingup.com

Changes to this Privacy Notice

We keep our Privacy Notice under regular review. Any changes we make to this Privacy Notice in the future will be posted on this page. Please regularly check back to see any changes to this Privacy Notice.

Third-party links

Our Website includes links to third-party websites, plug-ins and applications. 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 policies. When you leave our Website, we encourage you to read the privacy policy of every website you visit.

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).

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, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes address, email address and telephone numbers.
• Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Website.
• Enquiry Data includes summary of circumstances you may wish to provide to us that forms an enquiry.
• Usage Data includes information about how you use the Website.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

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 any communication you send to us includes details of any Special Categories of Personal Data, such information will be retained in line with the data retention section below.

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 link you to any relevant recommended service providers. 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 and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• give us feedback or contact us.

Automated technologies or interactions. As you interact with our Website, we will automatically collect Technical and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please refer to how we use cookies in section 6 below for further details.

• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below.
  • Technical Data from the following parties:

1. analytics providers such as Google based outside the UK; and
2. search information providers such as Google based outside the UK.

Informing us of changes

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.

Monitoring

We may monitor communications with you for the purpose of quality assurance, training, fraud prevention and compliance.

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 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.

View section 11 below to find out more about the types of lawful basis that we will rely on to process your personal data.

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.

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.

Marketing

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

Third-party Marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting Out

You can ask third parties to stop sending you marketing messages at any time by contacting them at any time.

5. Disclosures of your personal data

We may share your personal data with the third parties set out below for the purposes set out in the table above including;

• Internal Third Parties such as Major Family Law Limited, a company registered in England and Wales with company registration number 06972665, as a recommended legal services provider.
• External Third Parties such as business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.
• Other Third Parties such as analytics and search engine providers that assist us in the improvement and optimisation of the Website.

We may disclose your personal data to third parties:

• in the event that we sell, transfer or merge parts of our business or our assets, we may disclose your personal data to the prospective seller or buyer of such business or assets;
• if all, or substantially all, of our assets are acquired by a third party, in which case personal data held by us will be one of the transferred assets; and
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to enforce our terms and conditions.

We require all third parties 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. Cookies

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

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

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

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

We do not share the information collected by the cookies with any third parties.

Consent

There is a notice on our home page which describes how we use cookies and which also provides a link to this Privacy Notice. If you use our Website after this notification has been displayed to you, we will assume that you consent to our use of cookies for the purposes described in this Privacy Notice.

How to turn off cookies

If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may lose some of the functionality of the Website. For further information about cookies and how to disable them please go to: www.aboutcookies.org or www.allaboutcookies.org.

Monitoring

Our Website uses tracking software to monitor its visitors to better understand how they use it. This software is provided by Google Analytics which uses cookies to track visitor usage. The software will save a cookie to your computer’s hard drive in order to track and monitor your engagement and usage of our Website, but will not store, save or collect personal information. You can read Google’s privacy policy here for further information www.google.com/privacy.html.

7. International transfers

Some of our external third parties may be based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

8. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. 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.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Please also see section 12 below.

10. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• Complain 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 (ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

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.

11. Glossary

LAWFUL BASES

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.

12. Data retention policy

12.1 ABOUT THIS POLICY

• The records, personal data and non-personal data (collectively referred to as “data” in this Data Retention Policy) of Splittingup.com Limited (collectively referred to as “com Limited”, “we”, “us” or “our” in this Data Retention Policy) are important to how we conduct business.
• There are legal and regulatory requirements for us to retain certain data, usually for a specified amount of time. We also retain data to help our business operate and to have information available when we need it. However, we do not need to retain all data indefinitely, and retaining data can expose us to risk as well as be a cost to our business.
• This Data Retention Policy (referred to below as the “Policy”) explains our requirements to retain and to dispose of data and provides guidance on our data handling and disposal.

12.2 SCOPE OF POLICY

• This Policy covers data collected from the splittingup.com website (the “Website”) that we hold or have control over. This includes electronic data such as emails and electronic documents/forms.
• This Policy covers data that is held by third parties on our behalf, for example cloud storage providers or offsite records storage.
• This Policy explains the differences between our formal or official records, disposable information, confidential information belonging to others and data. It also gives guidance on how we classify our data.
• This Policy applies to Splittingup.com Limited’s collection of any data provided through the Website when website users accept our use of cookies or when they request a consultation or email us directly or contact us using our online form.

12.3 GUIDING PRINCIPLES

Through this Policy, and our data retention practices, we aim to meet legal and regulatory requirements to retain data.

12.4 TYPES OF DATA AND DATA CLASSIFICATIONS

• Disposable information. Disposable information consists of data that may be discarded or deleted at the discretion of the user once it has served its temporary useful purpose and/or data that may be safely destroyed because it is not a formal or official record as defined by this Policy and the Record Retention Schedule. Examples may include:
• Duplicate requests and enquiries.
• Personal data. Both formal or official records and disposable information may contain personal data; that is, data that identifies living individuals. Data protection legislation require us to retain personal data for no longer than is necessary for the purposes for which it is processed (principle of storage limitation).

12.5 RETENTION PERIODS

• Disposable information. This type of data should only be retained as long as it is needed for business purposes.
• Personal data. As explained above, data protection legislation require us to retain personal data for no longer than is necessary for the purposes for which it is processed (principle of storage limitation).

12.6 STORAGE, BACK-UP AND DISPOSAL OF DATA

• Our data will be stored in a safe, secure, and accessible manner.
• Destruction. We are responsible for the continuing process of identifying the data that has met its required retention period and supervising its destruction.