top of page
Imperial Vulpen Advisory Logo

Privacy Notice

Imperial Vulpen: Privacy Notice

Imperial Vulpen Advisory Ltd. customer privacy notice:

This privacy notice tells you what to expect us to do with your personal information.

​​

Contact details:

963 Fulham Road, LONDON, Greater London, SW6 5JJ, GB

​

Email:

enquiries@imperial-vulpen.com

 

What information we collect, use, and why:

We collect or use the following information to provide services and goods, including delivery:

  • Names and contact details

  • Addresses

  • Date of birth

  • Purchase or account history

  • Payment details (including card or bank information for transfers and direct debits)

  • Website user information (including user journeys and cookie tracking)

  • Photographs or video recordings

  • Call recordings

  • Records of meetings and decisions

  • Information relating to compliments or complaints

We collect or use the following information for recruitment purposes:

  • Contact details (eg name, address, telephone number or personal email address)

  • Date of birth

  • Employment history (eg job application, employment references or secondary employment)

  • Education history (eg qualifications)

  • Right to work information

  • Security clearance details (eg basic checks and higher security clearance)

We collect or use the following personal information for dealing with queries, complaints or claims:

  • Names and contact details

  • Address

  • Payment details

  • Account information

  • Purchase or service history

  • Correspondence

 

Lawful bases and data protection rights:

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

 

Our lawful bases for the collection and use of your data:

Our lawful bases for collecting or using personal information to provide services and goods are:

  • Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

  • Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

  • Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

  • We have a legitimate interest in managing and delivering our consultancy services, communicating with clients and prospective clients, maintaining records of consultations, meetings and decisions, managing client relationships, improving our services, and protecting our business interests. We only use personal information where necessary and proportionate, and we consider individuals’ rights and expectations.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Our lawful bases for collecting or using personal information for recruitment purposes are:

  • Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

  • Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

  • Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

  • We have a legitimate interest in managing recruitment, assessing candidates’ suitability for roles, reviewing applications, arranging interviews, taking up references where appropriate, keeping recruitment records, and protecting our business against legal claims. We only collect information relevant to the recruitment process and keep it for no longer than necessary.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:

  • Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

  • Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

  • Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

  • We have a legitimate interest in responding to queries, investigating and resolving complaints, keeping accurate records of communications and decisions, and establishing, exercising or defending legal claims. We only use personal information needed to handle the matter fairly, effectively and proportionately.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

 

Where we get personal information from:

  • Directly from you

 

How long we keep information:

For more information on how long we store your personal information or the criteria we use to determine this please contact us using the details provided above.

Our standard retention periods are set out below:

Category of information

Retention period

General enquiries and contact-form submissions that do not result in an engagement

Up to 24 months after our last meaningful contact with you

Prospective client information, unsuccessful proposals and quotations

Up to 24 months after the proposal, quotation or discussion ends

Client contact information and account records

For the duration of the client relationship and for 6 years after the relationship ends

Contracts, statements of work, accepted proposals and engagement documentation

6 years after the relevant engagement ends

Consultancy materials, project correspondence and records of advice provided

6 years after the relevant engagement ends

Invoices, payment records, expenses and other accounting or taxation records

6 years from the end of the financial year to which the information relates, or longer where required by law or by HM Revenue and Customs

Supplier, contractor and professional adviser records

For the duration of the relationship and for 6 years after it ends

Complaints, disputes and related correspondence

6 years after the matter is closed, or until any related legal proceedings have concluded

Records relating to data-protection requests, such as access or deletion requests

3 years after the request has been completed

Marketing contact information

Until you unsubscribe, withdraw your consent, object to the marketing, or we determine that the information is no longer accurate or useful

Marketing consent records

For as long as we rely on the consent and for up to 6 years after the consent is withdrawn or ceases to be relied upon

Marketing suppression records

For as long as reasonably necessary to ensure that we continue to respect your request not to receive marketing

Website enquiry and communications records

Up to 24 months after the communication, unless the information becomes part of a client or contractual record

Website security and access logs

Normally up to 12 months, unless a longer period is required to investigate a security incident or suspected unlawful activity

Cookie and website analytics information

For the periods stated in our Cookie Notice or within the relevant cookie-management tool

Recruitment information for unsuccessful applicants

6 months after the recruitment process ends, unless the applicant agrees that we may retain it for a longer stated period

Staff and director employment records

For the duration of employment or appointment and normally for 6 years after it ends

Payroll and PAYE records

At least 3 years from the end of the tax year to which the records relate

Information connected with actual or anticipated legal proceedings, fraud, regulatory enquiries or security incidents

Until the relevant matter has been fully resolved and any applicable claim or enforcement period has expired

When a retention period expires, we aim to securely delete or anonymise the information, unless we are legally required to retain it for longer.

Information may remain in secure backup systems for a limited period after deletion from our active systems. Backup information is not routinely accessed and will be removed when the relevant backups are overwritten under our normal backup cycle.

We may retain information for longer where:

  • a legal or regulatory obligation requires us to do so;

  • HM Revenue and Customs or another authority has opened an investigation;

  • the information is relevant to an actual or reasonably anticipated legal claim;

  • a complaint, dispute, fraud investigation or security incident remains unresolved; or

  • you have expressly asked us to retain the information and we have a lawful basis to do so.

We review our retention periods periodically and may delete or anonymise information earlier where it is no longer necessary.


 

Who we share information with:

Others we share personal information with:

  • Professional consultants

 

How to complain:

If you have any concerns about our use of your personal information, you can make a data protection complaint to us:

Email: enquiries@imperial-vulpen.com

Post: 963 Fulham Road, London, England, SW6 5JJ

You can view our data complaints procedure at this link: 

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO. 

The ICO’s address:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint

bottom of page