Privacy Policy

We are committed to protecting and respecting your privacy.

Lydford Advisory Limited (trading as Finerva) (“We”) are committed to protecting and respecting your privacy.

This policy, together with our terms of use (as set out on our website www.finerva.com) and any other documents referred to on it, sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of the UK GDPR, the controller of your data is Lydford Advisory Limited, a company registered in England and Wales under company number 08655612 whose registered office is at Mappin House, 4 Winsley Street, Spaces London W1W 8HF.

All your data will be held and used in accordance with the UK GDPR and any relevant national laws which implement the UK GDPR and any legislation that replaces it in whole or in part.

Information We may Collect from You

We may collect and process the following data about you:

Identity Data includes name, marital status, title, date of birth, gender and photograph.

Professional Data includes detail of your company including (but not limited to) its name or registration number.

Contact Data includes 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 other details of products and services you (or your company/ employer) have purchased from us.

Technical Data includes internet protocol (IP) address, your login data, 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 this website. This includes information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); content 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.

Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

Usage Data includes information about how you use our website, products and services.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for industry and market analysis, our marketing and advertising strategy or for any other business 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 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 policy.

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 goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

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 Identity, Professional, Contact and Financial Data by filling in forms on our site www.finerva.com (our site) or by corresponding with us by phone, e-mail or otherwise. This includes personal data you provide when you:

apply for our products or services;
create an account on our website;
subscribe to our service or publications;
request marketing to be sent to you;
enter a competition, promotion or survey; or
give us feedback or contact us.

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie policy set out on our website (www.finerva.com).
Information we receive from other sources or publicly available information. We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie policy set out on our website (www.finerva.com).

Uses made of the Information

We use information held about you in the following ways:

Information you give to us (i.e. Identity, Professional, Contact and Financial Data). We will use this information:
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;
to provide you with information about other goods and services we offer that are similar to those that you have already purchased;
to provide you, or permit selected third parties (further details of whom are set out in the ‘Disclosure of your Information’ section below) to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale to you, and you will be given an option to unsubscribe with each communication. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data (the registration form);
to notify you about changes to our service;
to ensure that content from our site is presented in the most effective manner for you and for your computer.

Information we collect about you (i.e. Technical Data). We will use this information:
to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
to allow you to participate in interactive features of our service, when you choose to do so;
as part of our efforts to keep our site safe and secure;
to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
Information we receive from other sources or publicly available information. We may combine this information with information you give to us and information we collect about you. We may us this information and the combined information for the purposes set out above (depending on the types of information we receive).

The Legal Basis for Processing your Information

In accordance with UK GDPR, the main grounds that we rely upon in order to process your information are as follows:

Necessary for entering into or performing a contract. In order to perform obligations which arise under any contract we have entered into with you, it will be necessary for us to process your information (i.e. to register you as a new customer, to provide the services to you, including manage payments, fees and charges, to manage our relationship with you, which will include notify you about the changes to our terms of service and privacy policy, or asking you to leave a review or survey)..
Necessary for compliance with a legal obligation. We are subject to certain legal requirements which may require us to process your information. We may also be obliged by law to disclose your information to a regulatory body or law enforcement agency (i.e. to administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
Necessary for the purposes of legitimate interests. Either we or a third party will need to process your information for the purposes of our (or a third party’s) legitimate interests, provided that we have established that those interests are not overridden by your rights and freedoms (including your right to have your information protected). Our legitimate interests include responding to requests and enquiries from you or a third party, optimising our website and user experience, informing you about our services and ensuring that our operations are conducted in an appropriate and efficient manner.
Consent. In some circumstances, we may ask for your consent to process your information in a particular way (for example, we will get your consent before sending you direct marketing communications via email or text message, or any third party marketing. You have the right to withdraw consent to marketing at any time by contacting us).

Disclosure of your Information

We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

We may share your information with selected third parties including:

Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.
Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others.
Analytics and search engine providers that assist us in the improvement and optimisation of our site.

Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
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.

If Lydford Advisory 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.

If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use (as set out on our site) or terms and conditions of supply and other agreements; or to protect the rights, property, or safety of Lydford Advisory Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

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.

International Transfers

The data that we collect from you may be transferred to, and stored at, a destination outside the United Kingdom (“UK”) or the European Economic Area (“EEA”). It may also be processed by staff operating outside the UK or the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

To the extent that any of your data is provided to third parties outside the UK or the EEA, or accessed by third parties from outside the UK or the EEA, we will ensure 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 (such as the European Commission’s standard contractual clauses, together with the UK Addendum).

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.

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

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.

Data Retention

We will only retain your information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. The criteria that we use to determine retention periods will be determined by the nature of the data and the purposes for which it is kept, the sensitivity of the data and the potential risk of harm from unauthorised use or disclosure.

Your Legal Rights

You have certain rights in relation to the personal data that we hold about you. Details of these rights and how to exercise them are set out below. Please note we will require evidence of your identity before we are able to respond to your request.

Right of Access (commonly known as “data subject access request”). You have the right at any time to ask us for a copy of the personal information that we hold about you and to check that we are lawfully processing it.  Where we have good reason, and if the UK GDPR permits, we can refuse your request for a copy of your personal information, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reasons for doing so.
Right of Correction or Completion. If personal information we hold about you is not accurate or is out of date and requires amendment or correction you have a right to have the data rectified or completed.
Right of Erasure. In certain circumstances, you have the right to request that personal information we hold about you is erased e.g. if the information is no longer necessary for the purposes for which it was collected or processed or our processing of the information is based on your consent and there are no other legal grounds on which we may process the information.
Right to Object to or Restrict Processing. In certain circumstances, you have the right to object to our processing of your personal information.  For example, if we are processing your information on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which override your rights and interests.

You may also have the right to restrict our use of your personal information, such as in circumstances where you have challenged the accuracy of the information and during the period where we are verifying its accuracy.

Right of Data Portability. In certain instances, you have a right to receive any personal information that we hold about you in a structured, commonly used and machine-readable format.

In such circumstances, you can ask us to transmit that information to you or directly to a third party organisation. While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third party organisation’s systems. We are also unable to comply with requests that relate to personal information of others without their consent. 

You can exercise any of these rights at any time by contacting us at hello@finerva.com.

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.

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.

Third Party Links. Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these 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.

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.  You can do this by contacting us using the details in the ‘Contact’ section below.

Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Changes to our Privacy Policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

Contact Details

If you have any questions, comments and requests about this privacy policy or our privacy practices, you can contact us at hello@finerva.com.

You have the right to make a complaint at any time with the UK Information Commissioner’s Office using any of the below contact methods. We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

Telephone: 0303 123 11113

Website: https://ico.org.uk/concerns/