Serenity is the controller and responsible for your personal data (“Serenity”, “we”, “us” or “our”).
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.
The data we collect
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 as follows:
We collect special categories of personal data about you, including details about your race or ethnicity, this data is not collected directly but can be inferred due to the fact that we are required to obtain copies of passports when you engage us to provide you with professional services.
We collect and process the above data only where it is strictly necessary to do so in order to deliver the professional service that you have engaged us to provide and where we are under a legal or regulatory obligation to collect the data. Furthermore, we will only collect and process the above special categories of sensitive personal data where you have provided us with your explicit consent to do so.
You are not under any obligation to consent to us processing your sensitive personal data. However, without your consent, we won’t be able to make the necessary arrangements to provide the professional services that you have engaged us to provide. As a result, if you do not provide your consent, we will be unable to proceed with your instruction.
If you are happy to consent to our use of your sensitive personal data, you will also be able to withdraw your consent at any time. However, as this will prevent us from providing the professional service you have engaged us to provide, we will be required to treat any withdrawal of consent as a cancellation of your instructions. In such circumstances, we will be invoice you for any costs incurred prior to the withdrawal of your consent.
How your personal data is collected
We use different methods to collect data from and about you including when:
How your personal data is used
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:
We may use your data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which professional services and offers may be relevant for you. You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing. You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data that you have provided to us as a result of an engagement to provide you with professional services or other such transactions.
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.
Disclosures of your personal data
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.
We do not transfer your personal data outside the United Kingdom, without your express consent.
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.
How long will you keep my personal data?
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 addition to the above, by law we have to keep basic information about our clients for seven years after they cease being clients for tax purposes.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
If you wish to exercise any of the rights set out above, please contact us.
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 may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data. 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.
We try to respond to all legitimate requests within one month.