Privacy Policy

Welcome to Seneschal Specialist Services Limited (we, us or Seneschal) website privacy policy. Seneschal respects your privacy and is committed to protecting your personal data. This privacy policy (policy) will inform you as to how we look after your personal data when you visit our website www.theseneschal.com (our website) (regardless of where you visit it from). It aims to give you information on how we collect and process your personal data through your use of our website, including any data you may provide through our website when you contact us. This policy also informs you about your privacy rights and how the law protects you. It does not cover any third party website you have used to access our website or any third party websites that you access from our website.

This website is not intended for children and we do not knowingly collect datarelating to children. It is important that you read this policy 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 policy supplements other notices and privacy policies and is not intended to override them.

Important information and who we are

Contact Details

Our full details are:
Full name of legal entity: Seneschal Specialist Services Limited, a company
incorporated in the United Kingdom under registered company number 13861623.
Email address: barry@theseneschal.com
Postal address: Seneschal Specialist Services Limited, 7th Floor, 50 Broadway,
London, SW1H 0DB

Under the UK General Data Protection Regulation or the EU General Data Protection Regulation (collectively GDPR) and other relevant data protection legislation, Seneschal acts as the controller and is responsible for your personal data. When Seneschal collects personal data and determines the purposes and means of processing that personal data – for example, when Seneschal stores account information for account registration, administration, services access, or contact information as explained below – Seneschal acts as a controller.

Third-Party Links

Our website may include 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 statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

What kind of personal data do Seneschal process?

Information you supply to us

General Personal Data: This is personal information about you that you share with us as user of our website by online forms on our website, through email, through post, on the telephone, when you complete surveys, engage with our customer services team, or by any other means. You may also provide personal data when you report any technical or service issues in relation to our websites, including relevant notes about any issues and how we responded to resolve these. Marketing Information: You may also communicate your preferences in receiving marketing from us and our third parties and your communication preferences (including details you provide when you opt-in to receive marketing communications from us).

Personal data we collect

Technical Data from our Website: We use certain technical services to gather technical data online whenever you use our website (as a visitor) including information about your device and your visits to our websites such as your IP address, geographical location, browser type, referral source, internet service provider (ISP), clickstream data, browser type and language, time zone, length of visit and pages viewed, date or time stamps weblogs and other communication data. 

Personal data we receive from third parties

Device Data: analytics providers such as Google based outside the EU; advertising networks such as Google based outside the EU; and search information providers such as Google based outside the EU.

Publicly Available Information: we may collect personal information about you from other publicly available sources. This can include your name, address and other publicly available information. As far as possible, we ensure that where any third parties are involved in suppling such information, that they are compliant to do so. This may include credit reference agencies such as Experian, public registers such as the Companies House registry or the Electoral Register.

Keeping your personal data up to date

It is important that the data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

What information is not collected?

We do not intentionally collect sensitive personal data or special category data, including details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, genetic data or social security numbers. Nor do we collect any information about criminal convictions and offences. 

How is information 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:

1. Where we need to perform the contract we are about to enter into or have entered into with you.

2. 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.

3. Where we need to comply with a legal or regulatory obligation. For the avoidance of doubt, the types of lawful basis that we will rely on to process your personal data have the following meanings:

4. 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 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 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.

5. 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, including for the purposes set out in the “Our Standard Business Operations” section below.

6. 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.

7. Consent: Where required we may seek your consent to process certain and specific personal data. This data will be strictly limited to the purpose of processing, and extra security controls may be applied to this data in order to protect it. You have the right to withdraw consent to marketing at any time by contacting us.

Marketing 

We maintain multiple contact lists (with email addresses and other information) to allow us to communicate with individuals who do business with us or who have expressed an interest in our products or services. We may contact you to respond to requests that you make, for marketing purposes, to inform you of any updates or news in relation to us or our products, or to otherwise inform you of information related to our business. We strive to provide you with choices regarding personal data uses for marketing and advertising and currently use to manage our email correspondence. 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, as appropriate, at any time. Where you opt out of receiving marketing messages, this will not apply to personal data provided to us as a result of a product or service purchase or other transactions. We will never sell your personal data to any third party (as noted 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.

Legal Requirements 

We will keep and use your data in terms of any legal or regulatory requirements that we have and can use your data to protect our legal position, if legal action is required, including the recovery of any outstanding debts. By way of further example, we will share your personal data with the relevant agencies and without notice, where we are requested to or suspect fraudulent activities, money laundering, terrorist related activities. 

Enhancing our Services

We may use personal data for the purposes of providing, enhancing, or improving our IP geolocation, fraud detection, demographic targeting, and other Services and products.

Website Administration and Customisation

We may use the information we collect about you for a variety of website administration and customisation purposes. For example, we use your information to process your registration request, provide you with services and communications that you have requested, send you email updates and other communications, customise features and advertising that appear on our websites, deliver our websites content to you, measure Website traffic, measure user interests and traffic patterns, and improve our websites and the services and features offered via our websites.

What information is shared?

We may share your personal data with the parties set out below for the purposes set out above. We do not disclose personal data outside Seneschal, except in the situations listed in this section or in the section below on Compelled Disclosure, but may have to share your personal data with the categories of processors or controllers set out below for the purposes set out above or otherwise below:  any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006; with your employer or the other person or entity by whom you have been authorised to contact us, who can access all information you input, store or process using our website; with HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances); with third party purchasers, if we buy, sell or merge any business or assets of our business and are required to share data as part of the buying, selling or merger agreement or if our assets are acquired by a third-party, and data is transferred as part of the purchased assets. If any such change happens, we will ensure that it is under terms that preserve the confidentiality of your personal data, and we will notify you on our website or by email before any transfer of your personal data.

Any purchaser would be bound by the terms of this policy;  with professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services, where they have a need to know same for any of the purposes set out above; with reputable and trusted third-parties where we have asked them to contact you on our behalf, where you have given us consent, it is part of our contractual agreement, is a legal requirement or there is clear legitimate interest between us (these services may include sending you email, calling you by telephone, sending you information through the post etc.); with specific selected third parties, determined by us, if you breach any agreement with us, including so as to enforce our rights against you, including credit-reference agencies, debt-collection firms or service providers, solicitors or barristers and law enforcement agencies (if applicable) and with service providers acting as processors based in the European Union or United Kingdom or the United States who provide IT and system administration services, including for the performance of our contract with you, as set out below: When we transfer your data to our service providers, we remain responsible for it:  with email marketing services, such as Mailchimp to send marketing emails where you have opted in to receiving them. You can unsubscribe directly from any mailing list using the unsubscribe links provided within emails; with analytical service providers, such as Google Analytics, in order to analyse our website’ traffic to improve products and services; and with processors offering software tools, or USA, EU or UK based external servers (including externally provided original and backup servers), that are used to store personal data provided by you on our behalf (our current servers are maintained by Big Wet Fish, whose privacy policies are available at https://bigwetfish.hosting/privacy-policy/). 

By default, and unless we have agreed otherwise in writing with the location of these servers will be within the UK or EU, where the organisation on whose behalf you are using the Services is based in the UK or EU, or the USA, where the organisation on whose behalf you are using the Services is based in the USA has requested this. 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 the minimal personal data required for the specified purposes, in accordance with our instructions, where they have agreed to privacy restrictions similar to our own policy. We do not share, sell, rent, or trade personal data with third parties for their commercial purposes. We may also share personal data with your permission, so we can perform services you have requested.

How is my information secured?

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 is information collected and stored globally?

Information that we collect will be stored and processed in the United Kingdom in accordance with this policy. However, where any of the third-party service providers listed above have access to personal data, they must comply with applicable data privacy laws, including signing data transfer agreements such as EU standard contractual clause agreements, where required by law.

What happens if I have a complaint?

If you have concerns about the way Seneschal is handling your personal data, please let us know immediately. We want to help and there are several ways available that you can contact us. You may also email us directly at barry@theseneschal.com with the subject line “Data Privacy”. We will respond within the relevant timeframes required under data protection legislation. If you are a data subject based in the UK or European Union, you may 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 (www.ico.org.uk), or other competent supervisory authority of an EU member state if the Services are accessed outside the UK. We would appreciate the chance to deal with your concerns before you approach such bodies so would ask that you please contact us in the first instance.

How can I access my personal information?

Under certain circumstances, where you are a citizen of the European Union or UK, you have rights under data protection laws in relation to your personal data under GDPR and UK GDPR. 

You have the right 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. 

Please 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 (or object to processing) 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.

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 could refuse to comply with your request in these circumstances. Where you exercise one of your rights, we may need to request specific information from you to help us confirm your identity and ensure your right to exercise such 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. We try to respond to all legitimate requests within one month. Occasionally it may 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.

How do you communicate with users?

We will use your email address to communicate with you, if you have confirmed we may do so, and only for the reasons you have permitted. Emails by default are not disclosed with other users, even if you belong to the same organisation. Depending on your email settings, Seneschal may occasionally send notification emails about new features, requests for feedback, important policy changes, or offer user support. We also send marketing emails, including ones featuring new services and products offered by our commercial partners, but only with your consent. There is an unsubscribe link located at the bottom of each of the emails we send you.

Will your website Privacy Policy change?

Unless legally necessary (in which case you will be notified by email), any changes we may make to this privacy notice in the future will be posted on this page without further recourse or notice to you. If there are material changes to this policy or in how we use your personal data, we will prominently post such changes prior to implementing the change. We encourage you to periodically review this policy to be informed of how we are collecting and using your information. We keep this policy under regular review, for example, to reflect changing business circumstances and legal developments. Although most changes are likely to be minor, it may change and if it does, these changes will be posted on this page. Any changes shall be applicable without further notice.

How can I contact Seneschal?

Questions regarding this policy or our information practices should be directed to us via one of the contact methods that we have provided in this policy. 

Legal

This policy shall be governed by and interpreted in accordance with the laws of England and Wales and you irrevocably agree that the courts of England and Wales shall have exclusive jurisdiction to settle any dispute which may arise out of, under, or in connection with this policy.