This privacy policy sets out how Penny Paddle Corporate Law Ltd uses and protects your personal data.
This privacy policy is provided in a layered format so you can click through to the specific areas set out
below.

1. IMPORTANT INFORMATION AND WHO WE ARE ( paragraph 1 )
2. TYPES OF PERSONAL DATA WE COLLECT ABOUT YOU ( paragraph 2 )
3. HOW IS YOUR PERSONAL DATA COLLECTED? ( paragraph 3 )
4. HOW WE USE YOUR PERSONAL DATA ( paragraph 4 )
5. DISCLOSURES OF YOUR PERSONAL DATA ( paragraph 5 )
6. INTERNATIONAL TRANSFERS ( paragraph 6 )
7. DATA SECURITY ( paragraph 7 )
8. DATA RETENTION ( paragraph 8 )
9. YOUR LEGAL RIGHTS ( paragraph 9 )
10. CONTACT DETAILS ( paragraph 10 )
11. COMPLAINTS ( paragraph 11 )
12. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
( paragraph 12 )
13. THIRD PARTY LINKS ( paragraph 13 )
1. Important information and who we are
Privacy policy
This privacy policy gives you information about how Penny Paddle Corporate Law Ltd collects and uses
your personal data through your use of this website, including any data you may provide when you register
with us, sign up to our newsletter or purchase a product or service.
This website is not intended for children and we do not knowingly collect data relating to children.
Controller
Penny Paddle Corporate Law Ltd is the controller and responsible for your personal data (collectively
referred to as "Company", "we", "us" or "our" in this privacy policy).

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If you have any questions about this privacy policy, including any requests to exercise your legal rights
( paragraph 9 ), please contact the Penny Paddle using the information set out in the contact details section
( paragraph 10 ).
2. The types of personal data we collect about you
Personal data means any information about an individual from which that person can be identified.
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, last name, any previous names, username or similar
identifier, marital status, title, date of birth and gender.
 Contact Data includes billing address, delivery address, 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 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, device ID and other technology on the devices you use to access this website.
 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 interact with and 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 which is not
personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate
individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to
analyse general trends in how users are interacting with our website to help improve the website and our
service offering.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
 Your interactions with us. You may give us your personal data by filling in online forms or by
corresponding with us by post, phone, email or otherwise. This includes personal data you
provide when you:
 Enquire about our products or services;
 subscribe to our service or publications;
 request marketing to be sent to you;
 enter a promotion or survey; or

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 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 [LINK] 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 is collected from the following parties:
 analytics providers such as Google based outside the UK; and
 advertising networks based inside the UK.
 Contact, Financial and Transaction Data is collected from providers of technical, payment and
delivery services.
 Identity and Contact Data is collected from data brokers or aggregators.
 Identity and Contact Data is collected from publicly available sources such as Companies House
and the Electoral Register based inside the UK.

4. How we use your personal data
Legal basis
The law requires us to have a legal basis for collecting and using your personal data. We rely on one or
more of the following legal bases:
 Performance of a contract with you: Where we need to perform the contract we are about to
enter into or have entered into with you.
 Legitimate interests: We may use your personal data where it is necessary to conduct our
business and pursue our legitimate interests, for example to prevent fraud and enable us to give
you the best and most secure customer experience. We make sure we consider and balance
any potential impact on you and your rights (both positive and negative) 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).
 Legal obligation: We may use your personal data where it is necessary for compliance with a
legal obligation that we are subject to. We will identify the relevant legal obligation when we rely
on this legal basis.
 Consent: We rely on consent only where we have obtained your active agreement to use your
personal data for a specified purpose, for example if you subscribe to an email newsletter.

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 the various
categories of 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.

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Purpose/Use Type of data Legal basis [and retention period]
To register you as a new
customer

(a) Identity
(b) Contact

Performance of a contract with you

To process and deliver your
order including:
(a) Manage payments, fees and
charges
(b) Collect and recover money
owed to us

(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and
Communications

(a) Performance of a contract with you
(b) Necessary for our legitimate interests
(to recover debts due to us)

To manage our relationship with
you which will include:
(a) Notifying you about changes
to our terms or privacy policy
(b) Dealing with your requests,
complaints and queries

(a) Identity
(b) Contact
(c) Profile
(d) Marketing and
Communications

(a) Performance of a contract with you
(b) Necessary to comply with a legal
obligation
(c) Necessary for our legitimate interests
(to keep our records updated and
manage our relationship with you

To enable you to partake in a
prize draw, competition or
complete a survey

(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and
Communications

(a) Performance of a contract with you
(b) Necessary for our legitimate interests
(to study how customers use our
products/services, to develop them and
grow our business)

To administer and protect our
business and this website
(including troubleshooting, data
analysis, testing, system
maintenance, support, reporting
and hosting of data)

(a) Identity
(b) Contact
(c) Technical

(a) Necessary for our legitimate interests
(for running our business, provision of
administration and IT services, network
security, to prevent fraud and in the
context of a business reorganisation or
group restructuring exercise)
(b) Necessary to comply with a legal
obligation

To deliver relevant website
content and online
advertisements to you and
measure or understand the
effectiveness of the advertising
we serve to you

(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and
Communications
(f) Technical

Necessary for our legitimate interests (to
study how customers use our
products/services, to develop them, to
grow our business and to inform our
marketing strategy)

To use data analytics to improve (a) Technical Necessary for our legitimate interests (to

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our website, products/services,
customer relationships and
experiences and to measure the
effectiveness of our
communications and marketing

(b) Usage define types of customers for our
products and services, to keep our
website updated and relevant, to develop
our business and to inform our marketing
strategy)

To send you relevant marketing
communications and make
personalised suggestions and
recommendations to you about
goods or services that may be of
interest to you based on your
Profile Data

(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and
Communications

Necessary for our legitimate interests (to
carry out direct marketing, develop our
products/services and grow our
business) OR Consent, having obtained
your prior consent to receiving direct
marketing communications

To carry out market research
through your voluntary
participation in surveys

Necessary for our legitimate interests (to
study how customers use our
products/services and to help us improve
and develop our products and services).

Direct marketing
You will receive marketing communications from us if you have requested information from us or purchased
goods or services from us and you have not opted out of receiving the marketing.
We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which
products, services and offers may be of interest to you so that we can then send you relevant marketing
communications.
Third-party marketing
We will get your express consent before we share your personal data with any third party for their own
direct marketing purposes.
Opting out of marketing
You can ask to stop sending you marketing communications at any time by following the opt-out links within
any marketing communication sent to you or by contacting us [LINK]].
If you opt out of receiving marketing communications, you will still receive service-related communications
that are essential for administrative or customer service purposes.
Cookies
For more information about the cookies we use and how to change your cookie preferences, please see
[LINK TO YOUR COOKIE POLICY].
5. Disclosures of your personal data

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We may share your personal data where necessary with the parties set out below for the purposes set out
in the table Purposes for which we will use your personal data above.
Specific third parties such as Spencer West LLP.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our
assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change
happens to our business, then the new owners may use your personal data in the same way as
set out in this privacy policy.

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. International transfers
We may transfer your personal data to service providers that carry out certain functions on our behalf. This
may involve transferring personal data outside the UK to countries which have laws that do not provide the
same level of data protection as the UK law.
Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of
protection is afforded to it by ensuring that the following safeguards are in place:
We will only transfer your personal data to countries that have been deemed by the UK to
provide an adequate level of protection for personal data.

7. 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.
8. 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.

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By law we have to keep basic information about our customers (including Contact, Identity, Financial and
Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see paragraph 9 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.
9. Your legal rights
You have a number of rights under data protection laws in relation to your personal data.
You have the right to:
Request access to your personal data (commonly known as a "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 in certain circumstances. 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) as the legal basis for that particular use of your data (including carrying
out profiling based on our legitimate interests). In some cases, we may demonstrate that we
have compelling legitimate grounds to process your information which override your right to
object.
You also have the absolute right to object any time to the processing of your personal data for
direct marketing purposes (see OPTING OUT OF MARKETING in paragraph 4 for details of
how to object to receiving direct marketing communications).
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
(see the table in section 4 for details of when we rely on your consent as the legal basis for
using your 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.

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Request restriction of processing of your personal data. This enables you to ask us to suspend
the processing of your personal data in one of the following scenarios:
If you want us to establish the data's accuracy;
Where our use of the data is unlawful but you do not want us to erase it;
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
You have objected to our use of your data but we need to verify whether we have overriding
legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us (see Contact details ( paragraph
10 ).
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
at 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.
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.
10. Contact details
If you have any questions about this privacy policy or about the use of your personal data or you
want to exercise your privacy rights, please Penny Paddle in the following ways:
Email address: penny.paddle@pennypaddlecorporatelaw.com
Postal address: The Old Carriage Works, Moresk Road, Truro, Cornwall, United Kingdom, TR1
1DG
11. Complaints
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO),
the UK regulator for data protection issues (www.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.
12. Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review.

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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, for example a new address
or email address.
13. Third-party links
This 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.