Aldan Management Limited
Independent governance, restructuring and insolvency

Privacy

Privacy policy

INTRODUCTION  

This privacy policy sets out how Aldan Management Limited (“Aldan Management”) uses and protects your personal data.

CONTENTS

1. IMPORTANT INFORMATION AND WHO WE ARE

2. TYPES OF PERSONAL DATA WE COLLECT ABOUT YOU

3. HOW IS YOUR PERSONAL DATA COLLECTED?

4. HOW WE USE YOUR PERSONAL DATA

5. DISCLOSURE OF YOUR PERSONAL DATA

6. INTERNATIONAL TRANSFERS

7. DATA SECURITY

8. DATA RETENTION

9. YOUR LEGAL RIGHTS

10. CONTACT DETAILS

11. COMPLAINTS

12. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

13. THIRD PARTY LINKS

1.  IMPORTANT INFORMATION AND WHO WE ARE  

Purpose of this privacy policy  

This privacy policy gives you information about how Aldan Management collects and uses your personal data through your use of this website, including any data you may provide through this website when you complete a contact form.

This website is not intended for children and we do not knowingly collect data relating to children.

Controller

Aldan Management is the controller and is responsible for your personal data (collectively referred to as "we", "us" or "our" in this privacy policy).

We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights (paragraph 9), please contact the DPO using the information set out in the contact details section (paragraph 10).

2.  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, title. date of birth and gender.

  • Contact Data includes address, email address and telephone number(s).

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

  • Query Data includes free-form information submitted to us in a contact form, email or other communication with us.

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:

    • apply for our services;

    • give us feedback or contact us.

  • Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

    • Identity and Contact Data from publicly available sources such as Companies House, based inside OR outside of 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 a description of all the ways we plan to use 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.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

1. To answer queries from you which are submitted via our web site

Type of data: (a) Identity, (b) Contact, (c) Query

Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to develop our services and grow our business)

2. To manage our relationship with you which will include notifying you about changes to our terms or privacy policy

Type of data: (a) Identity, (b) Contact, (c) Marketing and Communications

Lawful basis for processing including basis of legitimate interest: (a) Performance of a contract with you, (b) Necessary to comply with a legal obligation, (c) Necessary for our legitimate interests (to develop our services and grow our business)

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

Type of data: (a) Identity, (b) Contact

Lawful basis for processing including basis of legitimate interest: (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

4. To make suggestions and recommendations to you about services that may be of interest to you

Type of data: (a) Identity, (b) Contact (c) Marketing and Communications

Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to develop our services and grow our business)

Direct Marketing  

You may 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 marketing.

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.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase or other transactions.

Cookies

For more information about the cookies we use and how to change your cookie preferences, please see our cookie policy.

5.  DISCLOSURE OF YOUR PERSONAL DATA  

We may share your personal data where necessary with the parties set out below for the purposes set out in Section 4 above.

  • External Third Parties:

    • Service providers acting as processors based either within or outside of the UK who provide IT and system administration services.

    • Professional advisers including lawyers, bankers, auditors and insurers based either within or outside of the UK who provide consultancy, banking, legal, insurance and accounting services

    • HM Revenue & Customs, fraud prevention agencies, regulators and other authorities based within or outside of the UK who require reporting of processing activities in certain circumstances.

  • 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.

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, such as the European Economic Area (the “EEA”) and the United States of America (the “USA”).

  • We may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK.

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

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?  

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.

We retain client engagement files, which may include personal data, for five or six years following the conclusion of an engagement (the duration depends on the type of engagement).

In some circumstances you can ask us to delete your data: see Section 9 below for further information.

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 Section 4 above 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.

  • 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 at info@aldanmanagement.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.

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 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.

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 contact us in the following

11. COMPLAINTS

You have the right to make a complaint to the Information Commissioner’s Office, the UK regulator for data protection issues. However, before doing so please make sure you have first made your complaint to us or asked us for clarification if there is something you do not understand.

12. CHANGES TO THE PRIVACY POLICY AND OUR DUTY TO INFORM YOU OF CHANGES

We keep our privacy policy under regular review.

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.