Website privacy
This Privacy Policy (“Policy”) describes how Open Trustees collects, stores and uses Personal Information in the context of visitors to the Open Trustees website at www.opentrustees.com.
In this Policy, we use the terms “we”, “us”, and “our” (and other similar terms) to refer to Open Trustees (SRA reference: 80586) as owner of this website and who will be the data controller as prescribed in the entity’s local law (the “Data Controller”).
“OC Member Firm” to refer to any entity, including Osborne Clarke Verein, which is a member of international Osborne Clarke network (“Network Firm”) or which is a member firm of Osborne Clarke Verein, a Swiss Verein (“Osborne Clarke Verein Member Firm”).
“Network Firm” includes Osborne Clarke Services (company number: 3049484), Osborne Clarke Trustees Limited (SRA reference: 199769), Open Trustees Limited (SRA reference: 80586), Oval Nominees Limited (company number: 1865795), Ovalsec Limited (company number: 1379423) and Osborne Clarke International Services Ltd (company number: 8096377) – the registered office of each of the above companies is 2 Temple Back East, Temple Quay, Bristol, BS1 6EG.
“Osborne Clarke Verein Member Firm” includes (but is not limited to) those listed here. Each of the Osborne Clarke Verein Member Firm is a separately constituted and regulated legal entity or partnership which provides legal and other client services in accordance with the laws of the jurisdictions in which it operates. For the avoidance of doubt Osborne Clarke Verein is a Swiss verein which does not itself provide legal or other client services.
“Personal information” shall mean any information relating to an identified or identifiable natural person.
“Identifiable natural person” is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors.
“You” and “your” (and other similar terms) to refer website visitors.
1. Your rights in relation to the data and how to exercise them
You are entitled at any time to obtain confirmation of the existence of your Personal and Confidential Information and to be informed of the contents and origin, verify its accuracy, or else request that such data be supplemented, updated or rectified according to the provisions of local law.
You also have the right to request erasure, anonymisation or blocking of any data that is processed in breach of the law as well as to object in all cases, on legitimate grounds, to processing of the data.
You also have a right free of charge to object on legitimate ground to the processing of your Personal and Confidential Information and to object to the processing of your Personal and Confidential Information for marketing purpose.
To exercise such rights and if you have any questions about how we collect, store and use Personal and Confidential Information, then please contact us using the details provided below:
Write to us:
- In relation to the website to:The Privacy Officer, Osborne Clarke LLP, 2 Temple Back East, Temple Quay, Bristol, BS1 6EG; or
- In relation to any other relationship with us to:the Privacy Officer at the relevant OC Member Firm at their registered office as set out above.
E-mail us at: privacy@osborneclarke.com
2. What Personal Information do we collect?
We may collect, store and use the following Personal and Confidential Information in respect of website visitors:
- We may collect, store and use certain, limited information relating to your use of our website, if you have accepted the relevant cookies, for the purposes of better understanding the types of visitors who browse our website and improving our website offering. Other than information you choose to submit voluntarily to receive communications from us, the information we collect about website visitors does not enable any visitor to be individually identified, is processed only in anonymised, aggregated form, and will only be used for website analytics purposes as described in the section entitled “Website cookies” below.
We collect your Personal and Confidential Information through various means, including via our website, through e-mail correspondence, through direct contact (for example at marketing events and pension industry events).
The provision of your Personal and Confidential Information to us is optional – save for the case in which the law requires that this is provided (e.g. to enable us to comply with anti-money laundering regulation) in which case the provision of such data is mandatory and failure to provide the same may result in our inability to provide you with the services requested and subject you to administrative fines.
3. How will we use your Personal Information?
We use the Personal Information that we collect for the following purposes:
- For contact and communication purposes: We may use your contact information and preferences to send you legal updates that we may circulate from time to time, news about any events we are organising or participating in, and/or other information about us and the services that we or another OC Member Firm provides. We will only contact you in accordance with the contact preferences that you have specified. You can specify your contact preferences when registering online to receive communications from us (for example, through the Open Trustees website) or by subsequently advising us of your contact preferences using the contact details provided above.
- For website analytics purposes:If you have accepted the relevant cookies, we may collect, store and use certain, limited information relating to your use of the Open Trustees website for the purposes of better understanding the types of visitors who browse our website and improving our website offering. Other than information you choose to submit voluntarily to receive communications from an OC Member Firm, the information we collect about website visitors does not enable any visitor to be individually identified, is processed only in anonymised, aggregated form, and will only be used for website analytics purposes as described in the section entitled “Website cookies” below.
The processing operations connected with your Personal Information are only handled by authorised subjects or by persons appointed for the maintenance of the website.
4. Who else may have access to your Personal and Confidential Information?
We may pass your Personal and Confidential Information to third parties such as:
OC Member firms: Subject to compliance with local law, we also share your Personal and Confidential Information with OC Member Firms:
- To provide services to you and also:
- So that they may contact you (including by email), if you have expressly agreed to receive marketing communications about legal developments, services or events which may be of interest to you;
- Through the joint use of centralised IT tools;
- To manage our international client relationships;
- To respond to your requests concerning access, rectification, objection and cancellation as regards the processing of your personal data.
Disclosures required by law or regulation: In certain circumstances, please note that we may be required to disclose Personal and Confidential Information under applicable law or regulation, including to law enforcement agencies or in connection with proposed or actual legal proceedings.
5. International transfers of Personal Information (including to outsourced service providers)
As described above, from time to time, we may need to transfer your Personal Information to other OC Member Firms, who may have offices that are located in territories outside of the European Economic Area (“EEA”), including in the USA in order to provide you with the services required.
Please note that the legal regimes of some territories outside of the EEA do not always offer the same standard of data protection as those inside the EEA, although we will ensure that your Personal Information is only ever treated in accordance with this Policy and, if you are a client, our Engagement Letter.
Where necessary we have entered into standard European Commission approved form model data protection clauses with other OC Member Firms who have offices that are located in territories outside of the EEA, to provide you with the service required and with our external service providers and business partners in relation to services that they may provide that involve processing data from locations outside of the EEA for which we are Data Controller. If you would like to discuss any aspect of our arrangements with external service providers please contact the person responsible for your work.
If you or others on your behalf give us any Personal Information about another person, you take full responsibility for complying with any relevant data protection laws which apply to the provision of that information to us, and our use of it as explained in this Policy.
6. How we look after your Personal Information
Personal Information may be processed by either automated or manual methods.
We have in place appropriate technical and organisational security measures to protect your Personal Information against unauthorised or unlawful use, and against accidental loss, damage or destruction.
We put in place strict confidentiality agreements (including data protection obligations) with our third party service providers.
7. Website cookies
The Open Trustees website uses Google Analytics for website analytics purposes – meaning that we use them to see how many visitors come to our website, the pages that generate interest and the links that visitors most often click on (amongst other things). This means we also share information about your use of our site with our social media, advertising and analytics partners: for more information see here. Google Analytics uses cookies – small text files that are placed on your computer that store certain limited information about you. The cookies we use do not enable any website visitor to be individually identified and will only be used for website analytics purposes.
In addition, the coding language the Open Trustees website is written in uses session cookies. These are deleted each time you close your browser. These cookies do not store any information about the visitor once the browser is closed. For more information about cookies, we recommend that you visit www.allaboutcookies.org
You were given the opportunity to consent to our using cookies as you entered our site (to get this far, you have already either consented or opted out of their use). If you have opted out, we only store one permanent ‘compliance’ cookie which tells us that you want to opt out of use of any other cookies.
If you opted out then we have switched off all of them except our functional cookies which are needed to make the site run correctly. However, if you wish to do so, you can change your browser settings to reject cookies. As the means by which you can do this varies from browser to browser, please visit your web browser’s “Help” menu for further details. Please note that, should you choose to refuse cookies, this might impair some of the functionality of the Open Trustees website.
The cookies that we use on the site are:
Analytics Cookies
“_ga” is a Google Analytics cookie – It’s used to collect information about how visitors use the site. The information is collected anonymously, and used to report on the number of visitors to the site, where they have come from, and the pages they have visited. You can find out more info on Universal Analytics here.
“is_returning” – This cookie is used to anonymously visually interpret user behaviour on the site by building “Heat Maps”. This provides a graphical representation of where visitors click page links. You can find out more info on this cookie here.
“nmstat” is a siteimprove.com cookie – This cookie help record the visitor’s use of the website. This information is then used to improve the user experience on the website. This Siteimprove Analytics cookie contains a randomly generated ID used to recognise the browser when a visitor reads a page. The cookie contains no personal information and is used only for web analytics. You can find out more info on siteimprove.com cookies here.
Functional Cookies
ASPXAUTH – This cookie is used to make sure that your web experience, whilst on our site, is seamless as you move from page to page.
ASP.NET_SessionId – This cookie is installed automatically when a user connects to an ASP.NET application, and expires when the browser window closes. This provides a mechanism for persisting information between page requests in ASP.NET. You can find out more info on this cookie here and here.
Preference Cookies
“site-font-size” – This cookie remembers the font size selection for the session.
“site-css” – This cookie remembers the colour scheme for the session.
Compliance Cookies
“cb” and “szcookiechoice” – These cookies allows us to know whether or not you have given consent to the use of cookies and therefore do not need to be presented with this message again. This is a permanent cookie.
8. Updates to this Policy
This Policy was last updated on 1 November 2015. Please note that for legal, business or operational reasons we may from time to time update this Policy. We will highlight any material changes that we make to this Policy on the Open Trustees website.
9. Links to other websites
The Open Trustees website may link to other, unaffiliated third party websites. Please note that Open Trustees is not, and cannot, control or be responsible for the content or privacy and confidentiality practices of any third party websites. You must always carefully review the privacy and confidentiality policy of any third party website that you may visit in order to understand how the operators of that website may collect, store and use your personal and confidential information.
(Reviewed November 2015)