07970 720728

Who we are

We are IMH Advisory LLP and our website address is: http://www.imhadvisory.com

IMH Advisory LLP Privacy Policy

IMH Advisory LLP is committed to protecting information that identifies and relates to you or other individuals (personal information) and complying with data protection laws.

This privacy policy sets out IMH Advisory LLP’s personal information collection and sharing practices in relation to the personal information that we collect and use in providing capital allowances advisory services. This privacy policy also covers any personal information collected through your use of IMH Advisory LLP’s website.

The persons to which this privacy policy applies:

Clients, suppliers, advisers, service providers, enquirers and their agents (“you”)

Important

Please read this privacy policy with care. It provides information about how we use personal information and the rights available to you under data protection laws.

The Data Protection Act 2018 (“DPA 2018”) and the General Data Protection Regulation (“GDPR”) impose certain legal obligations in connection with the processing of personal data.

IMH Advisory LLP is a data controller within the meaning of the GDPR and we process personal data. The firm’s contact details are provided at point 9 below.

Layered Approach

Data protection laws require us to provide you with a lot of information about how we collect and use your personal information – and it is easy for all this information to become confusing rather than helpful.

We use a layered approach to provide you with the information required by law. This means that we may provide the information required in different formats and documents. In our initial contact with you, we may provide you only with the most important information about how we will use your personal information; but we will always provide you with easy access to all the further information you need about our privacy practices.

As an example, if you engage us for capital allowances services, then we may use this three-layer approach:

• A short form privacy notice in your terms of engagement that refers to this privacy policy
• Access to this privacy policy online or by post
• Additional privacy notice terms in your letter of engagement that accompanies the terms of engagement, tailored to the specific advisory services provided and data involved if required

By using this three-layer approach, we provide you with both specific and general information about how we use personal information to provide you with the insurance cover or advisory services that you require, whilst at the same time making sure that you get the most important information without overwhelming you with facts and information about all our privacy practices in one go.

How this privacy policy works

This privacy policy is intended to explain our privacy practices and covers the following areas:

1. Information we may collect about you
2. Why we collect information about you
3. How we may use your personal information
4. Consent
5. Sharing your personal information
6. Transmission, storage and security of your personal information
7. Retention of your personal information
8. Your rights
9. Contacting us
10. Changes to our privacy policy
11. Your right to complain

1 – Information we may collect about you

We may collect and process the following personal information about you:

• information that you provide by filling in forms or upload to us
• information including your name, address, contact details
• for advisory services, this includes details relating to your instructions for us to provide advisory services, the administration and management of those services
• if you contact us, we may keep a record of that correspondence, voicemail or details of any conversation we may have with you
• details of your visits to our website and information collected through cookies and other tracking technologies including, but not limited to, your IP address and domain name, your browser version and operating system, traffic data, location data, web logs and other communication data, and the resources that you access;
• details of transactions you carry out through our website, such as the contact form
• information that is available from publicly available sources including social media websites.

2 – Why we collect information about you

We may process personal information for certain legitimate or lawful purposes in some or all the following ways:

• for the performance of a contract with you or to take steps to enter a contract
• to maintain our accounts and records
• to modify, personalise or otherwise improve our services/ communications
• to correspond with clients, beneficiaries and claimants in order to facilitate the insurance policies or advisory services
• to comply with a legal obligation
• to gather market intelligence, communicate with and tailor offers to individuals
• for training and quality purposes

3 – How we may use your personal information

We may use your personal information in the following ways:

• to make decisions on whether to provide capital allowances advisory services
• to manage your engagement with us for advisory services
• to identify you and to carry out any identity checks as may be required by applicable law and best practice at any given time
• to recover any payments due to us and where necessary to enforce such recovery through the engagement of debt collection agencies or taking other legal action
• to analyse it in order to understand the service we provide and in order to improve our business
• to manage our business operations and comply with internal policies and procedures
• to notify you about changes to our service; and
• for marketing services to you by post, email, SMS, phone.

We will never process your data where these interests are overridden by your interests.

4 – Consent and legal basis for processing of personal data

Our intended processing of personal data has the following legal basis:  It is necessary for the performance of our contract with you.

Your consent to our processing of your personal information for certain purposes may be necessary to comply with applicable data protection laws; and where this is the case, we will ask you for your consent in accordance with those laws.

You may withdraw your consent to such processing at any time. However, if you withdraw your consent in relation to advisory services that we have provided then this is likely to impact our ability to provide those advisory services.

5  – Sharing your personal information

IMH Advisory LLP may make personal information available to:

Other third parties

We may also permit selected third parties and agents including HMRC, service providers, and financial organisations to access your personal information for the purposes set out in section 2. All such exchanges will be made in accordance with applicable laws. If false or inaccurate information is provided and/or fraud is identified or suspected, details may be passed to fraud prevention and anti-money laundering agencies, law enforcement agencies and may be recorded by us or by them.

Governmental authorities and third parties involved in court actions

We may disclose your personal information to third parties, the courts and/or regulators or law enforcement agencies in connection with enquiries, proceedings or investigations by such parties anywhere in the world or in order to enable IMH Advisory LLP to comply with its regulatory requirements or dialogue with its regulators as applicable.

6 – Transmission, storage and security of your personal information

Unfortunately, no data transmission can be guaranteed to be secure from intrusion. However, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your personal information in accordance with applicable data protection laws.

All information within our control is stored on a secure computer system (or secure hard copies) and accessed and used subject to our security policies and standards.

Where IMH Advisory LLP discloses your personal data to a third party, we require that third party to have appropriate technical and organisational measures in place to protect your personal data.

7 – Retention of your personal information

We will retain your personal information for as long as is reasonably necessary for the purposes listed in section 2 of this privacy policy. This may mean that we hold your personal information for some time where, for instance, there is a possibility that it may be needed in connection with a capital allowances claim or advisory services, or where we are obliged to keep it to comply with tax, accounting, regulatory or legal requirements.

We maintain a data retention policy that we apply to all data in our care. Where your personal information is no longer required, we will ensure it is securely deleted.

8 – Your rights

Data protection laws give you rights in relation to the personal information we hold about you, which may include the right to require us to:

• provide you with further details on the use we make of your personal information
• provide you with a copy of the personal information we hold about you
• update any inaccuracies in the personal information we hold about you
• delete any of your personal information that we no longer have a lawful ground to use
• where processing is based on consent, stop that processing by withdrawing your consent
• object to any processing based on our legitimate interests unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights
• restrict how we use your personal information whilst a complaint is being investigated
• transfer your personal information to a third party in a standardised machine-readable format
• In certain circumstances, we may need to restrict your rights in order to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege).

As noted above you have a right to request access to your personal data that we hold. Such requests are known as ‘subject access requests’ (“SARs”).  Please provide all SARs in writing marked for the attention of ian@imhadvisory.com

9 – Contacting us

You can contact us about data protection and privacy related issues by

• sending an email to ian@imhadvisory.com
• writing to IMH Advisory LLP, 52 Windhill, Bishops Stortford, Hertfordshire, CM23 2NH.

10 – Changes to our privacy policy

We may change the content of our website or services without notice, and consequently, our privacy policy may change at any time in the future. We, therefore, encourage you to review it from time to time to stay informed of how we are using personal information.

This privacy policy was last updated in January 2020.

11 – Your right to complain

If you are not satisfied with our use of your personal information, or our response to any request by you to exercise your data protection rights, or if you think that we have breached any relevant data protection laws, then you have the right to complain to the authority that supervises our processing of your personal information. In the UK, this is the ICO, details of which can be found here https://ico.org.uk/

If you are unsure of the authority that supervises our processing of your personal information, then please contact ian@imhadvisory.com for further guidance.