PRIVACY POLICY FOR The Siena Partnership Ltd

1. 1. INTRODUCTION
      • In this Privacy Policy:
        • references to we, us or our means The Siena Partnership Ltd, a limited company registered in England (company number: 12916152), whose registered office is Brookwood House, 84 Brookwood Road, London, United Kingdom, SW18 5BY;
        • references to you or your means the person accessing and using the Website (as defined below) or existing client’s and third parties;
        • references to the Website means the website found at https://www.thesienapartnership.com; and
        • personal information is information that is about you and which identifies you.
      • This Privacy Policy describes in detail who is responsible for the personal information that we collect about you, what personal information we collect, how we will use such personal information, who we may disclose it to and your rights and choices in relation to your personal information.
   2. Who is responsible for the personal information that we collect?
      • We are the data controller for the purpose of data protection law, in respect of your personal information collected we don’t sell or pass on your information to third parties without consent. Data stored is for internal use only. This is because we dictate the purpose for which your personal information is used and how we use your personal information.
      • If you have any questions regarding this Privacy Policy or the way we use your personal information, you can contact the Data Protection Officer by email or post at tom@thesienapartnership.com or Brookwood House, 84 Brookwood Road, London, United Kingdom, SW18 5BY
   3. What personal Information do we hold about you?
      • The personal information we collect includes:
        • Information that you provide to us:
          

          Type of Personal Information	Examples
          Contact information	Name, address, email and telephone number
          General information	Gender, marital and family status, date and place of birth, as well as data provided through social media platforms with consent.
          Business contact information	Name, address, email and telephone number
          Marketing preferences, marketing activities and client feedback	Marketing preferences or responses to voluntary client satisfaction surveys To improve our marketing communications, we may collect information about interaction with, and responses to, our marketing communications

        • This information may be provided:
          • in the course of communications between you and us (including by phone, email or otherwise); and
          • via our social media pages, other social media content, tools and applications.
        • Information we collect from you
          

          Type of information	Method of data collection	Examples
          Technical information	Through your internet browser or electronic device	Certain information is collected by most websites or automatically through your electronic device, such as your IP address (i.e. your computer’s address on the internet), screen resolution, operating system type (Windows or Mac) and version, internet browser type and version, electronic device manufacturer and model, language, time of the visit and pages visited.
          Technical information	Using cookies and online tracking	Cookies are pieces of information stored directly on the device you are using to access our Website. Cookies allow us to recognise your device and to collect information such as IP address, internet browser type, time spent using the Website and the pages visited.

        • Information we receive from other sources
          • information from any of the other websites we operate or the other services we provide;
          • information we obtain from publicly available sources such as Facebook, LinkedIn, Twitter; and
          • Business development agencies.
        • Information about third parties
          • You may provide us with personal information relating to third parties. For example, the personal information we collect in respect of:
            • Primary contact, including; Full Name, Job Title, Email and/or Phone number.
          • We will use this personal information in accordance with this Privacy Policy.  If you are providing personal information to us relating to a third party, you confirm that you have the permission of the third party to share such personal information with us and that you have made the information in this Privacy Policy available to the third party.
   4. How do we use the personal information we collect about you?
      • Your personal information may be used by us, our employees, service providers, and disclosed to third parties for the following purposes.  For each of these purposes, we have set out the legal basis on which we use your personal information.
        

        Purpose	Legal Basis
        To carry out our obligations arising from any contracts entered into between you and us.	performance of a contract between you and us;
        To manage complaints, feedback and queries.	compliance with legal obligations to which we are subject.
        To carry out market research and analysis.	our legitimate business interests in order for us to manage our relationship with you;
        To carry out satisfaction surveys and analysis.	our legitimate business interests in order for us to manage our relationship with you;
        To provide you with information about the services we offer regarding digital marketing and brand PR which we believe may be of interest to you in accordance with your preferences as indicated when you entered into any agreement with us, including any marketing consent preferences.	consent; and/or
        To comply with any legal or regulatory obligations (including in connection with a court order).	compliance with legal obligations to which we are subject.
        To enforce or apply the agreements concerning you (including agreements between you and us).	performance of a contract between you and us;

      • We may be required to obtain your personal information to comply with our legal requirements, to enable us to fulfil the terms of our contract with you (including Terms of Engagement and/or Scope of Work and/or Maintenance Agreement) or in preparation of us entering into a contract with you.  If you do not provide the relevant personal information to us, we may not be able to provide a contract to you.
   5. Who may we disclose your personal information to?
      • You agree that we may share your personal information with:
        

        Type of third party	Examples
        General
        Our service providers	Our business partners, suppliers and sub-contractors for the performance of any contract we enter into with you.
        Our professional advisers	Including accountants, lawyers and other professional advisers that assist us in carrying out our business activities
        Government authorities and third parties involved in court action	External agencies and organisations (including the police, the relevant local authority, the UK Visas and Immigration department and other law enforcement agencies) for the purpose of complying with applicable legal and regulatory obligations

      • We may also disclose your personal information to other third parties, for example:
        • in the event that we sell or buy any business or assets we will disclose your personal information to the prospective seller or buyer of such business or assets;
        • if we or substantially all of our assets are acquired by a third party (or are subject to a reorganisation within our corporate group), personal information held by us will be one of the transferred assets; and
        • if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our the agreements concerning you (including agreements between you and us).
   6. Where will we transfer your personal information?
      • If we transfer personal information outside the European Economic Area (EEA), we will implement appropriate and suitable safeguards to ensure that such data will be protected as required by applicable data protection law. For further information as to the safeguards we implement please contact tom@thesienapartnership.com.
   7. How long will we keep your personal information
      • If you are a client or employee, we will keep your personal information for the duration of the contract and a period of 5 years after the contract ends.
   8. Your rights
      • You have certain rights with respect to your personal information.  The rights may only apply in certain circumstances and are subject to certain exemptions.  Please see the table below for a summary of your rights. You can exercise these rights using the contact details below.
        

        	Summary of your rights	Who to contact
        Right of access to your personal information	You have the right to receive a copy of your personal information that we hold about you, subject to certain exemptions.	tom@thesienapartnership.com
        Right to rectify your personal information	You have the right to ask us to correct your personal information that we hold where it is incorrect or incomplete.	tom@thesienapartnership.com
        Right to erasure of your personal information	You have the right to ask that your personal information be deleted in certain circumstances.  For example (i) where your personal information is no longer necessary in relation to the purposes for which they were collected or otherwise used; (ii) if you withdraw your consent and there is no other legal ground for which we rely on for the continued use of your personal information; (iii) if you object to the use of your personal information (as set out below); (iv) if we have used your personal information unlawfully; or (v) if your personal information needs to be erased to comply with a legal obligation.	tom@thesienapartnership.com
        Right to restrict the use of your personal information	You have the right to suspend our use of your personal information in certain circumstances.  For example (i) where you think your personal information is inaccurate and only for such period to enable us to verify the accuracy of your personal information; (ii) the use of your personal information is unlawful and you oppose the erasure of your personal information and request that it is suspended instead; (iii) we no longer need your personal information, but your personal information is required by you for the establishment, exercise or defence of legal claims; or (iv) you have objected to the use of your personal information and we are verifying whether our grounds for the use of your personal information override your objection.	tom@thesienapartnership.com
        Right to data portability	You have the right to obtain your personal information in a structured, commonly used and machine-readable format and for it to be transferred to another organisation, where it is technically feasible. The right only applies where the use of your personal information is based on your consent or for the performance of a contract, and when the use of your personal information is carried out by automated (i.e. electronic) means.	tom@thesienapartnership.com
        Right to object to the use of your personal information	You have the right to object to the use of your personal information in certain circumstances. For example (i) where you have grounds relating to your particular situation and we use your personal information for our legitimate interests (or those of a third party); and (ii) if you object to the use of your personal information for direct marketing purposes.	tom@thesienapartnership.com
        Right to withdraw consent	You have the right to withdraw your consent at any time where we rely on consent to use your personal information.	tom@thesienapartnership.com
        Right to complain to the relevant data protection authority	You have the right to complain to the relevant data protection authority, which is, in the case of The Siena Partnership Ltd, the Information Commissioner’s Office, where you think we have not used your personal information in accordance with data protection law.	Tel: +44(0) 333 090 1246

   9. Third party links
      • The 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 how they handle your personal information. When you leave our Website, we encourage you to read the privacy notice of every website you visit.
   10. Cookies
       • The Website uses cookies to distinguish you from other users of the Website.  This helps us to provide you with a good experience when you browse the Website and also allows us to improve the Website . For detailed information on the cookies we use and the purposes for which we use them, see our Cookie Policy [view cookie policy].
   11. Changes to our privacy policy
       • Any changes we make to this Privacy Policy in the future will be posted on this page and, where appropriate, notified by email.  The updated Privacy Policy will take effect as soon as it has been updated or otherwise communicated.

This Privacy Policy was last updated in 30/09/2023..