Threadneedle Law Limited (trading as Threadneedle or Threadneedle Law) ( “Threadneedle Law”, “Threadneedle”, “our”, “us” and/or “we”), respects your privacy and is committed to protecting your personal data.
In this policy, we explain how we collect and use your personal data: during the course of our business, when you visit www.threadneedle.law (the “website”), submit information via our contact form and/or sign up to our newsletter.
Your personal data is valuable and belongs to you. Whilst third parties - such as Threadneedle - are allowed under certain circumstances to collect and use your personal data, you can in many circumstances tell us not to use it and/or to erase it from our systems. This is subject to a few exceptions which are discussed below at “4. Your privacy rights and choices”.
1. Important information and who we are
2. Personal data collection: what, when and why
3. Who we share your personal data with
4. Your privacy rights and choices
5. How we handle your personal data
Threadneedle is registered as a data controller with the UK Information Commissioner’s Office under number ZB088150. If you have any questions about this privacy policy or our privacy practices, please contact us at admin@threadneedle.law
If you are unhappy with how we deal with your personal data you can make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk), but please do let us address your concerns first.
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 their privacy statements. When you leave our website or member space, we encourage you to read the privacy policy of every website you visit.
“Personal data” means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
When you engage with us, we collect, use, store and transfer the following categories of personal data:
Business data: Includes any personal data that relates to any business that engages with us or is embedded into business documents and/or contracts that you may ask us to enter into
Communications data: Includes data in all communications and interactions
Financial data: Includes bank account and payment card details
Identity and contact data: Includes first name, last name, username or similar identifier, job title and other information in your email signature, address, email address and telephone number
Marketing data: Includes your preferences in receiving marketing from us and your communication preferences
Profile data: includes services provided to you, feedback and survey responses
Transaction data: Includes details of services received from us
Aggregated data:
We collect and use “Aggregated Data” such as statistical or demographic data and this is not considered personal data in law. We may combine or connect Aggregated Data with your personal data and will treat that combined data as personal data which will be used in accordance with this privacy policy.
Special categories of personal data: We do not collect, control or process details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, your health, or genetic and biometric data criminal convictions and offences.
Where we need to collect personal data by law, or under the terms of an engagement we have with you, and you don’t provide it when asked, we may not be able to perform the engagement we have or are trying to enter into with you.
There are 6 lawful grounds for legitimate processing of personal data, but Threadneedle generally relies on 3 of them:
Our legitimate interests: In order to protect our legitimate interests (or those of a third party) in conducting and managing our business, we sometimes need to use your personal data. We can only rely on this purpose if it doesn’t override your rights and interests. Our legitimate interests include:
To perform our engagement: If you are a client or wish to become one, we need to process your data in order to provide services under the terms of our engagement with you, provide customer support and/or collect payment for services
From time to time we may also need to collect and retain your personal data to comply with a legal obligation that we are subject to.
Your consent: Where you have provided clear and express consent for us to process your personal data, we will use the data for that specific purpose only. We usually do not rely on consent to process your personal data.
Threadneedle will collect personal data about clients, potential clients and other individuals who may work for clients or potential clients or be otherwise involved in matters we work on, as part of the firm’s onboarding process. Threadneedle will use the information provided by you, your employees and your agents primarily for the provision of legal services to you and for related purposes including:
To engage you as a client: type of data: Identity and contact; lawful basis for processing: performance of a contract with you
To manage payments, fees and charges and collect and recover monies owed to us: type of data: (i) Identity and contact, (ii) Communications, (iii) Financial, (iv) Marketing and (v) Transaction; lawful basis for processing: (i) Performance of a contract with you and (ii) necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you: type of data: (i) Identity and contact, (ii) Communications, (iii) Marketing and (iv) Profile; lawful basis for processing: (i) Performance of a contract with you, (ii) Necessary to comply with a legal obligation and (iii) necessary for our legitimate interests (to keep our records updated and to assess how our clients use our services)
To make suggestions and recommendations to you about our services that may be of interest to you: type of data: (i) Identity and contact, (ii) Communications, (iii) Marketing, (iv) Profile and (v)Technical and (vi) Usage; lawful basis for processing: necessary for our legitimate interests (to develop our services and grow our business)
To use data analytics to improve our website, marketing, services, client relationships and experiences: type of data: (i) Technical and (ii) Usage; lawful basis for processing: necessary for our legitimate interests (to define types of clients for our services, to keep our website updated and relevant and to develop our business and guide our marketing strategy)
To provide you with choices regarding certain personal data uses (particularly around marketing and advertising) we have established the following personal data control mechanisms:
Promotional offers: We may use your personal data to form a view on what services, products and offers we think may be of interest. You will receive marketing communications from us if you have requested information, downloaded resources or purchased services from us AND you have not opted out of receiving that marketing.
Change of purpose: We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Cookies: You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the website may become inaccessible or not function properly.
Opting out: You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing email OR by contacting us at any time. Where you opt out, this will not apply to personal data provided to us as a result of engaging us to provide legal services.
Third-party marketing: We do not sell or provide your personal data to third parties for marketing purposes.
No knowledge or consent: We may process your personal data without your knowledge or consent in compliance with the above rules if required or allowed by law.
We may share your personal data with the parties set out below for the purposes set out in 2.5 above (Personal data collection: when, what and why).
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.
External third parties:
Any purchasers of or investors in Threadneedle: We may choose to sell, transfer or merge parts of the Threadneedle 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.
Under certain circumstances, data protection laws give you rights over your personal data. If you wish to exercise any of these rights please contact us at info@threadneedle.law
No fee usually required: You will not usually have to pay a fee to exercise your rights. 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.
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 individuals or businesses 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 use data processors to process personal data for us. We only do so if they comply with the UK GDPR and the EU GDPR and have adequate technical measures to protect your personal data. The transmission and exchange of information is carried out at your own risk. We cannot guarantee the security of any information that you transmit to us, or receive from us; however, we take measures in order to safeguard against unauthorised disclosures by taking actions such as encrypting data with strong cryptography before transmitting it over a public network like the internet. Although there are no guarantees when sending personal data online, we strive for maximum protection.
We have processes 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.
Certain of our external third-party providers are based outside of the UK and the EU. If they are located in a country that has not been deemed to have the same standard of data protection as the UK and EU, we make sure that our agreements with them protect your privacy by complying with the UK’s international data transfer agreement (IDTA), the international data transfer addendum to the European Commission’s standard contractual clauses for international data transfers (Addendum).
How long will you use my personal data for?
We will only keep 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.
Once we no longer need to keep your personal data it will be deleted or anonymised.
Last updated: 18th March 2024
