Welcome to the S&K Enforcement Limited (“S&K Enforcement”) privacy notice.

This privacy notice provides information on how S&K Enforcement collects and processes your personal data when you visit our website.
It is important that you read this privacy notice together with our website privacy policy [LINK TO FULL PRIVACY POLICY] which contains more detailed information about our data processing.

1. Important information and who we are
S&K Enforcement Limited is the controller and responsible for your personal data.
If you have any questions about this privacy notice or our data protection practices please contact us using the following details:

CONTACT DETAILS
Full name of legal entity: S&K Enforcement Limited (12582521)
Name of contact: Mr Samuel Brown
Email address: info@skpropenforcement.co.uk
Postal address: Queens Arms, 23 Burrage Road, London, SE18 7LQ
Telephone number: 020 3633 8055

2. The data we collect about you
We may collect, use, store and transfer different kinds of personal data about you as follows:• Identity Data.
• Contact Data.
• Financial Data.
• Transaction Data.
• Technical Data.
• Profile Data.
• Usage Data.
• Marketing and Communications Data.
We explain these categories of data in our privacy policy here [LINK TO RELEVANT SECTION OF FULL PRIVACY POLICY].
We use different methods to collect data about you, which are explained here [LINK TO RELEVANT SECTION OF FULL PRIVACY POLICY].

3. How we use your personal data
We will only use your personal data for the purpose for which we collected it which may include the following:
• To register you as a new customer.
• To process any agreement made between us and/or to deliver any products/services.
• To manage your relationship with us.
• To improve our website, products/services, marketing or customer relationships.
• To recommend products or services which may be of interest to you.

4. How we share your personal data
We may share your personal data within the S&K Enforcement group or with external third parties. More detail can be found here [LINK TO RELEVANT SECTION OF FULL PRIVACY POLICY].

5. International transfers
We may transfer, store and process your personal data outside the European Economic Area. More detail can be found here [LINK TO RELEVANT SECTION OF FULL PRIVACY POLICY].

6. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data including the right to receive a copy of the personal data we hold about you and the right to make a complaint at any time to the Information Commissioner’s Office, the UK supervisory authority for data protection issues (www.ico.org.uk).
More detail can be found in our here [LINK TO RELEVANT SECTION OF FULL PRIVACY POLICY].

7. Further details
If you are looking for more information on how we process your personal data including on data security, data retention and lawful processing bases, please access our website privacy policy here [LINK TO FULL PRIVACY POLICY].

Introduction

Welcome to the S&K Enforcement Limited (“S&K Enforcement”) privacy policy, which we have implemented as we collect information about you via our website and through our interactions with you (which we refer to collectively as “services” in this policy).
At S&K Enforcement your privacy is our number one priority and we have taken great care to ensure that we comply with all data protection legislation in the UK to maintain your privacy and keep your data safe and secure.
This privacy policy will inform you as to how we look after your personal data when you use our services (regardless of where you visit our website or contact us from) and tells you about your privacy rights and how the law protects you.
This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Alternatively, you can download a pdf version of the policy here [LINK TO PDF VERSION]. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

1. IMPORTANT INFORMATION AND WHO WE ARE [LINK TO SECTION BELOW]
2. THE DATA WE COLLECT ABOUT YOU [LINK TO SECTION BELOW]
3. HOW IS YOUR PERSONAL DATA COLLECTED? [LINK TO SECTION BELOW]
4. HOW WE USE YOUR PERSONAL DATA [LINK TO SECTION BELOW]
5. DISCLOSURES OF YOUR PERSONAL DATA [LINK TO SECTION BELOW]
6. INTERNATIONAL TRANSFERS [LINK TO SECTION BELOW]
7. DATA SECURITY [LINK TO SECTION BELOW]
8. DATA RETENTION [LINK TO SECTION BELOW]
9. YOUR LEGAL RIGHTS [LINK TO SECTION BELOW]
10. GLOSSARY [LINK TO SECTION BELOW]


1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how we collect and process your personal data through your use of our services, including any data you may provide to us by using the services.
Our services are not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Controller
S&K Enforcement Limited is the controller and responsible for your personal data (collectively referred to as “S&K Enforcement”, “we”, “us” or “our” in this privacy policy).
If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below.
Contact details
If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:
Full name of legal entity: S&K Enforcement Limited (12582521)
Email address: info@skpropenforcement.co.uk
Postal address: Queens Arms, 23 Burrage Road, London, SE18 7LQ
Telephone number: 020 3633 8055
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated on 5th March 2021. Historic versions can be obtained by contacting us.
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.
Third-party links
Our services may include links to third-party websites, plug-ins and apps. 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 or apps and are not responsible for their privacy statements. When you stop using our services to use any third-party services, we encourage you to read the privacy policy of every service that you use.


2. The data we collect about you

Personal data, or personal information, 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).
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, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our services.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific service feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.


3. How is your personal data collected?

We use different methods to collect data from and about you including through:
• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• apply for our products or services;
• create an account on our website/app;
• subscribe to our services or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us feedback or contact us.
• Automated technologies or interactions. As you interact with our services, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy here [LINK TO COOKIE POLICY] for further details.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
• Technical Data from the following parties:
analytics providers such as Google;
advertising networks; and
search information providers.
◦ Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
◦ Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.


4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.
Click here [LINK TO GLOSSARY, LAWFUL BASIS] to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we may 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.

Purpose/Activity
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new user/client of our services
(a) Identity
(b) Contact
Performance of a contract with you
To process, administer and deliver our services to you:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you, which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and our services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Identity
(b) Contact
(c) Technical
(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
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our products/services, marketing, customer relationships and experiences
(a) Technical
(b) Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our app and website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you and new services
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You may receive marketing communications from us if you have requested information from us or purchased products or services from us and you have not opted-out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Automated decision making and profiling
We may use your personal data for the purposes of automated decision making or profiling but will notify you beforehand to provide you detailed information in relation to the auto-decision logic used and about the significance and the consequences for you of any automated decision-making or profiling.
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:
1. Where we have notified you of the decision and given you 21 days to request a reconsideration.
2. Where it is necessary to perform any contract with you and appropriate measures are in place to safeguard your rights.
3. In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.
If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.
Opting-out
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at Queens Arms, 23 Burrage Road, London, SE18 7LQ ­­­­­­­­­­or by email using info@skpropenforcement.co.uk.
Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, subscription, warranty registration, product/service experience or other transactions.

Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when apps or websites set or access cookies. If you disable or refuse cookies, please note that some parts of our services may become inaccessible or not function properly. For more information about the cookies we use, please see here [LINK TO COOKIE POLICY].

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 at Queens Arms, 23 Burrage Road, London, SE18 7LQ or by email using info@skpropenforcement.co.uk.
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.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.


5. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data [LINK TO SECTION ABOVE] above.
• External Third Parties as set out in the Glossary [LINK TO GLOSSARY].
• 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 share or transfer your personal data outside of the European Economic Area (EEA).
Some of our external third parties may be based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. These countries include: Andorra, Argentina, Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Jersey, New Zealand, Switzerland, Uruguay and the United States of America; or
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.


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?
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.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see your legal rights [LINK TO “YOUR LEGAL RIGHTS” SECTION] below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.


9. Your legal rights

In addition to the right to be informed, under certain circumstances you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
• Request access to your personal data (Subject Access Request ‘SAR’) [LINK TO GLOSSARY].
• Request correction of your personal data [LINK TO GLOSSARY].
• Request erasure of your personal data [LINK TO GLOSSARY].
• Object to processing of your personal data [LINK TO GLOSSARY].
• Request restriction of processing your personal data [LINK TO GLOSSARY].
• Request transfer of your personal data [LINK TO GLOSSARY].
• Right to withdraw consent [LINK TO GLOSSARY].
• Rights related to automated decision making and profiling [LINK TO GLOSSARY].
If you wish to exercise any of the rights set out above, please contact us.
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. Glossary

LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES
External Third Parties
• Service providers based worldwide who provide IT and system administration services.
• Professional advisers including lawyers, bankers, auditors and insurers based worldwide who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities based worldwide who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data 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. 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) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in 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.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
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. 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.
Be notified in respect of any automated decision-making or profiling in respect of your personal data.
Request meaningful information about the auto-decision logic used in any automated decision-making or profiling and about the significance and the consequences of any automated decision-making or profiling.
Object to automated decision-making or profiling of your personal data.