Last updated: 29/09/2024
Special Circumstances Limited (“we”, “us”, “our”) is committed to protecting the privacy and security of your personal data. This Privacy Policy explains how we collect, use, store, and share your personal data when you visit our website or engage our consulting services.
We act as a Data Controller for the personal data we collect.
If you have any questions, please contact us using the details below.
1. Who We Are
Special Circumstances Limited
Company number: 07451351
Email: info@specialcircumstances.eu
2. What Personal Data We Collect
We collect and process only the minimum data necessary for legitimate business purposes. Types of data may include:
2.1 Data you provide directly
- Name, job title, and contact details
- Business information and enquiry details
- Information provided during consultations or service engagements
- Any documents you choose to send us
2.2 Automatically collected data (website analytics)
When you visit our website, we may automatically collect:
- IP address
- Browser type and version
- Pages visited, time and date of visit
- Log data and diagnostic data
We do not use profiling, automated decision-making, or behavioural tracking cookies without your consent.
2.3 Cookies
We use essential cookies necessary for site functionality.
Non-essential cookies (analytics or marketing) are opt-in only, in compliance with PECR.
3. How We Use Your Personal Data
We process your data only where lawful and necessary. This includes:
- Responding to enquiries or requests for information
- Providing consulting services
- Managing contracts and client relationships
- Maintaining website security and performance
- Meeting legal, regulatory, and compliance obligations
- Maintaining internal records and administration
We rely on one or more legal bases under the UK GDPR, including:
- Contract performance
- Legitimate interests (e.g., business administration, service delivery)
- Consent (for optional cookies or marketing communications)
- Legal obligations
We do not sell your personal data.
4. Sharing Your Data
We only share your personal data when necessary and lawful.
We may share data with:
- Professional advisers (e.g., legal, accounting)
- Service providers who assist with IT, hosting, email, or analytics
- Regulators or law enforcement where legally required
All third-party processors are bound by data-processing agreements ensuring confidentiality, security, and compliance with the UK GDPR.
We do not transfer your personal data outside the UK unless adequate safeguards (such as UK IDTA or SCCs) are in place.
5. Data Retention
We retain your personal data only for as long as necessary for the purposes collected, including:
- Contractual and project information: typically 6 years after project completion (to meet legal and professional obligations)
- Enquiry information: up to 12 months if no engagement occurs
- Website analytics data: retained in accordance with our cookie policy
After retention periods expire, data is securely deleted or anonymised.
6. Your Rights Under UK GDPR
You have the following rights regarding your personal data:
- Right to be informed
- Right of access (obtain a copy of your data)
- Right to rectification
- Right to erasure (“right to be forgotten”)
- Right to restrict processing
- Right to data portability
- Right to object to certain processing
- Right to withdraw consent at any time (where consent is relied upon)
- Right not to be subject to automated decision-making or profiling
To exercise any of your rights, contact: [Insert Email].
We may need to verify your identity before responding to your request.
7. Data Security
We apply strict technical and organisational measures to protect your data, including:
- Secure servers and encrypted communications
- Access controls and authentication
- Regular security review and risk assessment
- Minimum-necessary data collection
Despite our efforts, no method of digital transmission is fully secure. We encourage you to contact us if you have any concerns.
8. Links to Third-Party Sites
Our website may contain links to external websites. We are not responsible for their content or privacy practices. We encourage you to review their privacy policies.
9. Children’s Privacy
Our services are not directed at individuals under 18. We do not knowingly collect data relating to minors.
10. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in law or our data practices. The revised version will be posted on this page with an updated “Last updated” date.
11. How to Complain
If you have concerns about our use of your personal data, please contact us first so we can address the issue.
You may also lodge a complaint with the UK regulator:
Information Commissioner’s Office (ICO)
www.ico.org.uk
Telephone: 0303 123 1113
Company number: 07451351
Email: info@specialcircumstances.eu