Head Office:
17 Hanover Square, Mayfair, London, W1S 1HT

Privacy Policy

The below privacy notice is in effect from 25th May 2018.

Primatas Ltd, trading as Westkin Associates (or “WESTKIN”) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you use our services and tell you about your privacy rights and how the law protects you.

1 IMPORTANT INFORMATION AND WHO WE ARE

1.1 PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how WESTKIN collects and processes your personal data through forms, our website, and including any data you may provide through this website when you contact us and/or use a product or service.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice 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 notice supplements the other notices and is not intended to override them.

1.2 CONTROLLER

WESTKIN is the controller and responsible for your personal data
(collectively referred to as “Westkin”, “we”, “us” or “our” in this privacy notice).

Its registered office is

Primatas Ltd
3RD FLOOR 
120 MOORGATE 
LONDON 
ENGLAND 
EC2M 6UR

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.

1.3 CONTACT DETAILS

Email address amir.zaidi@westkin.com (Subject: “Data Privacy” or “GDPR”).
Postal address: Westkin Associates, 17 Hanover Sq, Mayfair, London, W1S 1BN

1.4 CHANGES TO PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on in May 2018. This privacy policy may change
from time to time so please check it periodically.

The data protection law in the UK will change on 25 May 2018. Although this
privacy notice sets out most of your rights under the new laws, we may not
initially be able to respond to some of your requests (for example, a request for the transfer of your personal data) as we are still working towards getting our systems and processes ready for some of these changes.

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.

1.5 THIRD-PARTY LINKS

This 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, we encourage you to read the privacy notice of every website you visit.

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 follows:

• Identity Data includes first name, last name, username or similar identifier, title, date of birth and gender.

• Family Identity Data includes first name, last name, username or similar
identifier, title, date of birth and gender of your immediate family, where they are included in your membership.

• Contact Data includes billing address, correspondence address, email address and telephone numbers, as well as the content of correspondence to and from you.

• 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 this website.

• Usage Data includes information about how you use our website and services.

We also collect, use and share Aggregated Data such as statistical or
demographic data for any purpose. Aggregated Data may be derived from your
personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website 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 notice.

2.1 SENSITIVE DATA

By holding Identity Data and Family Data, we implicitly hold ‘Special Category’ data about you, as this includes details about your race or ethnicity or religious affiliation, which could be inferred through it being held by us. Additionally,where relevant to your case or your ability to access our offices, we potentially hold information about your health or disability(e.g. Medical Surgeries).

In addition to the above, we would also hold details of any criminal records you disclose to us as well as details of any children under 18 where relevant to your case.

3 HOW IS YOUR 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 and Previous and current claims by filling in forms or by corresponding with us by our website, post, phone, email or otherwise. This includes personal data you provide when you:

(1) Complete an enquiry form, or any other service;
(2) make a payment;
(3) subscribe to a mailing list;
(4) send us key case data
(5) enter a competition or survey; or
(6) give us feedback.

• Automated technologies or interactions. As you interact with our website, we may 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.

• Third parties or publicly available sources. We may receive personal data
about you from various third parties and public sources as set out below:

(1) Technical Data from analytics providers such as Google based outside the
EU.
(2) Contact, Financial and Transaction Data from providers of technical,
payment and delivery services such as World Pay and Barclaycard 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 for personal services 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 or regulatory obligation.
• With your consent

Please refer to the Glossary 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 other than in relation to sending marketing communications to
you via email, post or text message.

You have the right to withdraw consent to marketing at any time by contacting
us.

4.1 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 plan to use your personal data, and which of the legal bases we rely on to do so. Wehave 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

PERFORMANCE OF A CONTRACT

Taking data related to personal information, travel history, personal relationships, criminal records, financial history and information and other information related to the application or appeal as may be.
These uses will be: Identity , Contact and Financial

CONSENT

We ask for permission to continue to remain in contact by phone and email after the conclusion of the contract in order to provide occasional information on changes in law and visa expiry dates. These do not replace the need for legal advice and for clients to remain on top of their visa expiry dates.

Taking data related to personal information, travel history, personal relationships, criminal records, financial history and information and other information related to the application or appeal as may be and needed to review the file. These will be Identity, Contact and Financial

COMPLYING WITH OUR LEGAL OR REGULATORY OBLIGATIONS

(a) Necessary to comply with a legal obligation
(b) Necessary for our legitimate interests
(to take pre-emptive steps to ensure legal and regulatory compliance)
(c) Providing files for audit and investigation to our regulator, OISC.
Taking data related to personal information, travel history, personal relationships, criminal records, financial history and information and other information related to the application or appeal as may be

To manage our relationship with you which will include:

1. Notifying you about changes to our terms or privacy policy
2. Asking you to take a survey
3. General client care, including communications

4.2 MARKETING

We strive to provide you with choices regarding certain personal data uses,
particularly around marketing and advertising.

4.3 OPTING OUT

You can ask us to stop sending you marketing messages at any time by
contacting us. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service or other transaction.

4.4 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 our websites may become inaccessible or not function properly.

4.5 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

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 have to share your personal data with the parties set out below for the purposes set out in the table in section 4 above.

• External Third Parties as set out in the Glossary.
• Government Departments, but only as part of your application
• Sister companies such as Westkin Law

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

6 DATA STORAGE AND INTERNATIONAL TRANSFERS

We primarily store data internally, i.e. in the UK and on private infrastructure, however in the course of processing we may rely on tools and services which are hosted outside of the EU, for example, Drop Box, Salesforce or Gmail. Your data may therefore be held and processed outside the EU at any given time in order to enable lawful and legitimate processing.

7 DATA SECURITY

We have put in place measures to prevent your personal data from being
accidentally lost or used in an unauthorised way. In addition, we limit access to your personal data to those employees, agents, and other third
parties who have a 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

8.1 HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

Our retention periods for personal data are based on business needs and legal
requirements. We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements, and any other permissible related purpose.

For example, we retain payment information to support our accounts and to
comply with regulatory requirements regarding the retention of such data.
When personal data is no longer needed, we either irreversibly anonymise the
data (in which case we may further retain and use the anonymised information)
or securely destroy the data.

In some circumstances you can ask us to delete your data: see Request erasure
below for further information.

9 YOUR LEGAL RIGHTS

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
• Request correction of your personal data
• Request erasure of your personal data
• Object to processing of your personal data
• Request restriction of processing your personal data
• Request transfer of your personal data
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

9.1 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 may refuse to comply with your request in these circumstances.

9.2 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.

9.3 TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month of confirming the identity, scope and validity of a request. Occasionally it may take us longer than this, for example, 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, and inform you that it may take up to 2 months.

10 GLOSSARY

10.1 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 or regulatory obligation means processing your personal
data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

10.2 Third parties

External third parties

• Service providers acting as processors in the United Kingdom who provide IT
and system administration services.

• HM Revenue & Customs, regulators and other authorities acting as processors
or joint controllers based in the United Kingdom who require reporting of
processing activities in certain circumstances.

• The UK Home Office, for applications.

10.3 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 or to opt out of inclusion in data aggregation. 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:

(a) if you want us to establish the data’s accuracy;

(b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or
(d) 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.

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