1 Introduction
The data protection rules which apply from 25th May 2018 (the General Data Protection Regulation (GDPR)) requires data (information) to be treated and handled in certain ways which support compliance with its requirements. The data of significance is data relating to Data Subjects (People) where the Data Subject is a Natural Person. This document provides an overview of:
2 More information
This Privacy Policy will be amended to stay up to date. You can view a copy by visiting www.lflspv1.com or if you have any questions please contact LFL SPV 1 Ltd on 020 3747 9333. See section 12 below.
3 Who we are
When we say ‘LFL SPV 1’, we mean LFL SPV 1 Ltd who is the Data Controller for the information in this overview. This means we are responsible for deciding how we can use your information.
4 This Privacy Policy
4.1 The Core Purpose
As a business LFL SPV 1 Ltd undertakes a number of functions. This Privacy Policy applies to the data processed to undertake its core purpose (Purpose) (see section 4.1). Privacy Policies covering data processed for other purposes are documented separately.
4.1.1 Description of the Core Purpose.
LFL SPV 1 Ltd provides services to businesses under commercial contract with those businesses (VFS Clients). The services provided consist of purchasing rights to and receiving payment of costs and payments in connection with these purchased rights, relating to a matter managed by the LFL SPV 1 Ltd Client. The services are a Core Activity of LFL SPV 1 Ltd and the activities to enable LFL: SPV 1 to provide this service form the Purpose.
4.1.2 How we use your information for the Purpose
It is for the Purpose that it is necessary for data to be provided by LFL SPV 1 Ltd Clients to LFL SPV 1 Ltd and by LFL SPV 1 Ltd with other parties. LFL SPV 1 Ltd will use your information to
5 Lawful basis for processing personal data
LFL SPV 1 Ltd processes Personal Data and Special Categories of Data for the Purpose. It processes the data using the lawful basis of Consent, of the Data Subject. The consent is provided in a document – Consent to share information with VFS. It is obtained by the Business contracted to LFL SPV 1 Ltd (the LFL SPV 1 Ltd Client) and for which LFL SPV 1 Ltd operates the Purpose.
The Consent complies with the requirements for consent as defined by the GDPR and includes information on how to withdraw Consent.
6 Retention of Information
LFL SPV 1 Ltd will keep your information for as long as we have payments due to us. After this we will keep it whilst it is required for our legitimate purposes e.g. to help us respond to queries or complaints or for other reasons such as fraud prevention or resolution, and responding to requests from regulators, or as legally required by law.
7 The types of information we collect about you
The information we collect will include information relating to a matter (usually a legal matter) being run by the LFL SPV 1 Ltd Client, on behalf of their client who is often an individual, or the Data Subject in the context of this policy.
7.1 Categories of data
In performing the Purpose LFL SPV 1 Ltd will or may be provided with
7.2 Types of information supplied
The following information is necessary to enable LFL SPV 1 Ltd to execute the Purpose. In each case the data will be that relating to the LFL SPV 1 Ltd Client’s matter for which the Purpose is being undertaken.
Some or all of the above may for Personal Data or Special Category Personal Data as defined under the GDPR.
8 how we collect and use it
LFL SPV 1 Ltd will be supplied with and may seek information from several sources including:
9 who we might share it with
LFL SPV 1 Ltd does not share Special Category Personal Data with third parties for support of the Purpose
LFL SPV 1 Ltd shares information provided for the Purpose with the following parties who will process that information;
9.1.1 Within the LFL SPV 1 Ltd Group of companies including wholly owned subsidiary businesses.
9.1.2 With Third Parties for the Purpose
9.2 Third Parties for support of LFL SPV 1 Ltd including general business support and support for the Purpose
10 the steps we’ll take to make sure it stays private and secure
LFL SPV 1 Ltd takes its responsibilities to safeguard your information seriously. Measures we take include: –
10.1 Electronically held information
10.2 Paper based information
11 your rights to your information
LFL SPV 1 Ltd will support individuals’ requests to access their personal data in accordance with the requirements of the GDPR. In the first instance individuals should contact the party to whom they provided their Consent to Share information with LFL SPV 1 Ltd.
11.1 Individuals rights:
Individuals have the right to:
11.2 Access to your information
Any individual wishing to seek details of the information processed by LFL SPV 1 Ltd for the Purpose should in the first instance contact the party to which they provided consent for their information to be shared.
LFL SPV 1 Ltd will when requested provide applicable information to the party supplying the information to LFL SPV 1 Ltd and identify the Data Subject (you) to which it relates.
12 Contact LFL SPV 1 Ltd
LFL SPV 1 Ltd may be contacted by emailing – info@lflspv1.com. Please include details of how you can be contacted for the purpose of a reply.
Alternatively, please telephone 020 3747 9333.