Introduction
This document refers to personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain. The General Data Protection Regulation (GDPR) seeks to protect and enhance the rights of data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU. It should be noted that GDPR does not apply to information already in the public domain.
Miller James Ltd is strongly committed to protecting the privacy of its user community. The intent of this privacy statement is to detail the information Miller James Ltd may gather about individuals who visit its website and how that information is used. You should read this statement carefully before using the website.
Personal Data
Miller James Ltd uses the information collected from you to provide quotations, make telephone contact and to email you marketing information which Miller James Ltd believes may be of interest to you and your business. In you making initial contact you consent to Miller James Ltd maintaining a marketing dialogue with you until you either opt out (which you can do at any stage) or we decide to desist in promoting our services. Miller James Ltd also acts on behalf of its clients in the capacity of data processor. When working exclusively as a data processor, Miller James Ltd will be acting on the instruction of its client, and will work hard to ensure that the client is fully GDPR compliant.
Some personal data may be collected about you from the forms and surveys you complete, from records of our correspondence and phone calls and details of your visits to our website, including but not limited to personally identifying information like Internet Protocol (IP) addresses. Miller James Ltd may from time to time use such information to identify its visitors. Miller James Ltd may also collect statistics about the behaviour of visitors to its website.
The Miller James Ltd websites use cookies, which is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. More specifically a “cookie” is a small text file which is stored, either on your hard drive, or in memory until your browser is closed. Cookies are used by
Miller James Ltd to enhance your experience of the site and facilitate ease of navigation through the website.
You are entitled to object to our use of cookies and you can disable cookies on your website browser. However, you should be aware that certain cookies may be necessary in order to provide you with certain features such as the customised delivery of certain information.
We also collect statistical data via the website, which allows us to assess the number of visitors to the website and to identify what page is viewed most frequently.
Cookies Policy
“Cookies” are small pieces of information stored by your internet browser that collect data such as your browser type, your operating system, web pages visited, time of visits, content viewed, advertisements viewed and other click stream data. We use cookies to help us tailor our websites to your needs, to deliver a better, more personalised service and to remember certain choices you’ve made so you don’t have to re-enter them. Cookies also enable us to identify traffic to our website including pages visited, visitor numbers and traffic paths taken.
We may use advertising networks to help present advertisements or other content on our website and other websites that display Miller James Ltd advertisements. Advertising networks use cookies, web beacons, or similar technologies on your computer or mobile or other device to serve you advertisements or content tailored to interests you have shown by building a profile of your internet browsing on this website and other websites you have visited.
This website uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses "cookies" as outlined above. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.
You can prevent Google’s collection and use of data (cookies and IP address) by downloading and installing the browser plug-in available under https://tools.google.com/dlpage/gaoptout
Link to Third Party Sites
Please note that this policy applies only to the Miller James Ltd and not to the websites of other companies or organisations to which we provide links. Any third-party websites are viewed at your own risk.
Legal basis for processing any personal data
To meet Miller James Ltd contractual obligations to clients and to also respond to marketing enquiries, or provide services requested directly by you.
Legitimate interests pursued by Miller James Ltd and/or its clients
To promote the services offered by Miller James Ltd and/or to market the services and/or products offered by Miller James Ltd to existing clients.
Consent
Through agreeing to this privacy notice you are consenting to Miller James Ltd processing your personal data for the purposes outlined. You can withdraw consent at any time by emailing jboyd@millerjames.co.uk Data Protection Officer.
Disclosure
Miller James Ltd may on occasions pass your Personal Information to third parties exclusively to process work on its behalf. Miller James Ltd requires these parties to agree to process this information based on our instructions and requirements consistent with this Privacy Notice and GDPR.
Miller James Ltd do not broker or pass on information gained from your engagement without your consent. However, Miller James Ltd may disclose your Personal Information to meet legal obligations, regulations or valid governmental request. Miller James Ltd may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of Miller James Ltd, its clients and/or the wider community.
Retention Policy
Miller James Ltd will process personal data during the duration of any contract and will continue to store only the personal data needed in accordance with Miller James Ltd Data Retention Policy.
Data storage
Data is held in the UK using different (multiple) servers. Miller James Ltd does not store personal data outside the EEA.
Your rights as a data subject
At any point whilst Miller James Ltd is in possession of or processing your personal data, all data subjects have the following rights:
• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.
In the event that Miller James Ltd refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge.
Miller James Ltd at your request can confirm what information it holds about you and how it is processed
You can request the following information:
• Identity and the contact details of the person or organisation (Miller James Ltd) that has determined how and why to process your data.
• Contact details of the data protection officer, where applicable.
• The purpose of the processing as well as the legal basis for processing.
• If the processing is based on the legitimate interests of Miller James Ltd or a third party such as one of its clients, information about those interests.
• The categories of personal data collected, stored and processed.
• Recipient(s) or categories of recipients that the data is/will be disclosed to.
• How long the data will be stored.
• Details of your rights to correct, erase, restrict or object to such processing.
• Information about your right to withdraw consent at any time.
• How to lodge a complaint with the supervisory authority (Data Protection Regulator).
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
• The source of personal data if it wasn’t collected directly from you.
• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
To access what personal data is held, identification will be required
Miller James Ltd will accept the following forms of ID when information on your personal data is requested: a copy of your national ID card, driving license, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If Miller James Ltd is dissatisfied with the quality, further information may be sought before personal data can be released.
All requests should be made to jboyd@millerjames.co.uk or writing to us at the address further below.
Link to Third Party Sites
Please note that this policy applies only to the Miller James Ltd website and not to the websites of other companies or organisations to which we provide links. Any third-party websites are viewed at your own risk.
Changes to Privacy Statement
Miller James Ltd may change this Privacy Statement from time to time. It is advisable that you review this Privacy Statement regularly for any such changes.
Governing Law
This Privacy Statement is governed by the laws of Ireland and you submit to the exclusive jurisdiction of the Irish Courts.
Complaints
In the event that you wish to make a compliant about how your personal data is being processed by Miller James Ltd or its partners, you have the right to complain to Miller James Ltd. If you do not get a response within 30 days you can complain to the Data Protection Regulator.
The details for each of these contacts are:
Miller James Ltd
2nd Floor
17 Castle Arcade
Belfast, BT1 5DG
Telephone 028 9023 9385 or email amiller@millerjames.co.uk
Information Commissioner's Office
3rd Floor
14 Cromac Place
Belfast
BT7 2JB
Tel: 028 9027 8757 or 0303 123 1114 or email: ni@ico.org.uk