Terms & Conditions

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Lucia Hoxha & Luciahoxha.com is strongly committed to protecting personal data and complying with data protection legislation. This privacy statement tells you why and how I collect and use personal data and gives you information about individuals’ rights in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act (1998 or 2018) and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (‘Data Protection Legislation’). I will lawfully process personal data to meet my contractual or legal and regulatory obligations or legitimate interests in providing my services to you. It applies to personal data provided to me (either by individuals or by others). I may use personal data provided to me for any of the purposes described in this privacy statement as stated at the point of collection or in my Standard Terms and Conditions. I take the security of all the data I hold very seriously. I have a framework of policies, procedures in place regarding data protection, its security and confidentiality and regularly review the appropriateness of the measures I have in place to keep the data I hold secure. This Privacy Notice was last updated on 24 May 2018 and any changes I may make in the future will be available to you.

What is Personal Data?

Personal data is any information relating to an identified or identifiable living person. Lucia Hoxha & Luciahoxha.com processes personal data for many purposes. The lawful basis of processing, use, the means of collection, disclosure, and retention periods for each purpose may differ.

When I collect and use personal data, my policy is to be as transparent as I can about why and how I process that personal data. I summarise my specific processing activities in each section below.

When and how I share personal data and locations of processing

I will only share personal data with others for legitimate purposes and when I am legally permitted to do so. When I share data with others, I put contractual arrangements and security measures in place to protect that data and to comply with my policies and procedures.

I generally do not transfer data to non the EU countries but where I transfer personal data outside of the EU to a country not determined by the European Commission as providing an adequate level of protection for personal data, the transfers will be under an agreement which covers the EU requirements for the transfer of personal data outside the EU, such as the European Commission approved standard contractual clauses. The European Commission approved standard contractual clauses are available here: https://ico.org.uk/media/fororganisations/documents/1571/model_contract_clauses_international_transfers_of_personal_data.pdf

Personal data held by me may be transferred to:

Third party organisations that provide applications/functionality, data processing or IT services to me
I use third parties to support me in providing my services and to help provide, run and manage my internal IT systems. For example, providers of information technology, cloud-based software as service providers, identity management, data analysis, data back-up, security and storage services. The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal data may be stored in any one of them.
Third party organisations that otherwise assist me in providing goods, services or information
Other professional advisers, administration services, marketing services and banking services
Law enforcement or other government and regulatory agencies or to other third parties as required by, and in accordance with, applicable law or regulation

Occasionally, I may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that I am complying with applicable law and regulation, to investigate an alleged crime, to establish, exercise or defend legal rights. I will only fulfil requests for personal data where I am permitted to do so in accordance with applicable law or regulations.

Changes to this privacy statement

I recognise that transparency is an ongoing responsibility so I will keep this privacy statement under regular review.

This privacy statement was last updated on 24 May 2018.

Data controller and contact information

My clients are Data Controllers unless otherwise agreed between us. Lucia Hoxha & Luciahoxha.com is a Data Controller unless I have agreed with you that I act as a Data Processor for you. If you have any questions about this privacy statement or how and why I process personal data, please contact me at: lucia@luciahoxha.com

Individuals’ rights and how to exercise them

Individuals have certain rights over their personal data and data controllers are responsible for fulfilling these rights. Where I decide how and why personal data is processed, I am a data controller and include further information about the rights that individuals have and how to exercise them below. It is important that the personal data I hold about you is accurate and current. Should your personal information change, please notify me of any changes of which I need to be made aware by contacting me.

Access to personal data

You have a right of access to personal data held by me as a data controller. This right may be exercised by emailing me at lucia@luciahoxha.com. I may charge my administrative costs for a request for access in accordance with applicable law. I will aim to respond to any requests for information promptly and in any event within the legally required time limits. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, I may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, I may refuse to comply with the request in such circumstances. I may need to request specific information from you to help me confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Amendment of personal data

To update personal data submitted to me, you may contact me at email lucia@luciahoxha.com.

When practically possible, once I am informed that any personal data processed by me is no longer accurate, I will make corrections (where appropriate) based on your updated information.

Withdrawal of consent

Where I process personal data based on consent, individuals have a right to withdraw consent at any time. I do not generally process personal data based on consent (as I can usually rely on another legal basis). To withdraw consent to my processing of your personal data please email me at lucia@luciahoxha.com. Once I have received notification that you have withdrawn your consent, I will no longer process your personal information (personal data) for the purpose or purposes you originally agreed to, unless I have another legitimate basis for doing so in law.

Other data subject rights

This privacy statement is intended to provide information about what personal data I collect about you and how it is used. As well as rights of access and amendment referred to above, individuals may have other rights in relation to the personal data I hold, such as a right to erasure/deletion, to restrict or object to my processing of personal data and the right to data portability. If you wish to exercise any of these rights, please send an email to lucia@luciahoxha.com.

Complaints

I hope that you will not ever need to, but if you do want to complain about my use of personal data, please send an email with the details of your complaint to lucia@luciahoxha.com. I will look into and respond to any complaints I receive.

You also have the right to lodge a complaint with the Information Commissioner’s Office (“ICO”) (the UK data protection regulator). For further information on your rights and how to complain to the ICO, please refer to the ICO website https://ico.org.uk/concerns.

Personal Clients/Corporate Clients (and associated individuals)

Collection of personal data

My policy is to collect only the personal data necessary for agreed purposes and I ask my clients only to share personal data where it is strictly needed for those purposes.

Where I need to process personal data to provide my services, I ask my clients to provide the necessary information to other data subjects concerned, such as family members, regarding its use. Generally, I collect personal data from our clients or from third parties acting on the instructions of the relevant client, as well as contact details for my clients in order to manage and maintain my relationships with them.

Given the diversity of the services I provide to personal clients, I process many categories of personal data, including as appropriate for the services I am providing:

Personal/Contact details, such as your name, address, email and contact details. This will include my correspondence and communication with you;
Business activities and details of any services you have received/requested;
Family information;
Income, taxation and other financial-related details; and
Research, surveys and marketing activities.

For certain services or activities, and when required by law or with an individual’s consent, I may also collect special categories of personal data. Examples of special categories include race or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; physical or mental health; genetic data; biometric data; sexual life or sexual orientation; and, criminal records. Generally, I collect personal data from my clients or from a third party acting on the instructions of the relevant client.

Use of personal data

I may use personal data for the following purposes:

Providing contracted professional services

I provide a diverse range of professional services which require me to process personal data in order to provide advice. For example, I need to use personal data to provide individual tax advice.

Administering, managing and developing my businesses and services

I process personal data in order to run my business, including:

– managing my relationship with clients;

– developing my businesses and services (such as identifying client needs and improvements in service delivery);

– maintaining and using IT systems;

– hosting of events; and

– administering and managing my systems, applications and for my own legitimate interests provided those interests do not override any of your own interests, rights and freedoms which require the protection of personal data.

Security, quality and risk management activities

I have put in place commercially reasonable and appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, I limit access to your personal data to other third parties who have a business need to know. They will only process your personal data on my instructions and they are subject to a duty of confidentiality. I have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where I am legally required to do so. Personal data may be processed as part of the security monitoring that I undertake. I monitor the services provided to clients for quality purposes, which may involve processing personal data stored on the relevant client file. I have policies and procedures in place to monitor the quality of my services and manage risks in relation to client engagements. I collect and hold personal data as part of my client engagement and acceptance procedures and I carry out searches using publicly available sources (such as internet searches and sanctions lists) to identify politically exposed persons and heightened risk individuals and organisations and check that there are no issues that would prevent me from working with a particular client such as sanctions, criminal convictions (including in respect of company directors), conduct or other reputational issues.

Providing my clients with information about me and range of services

With consent or otherwise in accordance with applicable law, I use client’s contact details to provide information that I think will be of interest about me and my services. For example, updates and insights, other services that may be relevant and invites to events.

Complying with any requirement of law, regulation or a professional body of which I may become a member

As a provider of professional services, I am subject to legal, regulatory and professional obligations. I need to keep certain records to demonstrate that my services are provided in compliance with those obligations and those records may contain personal data.

I am continually looking for ways to help my clients and improve my business and services. Where agreed with my clients, I may use information that I receive in the course of providing professional services for other lawful purposes, including analysis to better understand a particular issue, provide insights back to my clients, to improve my business, service delivery and offerings. Please note that I may process your personal data for more than one lawful basis depending on the specific purpose for which I am using your data. In some circumstances I may anonymise or pseudonymise the personal data so that it can no longer be associated with you, in which case I may use it without further notice to you. If you refuse to provide me with certain information when requested, I may not be able to perform the contract I have entered into with you. Alternatively, I may be unable to comply with my legal or regulatory obligations. I may also process your personal data without your knowledge or consent, in accordance with this notice, where I am legally required or permitted to do so.

Data retention

I retain the personal data processed by me for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation).

In the absence of specific legal, regulatory or contractual requirements, my baseline retention period for records and other documentary evidence created in the provision of services is 8 years and required for the following purposes:

– The requirements of my business and the services provided;

– Any statutory or legal obligations;

– The purposes for which I originally collected the personal data;

– The lawful grounds on which I based our processing;

– The types of personal data I have collected and;

– The amount and categories of your personal data.

Others who get in touch with us

I collect personal data when an individual gets in touch with me with a question, complaint, comment or feedback (such as name, contact details and contents of the communication). In these cases, the individual is in control of the personal data shared with me and I will only use the data for the purpose of responding to the communication.[:sk]