Privacy Policy

This is an important notice regarding your privacy and the way in which Riverside Escrow Limited (referred to as “we”, “our”, “us” or “the Company” in this policy) collects and makes use of your personal data. We want to be open and transparent with you, and therefore encourage you to contact us if you have any questions about this policy or the ways in which we use your personal data.

This policy applies to our applicants, clients, prospective clients, parties to any escrow agreement where we act as a third party, business contacts, suppliers and contractors generally. We take our privacy responsibilities seriously and are committed to protecting and respecting your privacy.

This policy sets out the basis on which any personal data we collect from or about you, or that you provide to us, will be processed by us. Please read this policy carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of applicable privacy legislation, the data controller is Riverside Escrow Limited of Brennan House, Farnborough Aerospace Centre Business Park, Farnborough, Hampshire, GU14 6XR. Our company registration number is 05474890. Riverside Escrow Limited is registered as a data controller with the Information Commissioner’s Office with registration number ZA132453. You can check the register of data controllers here: https://ico.org.uk/esdwebpages/search.

The Company’s Data Protection Officer is responsible for ensuring compliance with relevant data protection legislation and this policy. Any questions regarding the operation of this policy or any concerns that the policy has not been complied with should be directed to our Data Protection Officer. Questions should be sent by email to dpo@herrington-carmichael.com.

What information do we hold about you?

We may collect, store and use personal data about you (referred to throughout this privacy policy as personal information):

Clients, prospective clients and a party to any escrow agreement where we act as a third party
Personal contact details such as name, title, date of birth, address, telephone number and personal email address.
Personal information to verify your identity, for example, a copy of your passport.
Payment information such as bank account details, credit/debit card number, expiration date, security code (CVV), name as it appears on the card or bank account, and address the card or bank account is registered to.
Personal information you provide to us via our website by using the “Quick Enquiry” form.
Personal information provided to us by the third party service providers we work with, for example, money laundering search providers and credit reference agencies.

Business contacts (for example, accountants, financial advisors and other professionals)

Contact details such as your name, title, business telephone number and business email address, or personal telephone number and personal email address (if you provide them to us).
Information you provide or we collect during our interactions with you or your employer, such as how long we have done business with you, or how long you have worked at your company.
Personal information you provide to us via our website by using the “Quick Enquiry” form.

Suppliers and contractors

Personal details such as your name, address, bank account information, email address and telephone number.

Generally (uses applicable to all categories of person detailed above)

If you visit our offices, images and video which are recorded by the CCTV system in operation on our premises.

Information gathered when you visit our offices via our visitor sign-in process, including your name and vehicle registration information.
Any personal information you provide to us during your interactions with us (which may include image and video interactions).
Any personal information about you provided to us during our interactions with you, your employer or a third party.
Any personal information you provide to us via our website by using the “Quick Enquiry” form.
Information gathered by cookies used on our website. Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse and also allows us to improve the way our website works. For detailed information on the cookies we use and the purposes for which we use them please refer to our Cookies Policy https://www.riverside-escrow.com/cookies.

Information provided to us by third party service providers we work with, for example, analytics providers, search information providers, web developers and credit reference agencies.

How will we use information about you and what is the legal ground we rely on for doing so?

We will only use your personal information when the law allows us to. When we use your personal information, we must have a legal ground for doing so. The following are (amongst others) the legal grounds by which we can use your personal information:

Where you have provided us with your consent for us to do so
Where we need to perform the contract we have entered into with you or to take steps to enter into a contract with you. Where we need to comply with a legal obligation to which we are subject.
Where it is in pursuit of our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interest.

More specifically, without limiting the above we will use your personal information in the following circumstances:

Clients, prospective clients and a party to any escrow agreement where we act as a third party

Your contact details to facilitate your business with us – to perform the contract with you or to take steps to enter into a contract with you.
Your contact details to provide you with information on our services:

If our client or prospective client is one or more individuals instructing us or enquiring of us in their capacity as individuals (including sole traders and traditional partnerships):

We may use your personal information to perform the contract or prospective contract with you or to take steps to enter into a contract with you; and
We may also provide you with marketing information where we have your consent to do so.
If our client or prospective client is a business (other than a sole trader or and traditional partnership) which you are employed or engaged by or on behalf of:
We may use your personal information to perform the contract or prospective contract with the client or to take steps to enter into a contract with the client; and
We may also use your personal information to provide technical information (for example legal updates) and/or marketing information in pursuit of our legitimate interests (keeping the client informed about our services and business updates) or where we have your consent to do so.

Your contact details to manage your client account – to perform the contract with you or to take steps to enter into a contract with you.
Your personal details and payment information to identify and prevent fraud – in pursuit of our legitimate interests (to prevent fraud for you and for us).
Your personal details and payment information to identify and prevent money laundering – to comply with a legal obligation.
Dealing with your enquiry made via the “Quick Enquiry” form on our website – in pursuit of our legitimate interests to ensure your enquiry is dealt with promptly and efficiently.

Business contacts (for example, accountants, financial advisors and other professionals.

Your contact details – in pursuit of our legitimate interests (to facilitate business between your organisation and ours).
Your contact details to provide you with further information on our services. This may include technical information (for example legal updates) and / or marketing information – in pursuit of our legitimate interests (keeping you informed about our services and business updates) or where we have your consent to do so.

Generally

To ensure our offices are kept secure – in pursuit of our legitimate interests (in ensuring our premises are kept secure and keep evidence of this).
Health and safety purposes – to comply with a legal obligation.
To track your Wi-Fi usage – in pursuit of our legitimate interests (in ensuring our network is being used for acceptable purposes).
To administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes – in pursuit of our legitimate interests (to better understand how people interact with our website and solve any issues it may have).
To improve our website to ensure that content is presented in the most effective manner for you and your computer – in pursuit of our legitimate interests (to improve our content and your experience).
To transfer to third party service providers – in pursuit of our legitimate interests (outsourcing for effectiveness and efficiency).
To transfer to our insurance providers – to comply with a legal obligation.
To transfer to our regulators – to comply with a legal obligation or in pursuit of our legitimate interests.
To contact you if we wish to use your information for a purpose not set out in this policy – to comply with a legal obligation.

What happens if there is a change of purpose?

We will only use your personal information 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 we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Which type of third parties might we share your personal information with?

We require third parties to respect the security of your information and to treat it in accordance with the law. For example, where we instruct third party services providers we carry out due diligence on those providers to ensure they treat your information as seriously as we do.
We may share your information with the following types of third parties:
Regulatory bodies such as the Financial Conduct Authority and HM Revenue & Customs.
Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined by section 1159 of the Companies Act 2006.
Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.
Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others.
Technical support providers, for example, assisting with our website.
Third party software hosting companies which provide us with software solutions.
Professional advisers such as solicitors, accountants, tax advisors and auditors.
Providers which help us store, collate and organise information effectively and securely, both electronically and in hard copy format, and for marketing purposes.
Providers which help us generate and collate reviews in relation to our services.
Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
Regulatory authorities, law enforcement authorities in connection with our legal and regulatory obligations and for the prevention and detection crime.
Banks that provide our escrow accounts in connection with opening, the use, audit, compliance and closing of such accounts (for example checks and audits on transactions.
Providers of insurance services we and our group companies use.
Money laundering search providers.

Data retention

How long will you use my information for?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for.

We assess the appropriate retention period for different information based on the size, volume, nature, and sensitivity of that information, the potential risk of harm to you from unauthorised use or disclosure of that information, the purposes for which we are using that information, applicable legal requirements for holding that information, and whether we can achieve those purpose(s) through other means.

Clients, prospective clients and a party to any escrow agreement where we act as a third party

The period during which we keep your information will depend on a number of things. For example:

if you have consented to receiving marketing information we will keep your contact details for as long as we still have your consent;
if you are our client of ours, we will keep your information until your client file has been inactive for 12 years;
if you are a prospective client of ours and do not choose to engage us, we will keep your information for 6 years;
where you use our website and one of our cookies are activate, that cookie will operate for the duration set out in our Cookie Policy https://www.riverside-escrow.com/cookies.

Business contacts (for example, accountants, financial advisors and other professionals)

We will keep your information for as long as our organisations do business together or for as long as we have a commercial interest in holding that information, for example, doing business in the future, inviting you to our events and providing you with information about our services where you have not opted out from this.
If you have consented to receiving technical information or marketing information we will keep your contact details as long as we still have your consent.

Generally

Where you use our website and one of our cookies is enabled and active, that cookie will operate for the duration set out in our Cookie Policy https://www.riverside-escrow.com/cookies.

Where we store your personal information

Electronic versions of the information you provide to us or we collect about you are stored on our servers at our offices within the UK. Our back up servers are also located within the UK.

The data that we collect from you may be transferred to, and stored at, a destination outside of the EEA. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers.

Where we use third party service providers to assist us, your information may also be stored in accordance with their practices and procedures. We require third parties to respect the security of your information and to treat it in accordance with the law.

If your data is transferred outside of the EEA, we will take steps to ensure your personal information is adequately protected by, for example, ensuring appropriate safeguards are in place governing the transfer.

Rights of access, correction, erasure, and restriction

Your rights in connection with your personal information

Under certain circumstances, by law you have the right to:

Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request the erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to stop processing personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact our Data Protection Officer in writing using the contact details set out at the beginning of this privacy policy.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

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 the information or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to another person who has no right to receive it.

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our Data Protection Officer in writing using the contact details set out at the beginning of this privacy policy.

Where we are providing you with marketing information, you can also change your marketing preferences via your online account (if you have one with us) or by using the unsubscribe button at the bottom of our marketing emails to you.

Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so.

What happens if you fail to provide personal information?

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as providing you with our products or services), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of visitors to our offices).

Right to complain

You have a right to make a complaint if you wish to do so. The organisation with oversight of our processing is the Information Commissioner’s Office, which can be contacted in writing at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, by telephone (0303 123 1113) or by e-mail (casework@ico.org.uk).

Changes to this privacy notice

We may change, modify, add or remove portions of this policy at any time, and any changes will become effective immediately.

Any changes we make to our privacy policy will be posted on this page and, where appropriate, notified to you.