Gordon MacRae & Co Ltd (“GMC” or “We”) are committed to protecting and respecting your privacy.

This policy (together with the terms of use of the GMC website which are available in the link below link for this privacy policy on the GMC website) and any other documents referred to in those terms) sets out the basis on which any personal data We collect from you (you being a user of the website who provides or otherwise leaves personal data on our website hereafter defined as “You”), or that You provide to us, will be processed by us.  Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of the EU General Data Protection Regulation and the UK Data Protection Act 2018 (the “Act”), We are a data controller. Our data protection officer and nominated representative for the purpose of the Act is Mr C MacRae.

Information we may collect from you

We may collect and process the following data about You:

• Your name, address and contact details.
• Your date of birth and idetification information as required for regulatory reasons (such as copies of your passport, driver’s licence , utility bills or other froms of identification information).
• Employment details.
• `business and personal bank account details.
• Records of business meetings and communications such as emails, telephone cals, text messages and/or other forms of digital communication or other direct or indirect engagement.
• Copies of physical and/or electronic correspondence and other physical or electronic documentation.
• Information that You provide by filling in forms on our site www.gordonmacraeip.com (our site). This includes information provided at the time of registering to use our site, subscribing to our services, posting material, or requesting further services. We may also ask You for information if You report a problem with our site.
• If You contact us, We may keep a record of that correspondence.
• We may also ask You to complete surveys that We use for research purposes, although You do not have to respond to them.
• Details of your visits to our site including, but not limited to, traffic data, location data internet protocaol addresses(“IP addresses”) and other communication data or market research.

PURPOSES OF PROCESSING AND THE LEGAL BASIS OF PROCESSING

The personal data referred to above is required to provide You with the resources  and the services that You accessor request,  for our own business purposes and for regulatory purposes. The legal basis on which personal data collected from You is  processed is the legitimate interests persued by GMC for the purposes of its business and for the marketing of its business and services.

RECIPIENTS OR CATEGORIES OF RECIPIENTS OF PERSONAL DATA PROCESSED BY GMC

GMC supliers that are data processors of personal data collected by GMC include the following companies. Some of the suppliers of GMC may transfer Your personal data to third countries outwith the European Union and/or the UK (“third Countries”) for technical reasons and/or for the purpooses of their business and legitimate interests. Where any such third country does not have the benefit of an adequacy decision from the EU Commission, GMC sought to ensure that its suppliers are in compliance with applicable regulations including the GDPR , the Act and any other applicable laws or regulations concerning any personal data processed on behalf of GMC.

Suppliers which provides GMC’s email servers and website analytics information.

Suppliers which provide GMC with client identification and other regulatory services including anti-money laudering regulatory services.

Suppliers which provide web hosting services.

Suppliers which provide accounting services, cashroom services payroll services and tax services.

As a regulated business GMC may be required to share personal data processed by it with the UK Tax Authorities and UK Regulators including The Law Society of Scotland, The Information Commissioners’s Office, Her majesty’s Revenue and Customs and The Scottish Legal Complaints Commission.

GMC takes the security and confidentiality of Your personal data and other information very seriously and  accordingly GMC will not  share Your information or personal data with any other organisations unless You have expressly requested GMC to do so or unless GMC is required to do so by aplicable laws and/or regulations. GMC will not sell or rent Your information. All GMC personnel with access to your information are under duties of conidentiality.

ADDITIONAL INFORMATION REGARDING GMC PROCESSING OF PERSONAL DATA

The period for which GMC holds personal data dpepends on several factors including (without limitation): the purpose for which the personal data was collected, whether its dletion is reuested by the relevant data subject or as required by by aplicable laws and/or regulations.

For clients of GMC, their personal data will be held for the duration of the client’s engagement of the firm and for a further period of the longer of; (i)  seven years or (ii)  such longer period as is prescribed by the insureres of GMC or by aplicable laws and/or regulations.

Any data subject whose personal data GMC processes has the right to request: (i) access to their personal data held by GMC (except where the relevant data subject already has such personal data or information) and/or (ii) GMC to correct his or her personal data, and/or (iii) erasure of such personal data and/orrestriction of processing of such personal data and/or (iv) restriction of such data processing and/or (v) to object to the processing of such personal data, and/or (vi) the data portability of such personal data (except where the relevant data subject already has such personal data or information).

Where any processing carried out by GMC is based on consent rather than legitimate interest, the data subject of any such  processing, the relevant data subject has the right to withdraw consent at any time, athough such withdrawal of onsent may impede the ability of GMC to provide any requested services to the relevant data subject that so withdraws their consent.

Every data subject whose personal data os processed by GMC has the opportunity to raise an complaint regarding any such processing of personal data with a supervisory authority. In the UK the supervisory authority is the Information Comssioner’s Office.  

For marketing purposes GMC shall hold personal data collected for the duration of its business unless the relevant data subject requests that such processing for marketing purposes ceases. Any data subjects wishing to request ther removal from GMC marketing lists should use the contact form at the bottom of any page of the GMC website to intimate such request to GMC.

GMC does not process personal data that has not been obtained from the data subject.

IP addresses and cookies

We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.

For the same reason, We may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. They help us to improve our site and to deliver a better and more personalised service. They enable us:

• To estimate our audience size and usage pattern.
• To store information about your preferences, and so allow us to customise our site according to your individual interests.
• To speed up your searches and to improve Our website and how you use it.
• To recognise You when You return to our site.
• To support our advertising online and on social media.

Often websites have cookies that are either strictly necessary or optional. Our site only uses strictly necessary cookies which are necessary for the website to be able to function correctly. The categories these strictly necessary cookies that GMC may use on Our website are as follows.

Cookies that help GMC provide services and information to You.

Cookies that help keep the GMC website optimsed and secure. Google Analytics is used by GMC to provide cookies that alllow GMC to carry out these functions for its website.

Cookies that help us detect fraud or crime by assisting GMC to identify suspicious behaviour on the GMC website.

GMC does not have to ask for your permission to store these cookies on your browser.

You may refuse to accept cookies by activating the setting on your browser which allows You to refuse the setting of cookies. However, if You select this setting You may be unable to access certain parts of our site. Unless You have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when You log on to our site.

Where We store your personal data

The data that We collect from You may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff  operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your instructions if you become a client of the company, the processing of your payment details and the provision of support services. By submitting your personal data, You agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

All information You provide to us is stored on secure servers. Where We have given You (or where You have chosen) a password which enables You to access certain parts of our site, You are responsible for keeping this password confidential. We ask You not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although We will do our best to protect your personal data, We cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once We have received your information, We will use strict procedures and security features to try to prevent unauthorised access.

Uses made of the information

We use information held about You in the following ways:

• To ensure that content from our site is presented in the most effective manner for You and for your computer.
• To provide You with information, products or services that You request from us or which We feel may interest You, where You have consented to be contacted for such purposes.
• To carry out our obligations arising from any contracts entered into betWeen You and us.
• To allow You to participate in interactive features of our service, when You choose to do so.
• To notify You about changes to our service.

We may also use your data, or permit selected third parties to use your data, to provide You with information about goods and services which may be of interest to You and We or they may contact You about these by post or telephone.

If You are an existing client, We will only contact You by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale to You.

If You are a new client, and where We permit selected third parties to use your data, We (or they) will contact You by electronic means only if You have consented to this.

If You do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which We collect your data (the registration form).

Disclosure of your information

We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section [736] of the UK Companies Act 2006.

We may disclose your personal information to third parties: if We are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use (which are available in the link below link for this privacy policy on the GMC website) and other agreements; or to protect the rights, property, or safety of Gordon MacRae & Co Limited, our clients, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection, identification and credit risk reduction.

Your rights

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform You (before or when collecting your data through our contact forms on this website). If We intend to use your data for such purposes or if We intend to disclose your information to any third party for such purposes.

We may occasionally by post/email/telephone with updates regarding changes in legal or regulatory rquirements or to inform you of other information we are releasing that may be of interrest to You and Your business. You can exercise your right to prevent such processing by checking certain boxes on the forms We use to collect your data.  You can also exercise the right at any time by contacting us at chris.macrae@gordonmacraeip.co.uk.

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates.  If You follow a link to any of these websites, please note that these websites have their own privacy policies and that We do not accept any responsibility or liability for these policies.  Please check these policies before You submit any personal data to these websites.

Access to information

The GDPR and the Act give You the right to access information held about You as well as the other rights discussed in this privacy policy and the rights mentioned below. Your right of access can be exercised in accordance with the GDPR and the Act. After an initial request for a copy of Your information held, any access request may be subject to a reasonable fee to meet our costs in providing You with details of the information we hold about You.

You have the following rights concerning Your personal information processed by GMC.

            -Access to Your personal data.

            -Deletion of Your personal data (unless subject to statutory or regulatory retention rules).

            -Objecting To How Gmc Uses Your Information For Marketing Purposes.

Changes to our privacy policy

Any changes We may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to You by e-mail.

Contact

The registered office address of Gordon MacRae & Co Ltd is : CBC House, 24 Canning Street, Edinburgh EH3 8EG.

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to Data Protection Officer at Gordon MacRae & Co Ltd by emailing: chris.macrae@gordonmacraeip.com.

COMPLAINTS

GMC wishes to resolve any issues or complaints you may have regarding its processing of your personal data directly with You. If You have any concerns please contact our DPO using the following email address:chris.macrae@gordon macraeip.com.

You do have the right to file a complaint with:The information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Chechire, SK9 5AF.Telephone: 03031231113 or 01625 545 745. Website: https://ico.org.uk/concerns.