Privacy Policy (Last Updated: 25 May 2018)

This website is brought to you by Financial Systems & Consultancy Ltd of Stable Mews, Beechwood Estate, Elmete Lane, Leeds, United Kingdom, LS8 2LQ (we, our or us). We also operate from another company called Lake Business Systems & Consultancy Ltd of the same address (together, the Group). We are committed to protecting and respecting your privacy. We are the data controller (i.e. the company who is responsible for, and controls the processing of, your personal data).

If you are an employee, contractor or would like to work for us, we have a separate privacy policy which describes how we process your personal data and this is available on request.

This policy sets out the basis on which any personal data we collect from 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.

As part of the solutions and services we provide, we may also be the recipient of data sets and need to act as a data processor. This policy does not cover our data processing activities when we are acting as a data processor. When we are acting as a data processor, it is at the documented and lawful instruction of our customers, who are responsible for identifying the lawful basis for processing, and ensuring the integrity of the personal data we process on their behalf.

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1. 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 if you are a customer, supplier or other type of business partner whose relationship with us is governed by a contract. Please check back frequently to see any updates or changes to our privacy policy.

2. Information we may collect from you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you, such as:

  • Identity Data includes first name, last name, username or similar identifier, title.
  • Contact Data includes business addresses, email address and telephone numbers. We do not routinely collect email addresses or telephone numbers that are not business related, unless these are provided to us by you.
  • Financial Data includes bank account details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes such things as: Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

You may give us your personal data by filling in our Contact Form, using our Live Chat facility or by corresponding with us by post, phone, through social media, email or otherwise. This includes personal data you provide when you enquire about our products or services; engage our services; subscribe to our marketing; or otherwise liaise with us and our representatives.

As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. Please see our section on Cookies for further details.

We may receive personal data about you from our various technology vendors listed on our website, for example, Infor, SAP, Proactis Group or IBM.

We may also receive personal data about you from trusted advisory services and referral agencies from whom we have ongoing assurance that such information is passed only with your consent.

Informing us of changes: It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Information about other people: If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can give consent on his/her behalf to the processing of his or her personal data and receive on his/her behalf any data protection notices.

Monitoring: We may monitor and record communications with you (such as emails) for the purpose of quality assurance, training, fraud prevention and compliance.

Credit checking: To enable us and other companies in our group to make credit decisions about your business (as a customer) and for fraud prevention and money laundering purposes, we may search the files of credit reference and fraud prevention agencies (who will record the search). We may disclose information about how you conduct your account to such agencies. Other credit grantors may use this information to make credit decisions about your business, as well as for fraud prevention, debtor tracing and money laundering purposes. If you provide false or inaccurate information and we suspect fraud, we will record this.

4. Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/Activity Lawful basis for processing including basis of legitimate interest
To register new customers (and their representatives, if applicable) and suppliers Performance of a contract
To process and provide your services, including to manage payments, fees and charges, and collect and recover money owed to us Performance of a contract
To manage our relationship with you, which will include correspondence, service messages, and notifying you about changes to our terms or policies Performance of a contract
On occasion asking you to leave a review or take a survey Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To send you information and make suggestions and recommendations to you about goods or services that may be of interest to you, by telephone, email or post Necessary for our legitimate interests (to develop our products/services and grow our business)
To pass your information onto trusted vendors, for example, Infor, SAP, Proactis Group or IBM Performance of a contract
If you have specifically opted in to receive marketing from us Consent

Information we receive from other sources: We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).

5. Disclosure of your personal data

We may share your personal information with any member of our Group.

We may share your information with selected third parties including:

  • business partners, suppliers and sub-contractors in conjunction with business needs, for the performance of any contract we enter into with them or you;
  • analytics and search engine providers that assist us in the improvement and optimisation of our website; and
  • credit reference agencies for the purpose of assessing the credit score for your business (as a customer) where this is a condition of us entering into a contract with you.
  • service providers acting as processors based in the UK, the rest of the EU, the USA and Australia who provide IT and cloud hosting and telemarketing services.
  • professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
  • Vendor partners such as Infor, SAP, Proactis Group or IBM for products you use or are in the process of buying or to which you are in the process of subscribing.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. Cookies

A cookie is a small text file which is placed onto your computer (or other electronic device) when you access our website.

Cookies are small files saved to your computer’s hard drive that track, save and store information about your interactions and usage of the website. This allows the website, through its server to provide the users with a tailored experience.

We do not add cookies to the website. Some of our third parties, as part of the services they provide will and they are: Google Adwords, Bings Ads, LeadForensics and LiveChat. These third-party suppliers are responsible for the cookies they set on our website. If you want further information please go to the website for the relevant third party.

This website uses tracking software to monitor its visitors to better understand how they use it. This software is provided by Google Analytics which uses cookies to track visitor usage. The software will save a cookie to your computer’s hard drive in order to track and monitor your engagement and usage of the website, but will not store, save or collect personal information. You can read Google’s privacy policy here for further information https://www.google.com/privacy.html

How to turn off cookies

If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may lose some of the functionality of this website.

7. International Transfers

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • transferring to countries who have an Adequacy Ruling from the European Commission;
  • using specific contracts approved by the European Commission which give personal data the same protection it has in Europe;
  • transferring data to companies who are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

8. Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. However, the transmission of information via the internet is not completely secure. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. Data Retention

We store customer data for a maximum period of 7 years after a customer ceases to use our services. We may delete some personal data sooner if requested to securely dispose of it sooner, in line with a data subject’s rights (see Your Rights below).

In the event of a legal requirement we may retain it for longer.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for 7 years after they cease being customers for tax purposes.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

10. Third Party Links

Our website 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.

11. Your rights

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Complain you have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

12. Contact

Questions, comments and requests regarding this privacy policy are welcomed, please either contact us by:

  • Email: info@lake.co.uk
  • Post: LAKE Financial Systems, Stable Mews, Beechwood Estate, Elmete Lane, Leeds, United Kingdom, LS8 2LQ
  • Telephone: 0113 273 7788