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Privacy and Cookies Policies

Privacy Policy

This Privacy Policy explains how we use personal data for different purposes at Firinn.

If you are a user of one of our services or products, please refer to any privacy notices that have been made available to you separately in relation to those products and services.

The UK data protection regulator is the Information Commissioner’s Office: https://ico.org.uk

How we use personal data from website users

OVERVIEW

This Privacy Policy describes how Firinn Data Services Limited ("Firinn", “we”, “us”, “our”), as a data controller, collects and uses personal data about you if you use www.firinnservices.com (our “site“). It applies to all users of our site.

THE PERSONAL DATA WE WILL USE

We need to collect, store, and use the following categories of personal data about users of our site:

  • Technical Data

This includes internet protocol (IP) address, 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 our site.

  • Usage Data

This includes information about which pages you visit on our site.

We may collect, use, and share “Aggregated Data” such as statistical or demographic data. Aggregated Data may be derived from your Technical Data or Usage Data but is not considered personal data in law as it does not directly or indirectly reveal your identity.

For example, we may aggregate your Usage Data to calculate the number of users accessing a specific feature of our site. However, if we combine or connect Aggregated Data with Technical Data or Usage Data so that it can directly or indirectly identify you, we will treat the combined data as personal data which will be used in accordance with this privacy notice.

  • Data You Provide to Us

This includes any personal data you voluntarily submit via forms on our site, such as our contact forms.

This may include:

  • Name;

  • Email address;

  • Job role;

  • Company name; and

  • Any other personal data you include in your message.

We collect this information to allow us to address, and respond to, your enquiries, and/or provide the information or services you request.

HOW WE WILL USE PERSONAL DATA

We will use your Technical Data to administer and protect our business and the site (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data). This is necessary for our legitimate interests (for running our business, network security and to prevent fraud) and thus also necessary to comply with a legal obligation.

We will use your Technical Data and Usage Data for data analytics to improve our site. This is necessary for our legitimate interests (to keep our site updated and relevant, and to develop our business).

We will use Data You Provide to Us to allow us to address your enquiries, to provide the information or services you request, and to maintain effective communication with you. This is necessary for our legitimate interests (operating and growing our business, including customer service and managing potential client relationships).  In some cases, if required, we rely on your consent as the lawful basis for the processing of this data.

We will only use personal data for the following purposes:

  • where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

  • to fulfil legal or regulatory requirements if necessary.

HOW YOUR PERSONAL DATA WILL BE COLLECTED

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

AUTOMATED DECISION-MAKING

No decisions will be taken about you using automated means.

THIRD PARTIES

We may disclose Technical Data, Usage Data or Data You Provide to Us to our service providers who operate elements of our site and/or process Technical Data or Usage Data on our behalf. Our hosting provider is Squarespace. We may also need to share your personal data with a regulator or to otherwise comply with the law.

We may need to transfer Technical Data, Usage Data or Data You Provide to Us that we collect within our company group, or with third parties, who are based outside the EEA. 

Where such disclosures are made, this will be under contractual arrangements with us and carried out in accordance with the requirements of data protection law. We will satisfy ourselves that we have a lawful basis on which to share the Technical Data, Usage Data or Data You Provide to Us and document our decision making and satisfy ourselves we have a legal basis on which to share that information.

We may also need to share your personal data with a regulator or to otherwise comply with the law.

DATA SECURITY

We have appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data only to those involved in the maintenance of our site. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

HOW LONG WE WILL USE YOUR PERSONAL DATA FOR

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 

ACCURACY OF DATA

It is important that the Technical Data or Usage Data we hold about you is accurate and current, and we will take reasonable steps to ensure that this is the case.

YOUR RIGHTS

Under certain circumstances, by law 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 information we hold about you corrected.

  • 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 exercised your right to object to processing (see below).

  • object to processing of your personal data where we are relying on legitimate interests and personal circumstances give you reason to do so. You also have the right to object where we are processing your personal data for direct marketing purposes.

  • request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.

  • request the transfer of your personal data to another party.

  • make a complaint (at any time) to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). We may charge a reasonable fee or we may refuse to comply if your request for access is clearly unfounded or excessive.

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 an appropriate security measure to ensure that personal data is not disclosed to anyone who has no right to receive it.

IF YOU HAVE ANY QUESTIONS

Firinn has a Data Protection Officer (DPO). You can email the DPO at dpo@firinnservices.com.

IF YOU HAVE A COMPLAINT

The Information Commissioner’s Office is the official regulator of personal data in the UK. You can find its contact details here: https://ico.org.uk

We may update this notice from time to time. (Last updated: 16th May 2025)

How we use personal data from people who subscribe to our mailing lists

OVERVIEW

This privacy notice describes how Firinn Data Services Limited ("Firinn", “we”, “us”, “our”), as a data controller, collects and uses personal data about you if you are on our list of recipients for our occasional update emails, which typically contain news about us and our work, which we believe is of interest to you (“Mailings”).

THE PERSONAL DATA WE USE

We need to collect, store, and use the following categories of personal data about people to whom we send Mailings:

Contact Details – your name and your email address.

We also keep a record of ‘relevance criteria’. This is brief information about your employer or your business, how you came to be on our list, and why we believe you are interested in receiving Mailings from us.

HOW WE WILL USE PERSONAL DATA

We will only use personal data for the following purposes:

  • to send you Mailings, which we believe is in our legitimate interests, and is in accordance with the ICO’s ‘three-part test’.

  • where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

  • to fulfil legal or regulatory requirements if necessary.

HOW YOUR PERSONAL DATA IS COLLECTED

We will have your Contact Details because you have expressed an interest in Firinn. This may be because we have worked together, or because you have otherwise been in contact with one of our employees and given them your business card, or otherwise provided us with your Contact Details.

AUTOMATED DECISION-MAKING

No decisions will be taken about you using automated means.

THIRD PARTIES

We will not disclose your Contact Details to third parties, other than as set out in this section.

We may disclose your Contact Details to our service providers who operate elements of our mailing list and/or process your Contact Details on our behalf in order to manage our mailing lists.

We may need to transfer Contact Details that we collect within our company group, or with our service providers (as above), who are based outside the EEA.

Where such disclosures are made, this will be under contractual arrangements with us and carried out in accordance with the requirements of data protection law. We will satisfy ourselves that we have a lawful basis on which to share your Contact Details and document our decision making and satisfy ourselves we have a legal basis on which to share that information.

We may also need to share your Contact Details with a regulator or to otherwise comply with the law.

DATA SECURITY

We have appropriate security measures to prevent your Contact Details from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We limit access to your Contact Details only to those involved in the administration of the Mailings.

HOW LONG WE WILL USE YOUR PERSONAL DATA FOR

We will only retain your Contact Details for as long as necessary to send you Mailings, or for the purposes of satisfying any legal, accounting, or reporting requirements.

ACCURACY OF DATA

It is important that the Technical Data or Usage Data we hold about you is accurate and current, and we will take reasonable steps to ensure that this is the case. You should also tell us if your Contact Details change.

YOUR RIGHTS

Under certain circumstances, by law 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 information we hold about you corrected.

  • 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 exercised your right to object to processing (see below).

  • object to processing of your personal data where we are relying on legitimate interests and personal circumstances give you reason to do so. You also have the right to object where we are processing your personal data for direct marketing purposes.

  • request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.

  • request the transfer of your personal data to another party.

  • make a complaint (at any time) to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). We may charge a reasonable fee or we may refuse to comply if your request for access is clearly unfounded or excessive.

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 an appropriate security measure to ensure that personal data is not disclosed to anyone who has no right to receive it.

IF YOU HAVE ANY QUESTIONS

Firinn has a Data Protection Officer (DPO). You can email the DPO at dpo@firinnservices.com.

IF YOU HAVE A COMPLAINT

The Information Commissioner’s Office is the official regulator of personal data in the UK. You can find its contact details here: https://ico.org.uk

We may update this notice from time to time. (Last updated: 16th May 2025)

COOKIES POLICY

Our site uses cookies. Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are widely used by website owners in order to make their websites work, or to work more efficiently, as well as to provide reporting information.

WHY WE USE COOKIES

We use cookies for several reasons. Some cookies are required for technical reasons in order for our site to operate, and we refer to these as “essential” cookies. Other cookies are used to monitor which pages you go visit, and how long you spend on each page. This information helps us to understand how we can improve our user experience in our future work. Use of these non-essential cookies are described in more detail below. 

HOW YOU CAN CONTROL COOKIES 

Essential cookies are always automatically turned on because they are necessary for the core functionality of this site, such as security and network management. 

You can choose to accept or reject the use of non-essential cookies when you first visit our site. Turning off cookies is likely to limit the functionality of our site. 

You can also usually switch cookies off by adjusting your browser settings to stop it from accepting cookies. The Help function within your browser should tell you how to do this. 

To find information relating to particular browsers, visit the browser developer's website.

THE TYPES OF COOKIES WE USE

The specific types of cookies served through our site, as well as the purpose and expiration of each, are detailed in this Squarespace cookies page.

For questions regarding this Cookies Policy or to confirm the latest information regarding cookies used on our site, please contact dpo@firinnservices.com.

We may update this Cookies Policy from time to time in order to reflect, for example, changes to the cookies we use or for other operational, legal, or regulatory reasons. Please therefore revisit this Cookies Policy regularly to stay informed about our use of cookies and related technologies. Any changes will be reflected in this Cookies Policy notice and any tools used to implement cookies on our site, and will take effect as soon as they are posted.

CONTACT 

Firinn has a Data Protection Officer (DPO), who oversees compliance with this privacy notice. If you have any questions about this privacy notice or how we use personal data, please contact the DPO (dpo@firinnservices.com).

We may update this notice from time to time. (Last updated: May 16th 2025)