Privacy Policy

Policy version: 24 August, 2023

https://www.whitebox.legal (our website) is provided by Whitebox Legal Ltd, a company incorporated and registered under the laws of England and Wales with company number 14550567, trading as Whitebox (‘we’, ‘our’ or ‘us’). We are the controller of personal data obtained via our website, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our website. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR).

This privacy policy is divided into the following sections:

What this policy applies to
Personal data we collect about you
How your personal data is collected
How and why we use your personal data
Marketing
Who we share your personal data with
How long your personal data will be kept
Transferring your personal data out of the UK
Cookies and other tracking technologies
Your rights
Keeping your personal data secure
How to complain
Changes to this privacy policy
How to contact us

This privacy policy relates to your use of our website only.

What this policy applies to
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‍This privacy policy relates to your use of our website only.
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Throughout our website we may link to other websites. Those third party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to those third party websites, please consult their privacy policies as appropriate.

The personal data we collect about you depends on the particular activities carried out through our website. We will collect and use the following personal data about you:

Personal data we collect about you
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‍The personal data we collect about you depends on the particular activities carried out through our website. We may collect and use the following personal data about you:

your name, address and contact information, including email address and telephone number and company details, if you choose to give this to us
information to check and verify your identity, e.g. date of birth
your gender, if you choose to give this to us
location data, if you choose to give this to us
your billing information, transaction and payment card or other payment method information
bank account and payment details
details of any information, feedback or other matters you give to us by phone, email, post or via social media
your account details, such as username and login details
your activities on, and use of, our website
your professional online presence
information about the services we provide to you
your contact history, purchase history and saved items
information about how you use our website and technology systems
your responses to surveys, competitions and promotions

‍You must provide this personal data to use our website and the services on it unless we tell you that you have a choice.

Sometimes you can choose if you want to give us your personal data and let us use it. Where that is the case we will tell you and give you the choice before you give the personal data to us. We will also tell you whether declining to share that personal data will have any effect on e.g. your use of our website or any services on it.

We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.

We collect personal data from you:

How your personal data is collected
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‍We collect personal data from you:

directly, when you enter or send us information, such as when you register with us, contact us (including via email), send us feedback, purchase products or services via our website, post material to our website or complete customer surveys, and
indirectly, such as your browsing activity while on our website; we will usually collect information indirectly using the technologies explained in the section on ‘Cookies and other tracking technologies’ below

How and why we use your personal data
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‍Under data protection law, we can only use your personal data if we have a proper reason, eg:

where you have given consent
to comply with our legal and regulatory obligations
for the performance of a contract with you or to take steps at your request before entering into a contract, or
for our legitimate interests or those of a third party

A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).

The table below explains what we use your personal data for and why.

What we use your personal data for

Our reasons

Create and manage your account with us

To perform our contract with you or to take steps at your request before entering into a contract

Providing services to you

To perform our contract with you or to take steps at your request before entering into a contract

Conducting checks to identify you and verify your identity or to help prevent and detect fraud against you or us

For our legitimate interests, i.e. to minimise fraud that could be damaging for you and/or us

To enforce legal rights or defend or undertake legal proceedings

Depending on the circumstances:
—to comply with our legal and regulatory obligations
—in other cases, for our legitimate interests, ie to protect our business, interests and rights

Customise our website and its content to your particular preferences based on a record of your selected preferences or on your use of our website

Depending on the circumstances:
—your consent as gathered by the separate cookies tool on our website—see ‘Cookies and other tracking technologies’ below
—where we are not required to obtain your consent and do not do so, for our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price

If you have provided such a consent you may withdraw it at any time by changing the setting on the cookies tool (this will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn)

Retaining and evaluating information on your recent visits to our website and how you move around different sections of our website for analytics purposes to understand how people use our website so that we can make it more intuitive or to check our website is working as intended

Retargeting ads

Your consent as gathered by the separate cookies tool on our website—see ‘Cookies and other tracking technologies’ below

If you have provided such a consent you may withdraw it at any time by changing the setting on the cookies tool (this will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn)

Communications with you not related to marketing, including about changes to our terms or policies or changes to the services or other important notices

Depending on the circumstances:
—to comply with our legal and regulatory obligations
—in other cases, for our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price

Protecting the security of systems and data used to provide the services

To comply with our legal and regulatory obligations

We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, ie to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us

Statistical analysis to help us understand our customer base

For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price

Updating and enhancing customer records

Depending on the circumstances:
—to perform our contract with you or to take steps at your request before entering into a contract
—to comply with our legal and regulatory obligations
—where neither of the above apply, for our legitimate interests, e.g. making sure that we can keep in touch with our customers about existing orders and new products

Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, e.g. to record and demonstrate evidence of your consents where relevant

To comply with our legal and regulatory obligations

Marketing our services to existing and former customers

For our legitimate interests, i.e. to promote our business to existing and former customers

See ‘Marketing’ below for further information

The audit of the Information Commissioner’s Office or any other regulatory body as may be applicable

For our legitimate interests, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards

To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency

In such cases information will be anonymised where possible and only shared where necessary

Depending on the circumstances:
—to comply with our legal and regulatory obligations
—in other cases, for our legitimate interests, i.e. to protect, realise or grow the value in our business and assets

How and why we use your personal data—sharing
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See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.

We will use your personal data to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new products or services.

Marketing

‍We may use your personal data to send you updates (by email, text message, telephone or post) about our products and services, including exclusive offers, promotions or new products or services.

We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.

You have the right to opt out of receiving marketing communications at any time by using the ‘unsubscribe’ link in emails.

We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

We will always treat your personal data with the utmost respect and never sell it to other organisations for marketing purposes.

For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below. We routinely share personal data with:

Who we share your personal data with
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‍We routinely share personal data with:

third parties we use to help deliver our services to you, e.g. payment service providers
other third parties we use to help us run our business, e.g. website hosts and website analytics providers, such as Google Analytics

We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.

We or the third parties mentioned above occasionally also share personal data with:

our and their external auditors, e.g. in relation to the audit of our or their accounts, in which case the recipient of the information will be bound by confidentiality obligations
our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations
law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations
other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations

More details about who we share your personal data with and why are set out in the table below

Who we share your personal data with—further information
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‍If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

We will not keep your personal data for longer than we need it for the purpose for which it is used.

How long your personal data will be kept
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‍We will not keep your personal data for longer than we need it for the purpose for which it is used.

Different retention periods apply for different types of personal data.
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If you stop using your account we will delete or anonymise your account data after seven years.

Following the end of the relevant retention period, we will delete or anonymise your personal data.

Transferring your personal data out of the UK
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The UK and other countries outside the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.

It is sometimes necessary for us to transfer your personal data to countries outside the UK. In those cases we will comply with applicable UK laws designed to ensure the privacy of your personal data.

Under data protection laws, we can only transfer your personal data to a country outside the UK where:

the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR. A list of countries the UK currently has adequacy regulations in relation to is available via the link here. We rely on adequacy regulations for transfers to the following countries: countries in the EEA
there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you, or
a specific exception applies under relevant data protection law

‍Where we transfer your personal data outside the UK we do so on the basis of an adequacy regulation or (where this is not available) legally-approved standard data protection clauses recognised or issued further to Article 46(2) of the UK GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this policy.

Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to transfer personal data internationally will be notified to you in accordance with the section on ‘Changes to this privacy policy’ below.

Transferring your personal data out of the UK—further information
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If you would like further information about data transferred outside the UK, please contact us (see ‘How to contact us’ below).

Cookies and other tracking technologies
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A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use a website. These help website providers recognise you and your device and store some information about your preferences or past actions. We do not use cookies on our website.

For further information on cookies and our use of them, please see our Cookie Policy via the link here.

Your rights
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‍You generally have the following rights, which you can usually exercise free of charge:

The right to be provided with a copy of your personal data

A more detailed explanation of this right under UK law is available via the link here

Access to a copy of your personal data

Correction (also known as rectification)

The right to require us to correct any mistakes in your personal data

A more detailed explanation of this right under UK law is available via the link here

Erasure (also known as the right to be forgotten)

The right to require us to delete your personal data—in certain situations

A more detailed explanation of this right under UK law is available via the link here

Restriction of use

The right to require us to restrict use of your personal data in certain circumstances, eg if you contest the accuracy of the data

A more detailed explanation of this right under UK law is available via the link here

Data portability

The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations

A more detailed explanation of this right under UK law is available via the link here

To object to use

The right to object:
—at any time to your personal data being used for direct marketing (including profiling)
—in certain other situations to our continued use of your personal data, eg where we use your personal data for our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims
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A more detailed explanation of this right under UK law is available via the link here

Not to be subject to decisions without human involvement

The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

We do not make any such decisions based on data collected by our website. A more detailed explanation of this right under UK law is available via the link here

The right to withdraw consents

If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time

You may withdraw consents by contacting our Data Protection Officer as set out in ‘How to contact us’ section below

Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn

For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner available via the link here on your rights under the UK GDPR.

If you would like to exercise any of those rights, please email, call or write to us—see below: ‘How to contact us’. When contacting us please:

provide enough information to identify yourself (e.g. your full name, address and customer or matter reference number) and any additional identity information we may reasonably request from you, and
let us know which right(s) you want to exercise and the information to which your request relates

Keeping your personal data secure
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We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine need to access it.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

How to complain
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‍Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with:

the Information Commissioner in the UK

The UK’s Information Commissioner may be contacted using the details here or by telephone: 0303 123 1113

Changes to this privacy policy
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‍We may change this privacy policy from time to time—when we make significant changes we will take steps to inform you, for example by including a prominent link to a description of those changes on our website for a reasonable period or by other means, such as email.

You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

How to contact us
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‍Individuals in the UK

‍You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details are shown below:

Our contact details

Our Data Protection Officer details

Whitebox Legal Ltd
27 Old Gloucester Street
London
WC1N 3AX
England

fp@whitebox.legal
+44 20 4577 3366

Mr. Volodymyr Gromoglasov
27 Old Gloucester Street
London
WC1N 8AX
England

vg@whitebox.legal