Privacy Policy

How we use your personal data for marketing

We will add your details to our marketing database if:

• you make an enquiry about our services
• we supply services to you
• you share your business card with us
• you have expressed an interest in receiving certain marketing communications, newsletters or legal updates from us
• you have told a third party that you would like them to pass us your contact details so that we can send you updates about our services

We may send you marketing communications about our services, or matters relating to our services, such as newsletters and updates, by email.

You can ask us not to send you any marketing communications at any time by choosing the ‘unsubscribe’ option included in each email or by calling or emailing us using the details set out in the Who we are and how you can contact us section above.

When we will share your personal data with others

We may share your data with the following external third parties, where necessary, in the day to day running our business:

• business partners, suppliers and sub-contractors we work with to provide you with services that you have requested from us. This includes providers of IT support and consultancy services and cloud storage providers
• our marketing partner to provide you with marketing communications and newsletters (see How we use your personal data for marketing for more information)
• analytics and search engine providers that assist us in the improvement and optimisation of our site

We may also share your personal information with third parties on a one-off basis, for example, if:

• we sell or buy any business or assets (including our own), in which case we will disclose your personal data to the prospective seller or buyer of such business or assets
• 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 and conditions of service (should you require a copy of our Terms and Conditions please contact mail@stratagemipm.co.uk ) and other agreements; or to protect the rights, property, or safety of our customers, ourselves or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

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.

When we will send your personal data to other countries

We do not routinely transfer or store your personal data outside of the UK.

However, we may make such transfers or seek to store personal data on servers located outside of the UK where we consider this necessary in order to deliver specific services to you, or to effectively maintain our IT systems and infrastructure.

If we do transfer or store your personal data outside of the UK, we will ensure that it is given an equivalent degree of protection by implementing one of the following safeguards:

• confirming that the country to which personal data is transferred, or in which it is stored, is subject to a UK adequacy decision, meaning that the country provides an adequate level of protection for personal data;
• executing contracts containing standard contractual clauses which have been approved for use when personal data is transferred from the UK and which require the recipient to give the personal data the same protection it has in the UK; or
• ensuring that your personal data is only transferred or stored outside of the UK where specific and appropriate derogations set out in data protection legislation apply.

The contracts that we have in place with our sub-contractors require them to seek our permission before transferring or storing your data outside of the UK. Our consent will only be given where sub-contractors can demonstrate that one of the above safeguards has been implemented.

Please contact us if you want further information on whether your personal data has been transferred or stored outside of the UK and the specific safeguards used by us.

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 services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.

Your rights to know what personal data we hold and to control how we use it

If you are an individual, you have a legal right to know what personal data we hold about you – this is called the right of subject access.

You can exercise this right by sending us a written request at any time. Please mark your correspondence with “Subject Access Request” and send it to us by post or email using the details in the Who we are and how you can contact us section. We try to respond to all legitimate requests within one month.

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

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

You also have rights, in certain circumstances, to:

• have inaccurate personal data corrected, blocked or erased
• object to our using your personal data in ways that are likely to cause you damage or distress as well as the right to data portability
• restrict our use of your personal data
• require that we delete your personal data

You can find full details of your rights in respect of personal data on the Information Commissioner’s Office website at www.ico.org.uk.

Automated decision making and profiling

We do not make use of automated decision making or profiling.

How we keep your personal data safe

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.

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business “need to know”. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

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.

How long we keep your personal data

We only keep your personal data for as long as we actually need it or as required by law.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us using the details set out in the Who we are and how you can contact us section above.

Please note that we may anonymise your personal data or use it for statistical purposes. We keep anonymised and statistical data indefinitely, but we take care to ensure that such data can no longer identify or be connected to any individual.

Cookies

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 our website and also allows us to improve our website. For detailed information on the cookies we use and the purposes for which we use them see our Cookie policy on our website.

How you can make a complaint

If you are unhappy with the way we have used your personal data, please contact us to discuss this using the contact details set out in the Who we are and how you can contact us section above.

You are also entitled to make a complaint to the Information Commissioner’s Office which you can do by visiting www.ico.org.uk. Whilst you are not required to do so, we encourage you to contact us directly to discuss any concerns that you may have and to allow us an opportunity to address these before you contact the Information Commissioner’s Office.

How we keep this policy up to date

We keep our privacy policy under regular review any may update it to reflect a change in the services we offer, our internal procedures, or a change in the law.

The easiest way to check for updates is by looking for the latest version of this policy on our website (www.stratagemipm.co.uk) or you can contact us (see Who we are and how to contact us) to ask us to send you the latest version of our policy.

This policy came into effect in June 2025.