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 your personal data. It also explains your rights in relation to your personal data and how to contact us.
If you do not accept and agree with this Privacy Policy you must stop using our website www.laurencekeenan.com (“Our Website”) immediately.
This Privacy Policy (“Privacy Policy”) applies when you visit Our Website.
This Privacy Policy only applies to the use of your personal information obtained by us and explains our approach to any personal information that we collect from you or which we have obtained about you from a third party and the purposes for which we process your personal information. It also sets out your rights in respect of our processing of your personal information.
The Privacy Policy will inform you of the nature of your personal information that is processed by us and how you can respect that we delete, update, transfer and/or provide you with access to it.
Further, this Privacy Policy does not apply to information you might provide to us or we might collect in the context of our providing legal services under an advocate-client relationship. Where we are engaged to provide legal services, our Client Data Protection Policy applies.
We are Laurence Keenan Advocates Limited trading as Laurence Keenan Advocates & Solicitors, a company incorporated in the Isle of Man (company number 126958C) with registered office at Victoria Chambers, 47 Victoria Street, Douglas, Isle of Man, IM1 2LD (“LKAS”, “we”, “our”, and “us”).
We are a firm of Manx Advocates and are regulated by the Isle of Man Law Society.
We are a “data controller” for the purpose of data protection legislation.
If you have any questions about our Privacy Policy or your information, or wish to exercise any of your rights as described in this Privacy Policy or under data protection laws, you can contact us:
| By post: | Laurence Keenan Advocates & Solicitors Victoria Chambers 47 Victoria Street Douglas Isle of Man IM1 2LD |
| Data Protection Officer: | Craige Sansbury |
| By telephone: | +44 (0)1624 611933 |
| By email: | privacy@lklaw.co.im |
“Personal data’ means “any information relating to an identified or identifiable natural person (known as a ‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”
LKAS adheres to the following principles when processing your personal data:
You may choose to provide us with personal data when you are introduced to us, when we meet you in person, or when we are in contact by phone, email, via Our Website or otherwise.
The categories of personal data you provide may include:-
We collect most personal data from you directly. However, we may also collect information about you:
We do not use cookies or analytics on Our Website and do not collect any technical information from you when you access Our Website. No information about your visit and use of Our Website. Only information you provide to us voluntarily through the “Contact Us” feature of Our Website is collected or if you contact us under this Privacy Policy using the link below or by email to privacy@lklaw.co.im.
We do not generally seek to collect sensitive (or special categories of) personal data. Sensitive personal data is defined by data protection laws to include personal data revealing a person’s racial or ethnic origin, religious or philosophical beliefs, or data concerning health. If we do collect sensitive personal data, we will ask for your explicit consent to our proposed use of that information at the time of collection.
Our Website is not intended for or directed at children under the age of 16 years and we do not knowingly collect data relating to children under this age.
The purpose for which we use and process your information (excluding sensitive personal data) and the legal basis on which we carry out each type of processing is explained below.
| Purposes for which we will process the information | Legal Basis for the processing |
| To respond to your enquiries. | It is in our legitimate interests to respond to your queries and provide any information requested in order to generate and develop business. To ensure we offer a good and responsive service, we consider this use to be proportionate and will not be prejudicial or detrimental to you. |
| To enforce the terms and conditions and any contracts entered into with you. | It is in our legitimate interests to enforce our terms and conditions of service. We consider this use to be necessary for our legitimate interests and proportionate. |
| To send you information regarding changes to our policies, other terms and conditions and other administrative information. | It is in our legitimate interests to ensure that any changes to our policies and other terms are communicated to you. We consider this use to be necessary for our legitimate interests and will not be prejudicial or detrimental to you. |
| To send you updates, announcements, and other communications concerning LKAS | It is in our legitimate interests to market our services. We consider this use to be proportionate and will not be prejudicial or detrimental to you.
You can always opt-out of receiving direct marketing-related email communications by following the unsubscribe link contained in the communication. |
| To invite you to LKAS events, or functions we believe may be of interest to you. | It is in our legitimate interests to market our services. We consider this use to be proportionate and will not be prejudicial or detrimental to you.
You can always opt-out of receiving direct marketing-related email communications by following the unsubscribe link contained in the communication. |
A summary of the legal basis for each purpose is contained in Section 6 (How we use your Information) above.
In addition it may be necessary for us to use your personal information:-
Where we rely on “legitimate interests” as a lawful basis, we will carry out a balancing test to ensure that your interests, rights and freedoms do not override our legitimate interests.
If you do not wish to provide us with your personal data and processing such information is necessary for the performance of a contract with you, we may not be able to perform our obligations under the contract between us.
LKAS will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you in a timely manner and we will explain the legal basis which allows us to do so.
For email marketing to an individual subscriber (i.e. a non-corporate email address) with whom we have not previously engaged as a client, we need your consent to send you unsolicited email marketing.
Where you provide consent, you can withdraw your consent at any time, but without affecting the lawfulness of processing based on consent before its withdrawal.
You have the right to opt out of receiving email marketing communications from us at any time by contacting our Data Protection Officer using the contact details set out above.
We do not share your personal data with third parties except as provided in this Privacy Policy.
We share your information with the following third parties:-
Our third party processors and service providers are subject to security and confidentiality obligations and are only permitted to process your personal data for specified purposes and in accordance with our instructions.
As mentioned in Section 9 (Who do we share your personal information with?) above, we may appoint sub-contractor data processors as required to deliver the services, such as, (without limitation), document processing and translation services, IT systems or software providers and IT Support service providers, who will process personal information on our behalf and at our direction. We conduct an appropriate level of due diligence and put in place contractual documentation in relation to any sub-contractor to ensure that they process personal information appropriately and according to our legal and regulatory obligations.
We do not transfer your personal data outside the Isle of Man, or the European Economic Area (EEA).
We use industry standard physical and procedural security measures to protect information from the point of collection to the point of destruction. This includes encryption, firewalls, access controls, policies and other procedures to protect information from unauthorised access.
Where data processing is carried out on our behalf by a third party, we take steps to ensure that appropriate security measures are in place to prevent unauthorised disclosure of personal data.
Despite these precautions, however, LKAS cannot guarantee the security of information transmitted over the Internet or that unauthorised persons will not obtain access to personal data. In the event of a data breach, LKAS have put in place procedures to deal with any suspected breach and will notify you and any applicable regulator of a breach where required to do so.
Your personal data will not be kept for longer than is necessary for the purposes for which it was collected and processed and for the purposes of satisfying any legal, accounting, or reporting requirements.
The criteria we use for retaining different types of personal data, includes the following:
You have the following rights in relation to the personal information we hold about you:
If you ask us, we’ll confirm whether we’re processing your personal information and, if necessary, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
If the personal information we hold about you is inaccurate or incomplete, you are entitled to request to have it rectified. If you are entitled to rectification and if we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If you are entitled to erasure and if we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances (such as where you contest the accuracy of that personal information). If you are entitled to restriction and if we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
You have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.
You can ask us to stop processing your personal information, and we will do so, if we are:-
If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.
If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the Isle of Man Information Commissioner (via the contact details specified in Section 17 (Complaints) below.
Please note that some of these rights may be limited where we have an overriding interest or legal obligation to continue to process the data or where data may be exempt from disclosure due to reasons of legal professional privilege or professional secrecy obligations.
You can exercise any of your rights as described in this Privacy Policy and under data protection laws by contacting us as provided in “Contacting Us” above.
Our Website may, from time to time, contain links to and from third-party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and LKAS does not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Whilst every member of the LKAS team has a personal private email address, emails which you send to us or which we send to you may be monitored by LKAS to ensure compliance with professional standards and our internal compliance policies. Monitoring is not continuous or routine, but may be undertaken on the instruction of a director where there are reasonable grounds for doing so. Occasional spot checks or audits may also be undertaken on the instruction or with the authority of a director.
If you have any questions or complaints regarding our Privacy Policy or practices, please contact us as provided in “Contacting Us” above.
You have the right to make a complaint at any time with a supervisory authority where any alleged infringement of data protection laws occurred.
The supervisory authority in the Isle of Man is The Information Commissioner who can be contacted as follows:-
| By post: | First Floor, Prospect House, Prospect Hill, Douglas, Isle of Man, IM1 1ET |
| By telephone: | +44 (0)1624 693260 |
| By email: | ask@inforights.im |
| Via website: | www.inforights.im |
From time to time, we may change this Privacy Policy. The current version of this Policy will always be available from us in hard copy or on Our Website. We will post a notice on Our Website to notify you of any significant changes to this Policy.
Updated and effective as of 25th May 2018.