Privacy Policy

Introduction

Lindsell Train Limited (“LTL”) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from). This policy will tell you about your privacy rights and how the law protects you. 

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

1. Important information and who we are
2. The data we collect about you
3. How is your personal data collected
4. How we use your personal data
5. Disclosures of your personal data
6. International transfers
7. Data security
8. Data retention
9. Your legal rights
10. Glossary 

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how LTL collects and processes your personal data through your use of this website, including any data you may provide through this website.    

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them. 

Controller

Lindsell Train Limited (collectively referred to as “Lindsell Train”, “LTL” the “Company”, "we", "us" or "our" in this privacy notice) is the controller and responsible for your personal data 

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below. 

Contact details

Compliance Officer
Lindsell Train Limited
66 Buckingham Gate, London SW1E 6AU
compliance@lindselltrain.com

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. 

Changes to the privacy notice and your duty to inform us of changes

We may change this policy by updating this page. You should check this page from time to time to ensure that you are happy with any 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.

Third-party links

This website may include links to third-party websites, plug-ins and applications or store cookie files on your computer in order to deliver its service(s). Clicking on those links or enabling those connections may allow third parties to collect, store or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. The data we collect about 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, which we have grouped together as follows: 

We have then grouped together the data types within these categories as follows:

• Identity Data includes first name and last name.
• Contact Data includes company name and email address.
• Technical Data includes 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.
• Profile Data includes your username or similar identifier and password, your interests, preferences, feedback and survey responses.  
• Usage Data includes information about how you use our website, products and services. 
• Marketing Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Communications Data includes all communications we have with you whether by email, post, phone or otherwise.  

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:

• Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • inquire about our products or services;
  • request marketing documents or other publications to be sent to you;
  •  provide us with feedback. 
• Automated technologies or interactions. 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, server logs and other similar technologies. Please see our cookie declaration for further details.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below.
  • Technical Data from the following parties:
    • a. Analytics, storage, tools and media providers; 
    • c. automated quality control tools;
    • d. automated security and compliance tools;
    • e. social media and media networks such as Twitter, LinkedIn, Instagram, YouTube and Vimeo; and
    • f. email distribution and survey providers; 
  • Identity and Contact data from providers of data feeds and hosting services provided in the UK.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• To administer and manage delivery of our services and products to you.
• To send you requested product or service information and to market to you, for example by sending you our Managers Report or hosting networking events.
• To improve our websites and marketing efforts.
• 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.
• Where we need to comply with a legal or regulatory obligation such as regulatory reporting.

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.

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.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us  if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.

1. To administer and manage delivery of our services and products to you

Type of data
(a) Identity
(b) Contact

Lawful basis for processing including basis of legitimate interest
Performance of a contract with you

2. To manage our relationship with you 

This includes:

(a) Notifying you about changes to our terms or privacy policy
(b) Answering any queries you may have

Type of data

(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications

Lawful basis for processing including basis of legitimate interest

(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
(d) To deal with your enquiries

3. To administer and protect our business and this website 

This includes troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data.

Type of data

(a) Identity
(b) Contact
(c) Technical

Lawful basis for processing including basis of legitimate interest

(a) 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)
(b) Necessary to comply with a legal obligation

4. To deliver relevant website content to you and measure or understand the effectiveness of the content we serve to you

Type of data

(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical

Lawful basis for processing including basis of legitimate interest

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

5. To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

Type of data
(a) Technical
(b) Usage

Lawful basis for processing including basis of legitimate interest

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)

Marketing 

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and communications. We have established the following personal data control mechanisms:

You will receive marketing communications from us only where you have requested such information from us, and where you have not opted out of receiving that marketing.

Opting out

You can ask us to stop sending you marketing messages at any time by contacting us. 

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase or experience or other transactions.

Cookies

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site about aspects of your visit. For more information about the cookies we use and how you can control them, please see our cookie declaration.

Change of purpose 

We 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. 

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We will only share your personal data with third parties in the ways set out in this privacy policy.  We do not sell your personal data to third parties for them to market their services to you.

We may  share your personal data with our suppliers as necessary for our business activities, such as managing our client relationship system.  In all cases we will have a written processor agreement with these companies safeguarding your personal data, including that it may only be processed for the purposes of that agreement and on our instructions.

We may also disclose your personal data:

• as required by law, such as to comply with a regulatory obligation or similar legal process
• as allowed by law, such as when we believe in good faith that disclosure us necessary for our legitimate interest such as investigating fraud, to make or defend a legal claim, to protect your safety or the safety of others, or to maintain our compliance or that of our personnel with applicable laws, regulations and/pr professional obligations
• if Lindsell Train is involved in a merger, acquisition, or sale of all or a portion of its assets, we may disclose such personal data as is necessary for our legitimate interests in completing that transaction and always provided that appropriate safeguards are in place including limitations and restrictions on use, access and retention
• in other situations, only with your prior consent

6. International transfers

Wherever possible we do not transfer your personal data outside the UK or the European Economic Area (EEA).

All of our hosting is conducted in the UK but some of our external third party service providers are based outside the UK or the EEA so their processing of your personal data may sometimes involve a transfer of data outside the UK.

• Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• We will establish a processing agreement with any processor that safeguards your personal data including that it may only be processed for the purposes of that agreement and on our instructions.

Please contact us if you would like further information on the specific mechanism used by us when transferring your personal data out of the UK or the EEA. 

7. Data 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. 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.

If you have any questions regarding the security of your personal data please contact us.

8. Data retention

How long will you use my 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. 

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 by contacting us. In some circumstances you can ask us to delete your data: see Request erasure  below for further information.

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. 

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights: 

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent. 

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

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 may refuse to comply with your request in these circumstances.

What we may need from you

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.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. 

10. Glossary

Lawful basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Your legal rights

You have the right to:

Request access

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

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

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

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

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

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

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.