VSQ respects your privacy and is committed to protecting your personal data. This policy explains how we collect and use your personal data when you visit this website, make an enquiry, subscribe to our updates or engage us, and it sets out your rights and how the law protects you. Please read it alongside our cookie policy and our website terms.
1. Who we are and our regulatory status
This website is operated by VSQ Advisory & Capital Ltd, a company registered in England and Wales under company number 16429679, with its registered office at 85 Great Portland Street, London, England, W1W 7LT ("VSQ", "we", "us" or "our"). We trade as VSQ Legal. VSQ Advisory & Capital Ltd is the controller responsible for your personal data, and is registered with the Information Commissioner's Office under registration reference ZB995847.
VSQ Advisory & Capital Ltd is not a law firm and is not authorised or regulated by the Solicitors Regulation Authority or by any other approved legal services regulator. Some individuals who work with us are separately authorised to provide legal services in their personal capacity by their own professional regulator. Where any such individual provides regulated services, they do so in that personal capacity and subject to the rules of their own regulator, and not on behalf of VSQ Advisory & Capital Ltd.
We have not appointed a data protection officer. If you have any questions about this policy, or wish to exercise any of your rights, please contact us at info@vsqlegal.com (see also section 10). This website is not intended for children and we do not knowingly collect data relating to children.
2. The personal data we collect about you
Personal data means any information from which a living individual can be identified. We may collect, use, store and transfer the following kinds of personal data:
- Identity Data - your name, title and the organisation you represent.
- Contact Data - your email address, telephone number and postal address.
- Enquiry and Matter Data - information you give us about your matter or enquiry, for example through our contact or booking forms (such as the type of matter, stage, deal size and what you need), and information you share with us in the course of an engagement.
- Financial and Transaction Data - where you become a client, billing details and records of payments to and from you.
- Technical Data - your internet protocol (IP) address, browser type and version, time zone and location, operating system and device information. Most Technical Data is collected only where you accept analytics cookies.
- Usage Data - information about how you use our website.
- Marketing and Communications Data - your preferences in receiving updates from us.
We also collect aggregated data, such as statistical data, which does not identify you. We do not seek to collect any special categories of personal data (such as data about your health, race, religion or political opinions) or data about criminal convictions. If you volunteer such information in the context of a matter, we will handle it only where the law allows and, where required, with your explicit consent.
Where the law or a proposed engagement requires us to collect personal data and you do not provide it when requested, we may not be able to act for you.
3. How your personal data is collected
- Directly from you - when you complete our contact, booking or newsletter forms, correspond with us by email, telephone or video call, or provide information in the course of an engagement.
- Automatically - as you use our website, we collect Technical and Usage Data through cookies and similar technologies. Analytics are set only with your consent. See our cookie policy.
- From third parties and public sources - for example, analytics providers such as Google; and, where we carry out client due diligence, identity and background information from public sources such as Companies House and the electoral register.
4. How we use your personal data
The law requires us to have a lawful basis for using your personal data. We rely on one or more of the following: performance of a contract with you; our legitimate interests (where they are not overridden by your rights); compliance with a legal obligation; and, where relevant, your consent (for example, for our newsletter and for analytics cookies). We use your personal data to:
- respond to your enquiry, arrange and hold introductory calls, and provide information about our services;
- carry out client onboarding checks, including conflicts, identity and, where applicable, anti-money-laundering and sanctions checks;
- provide our services to you, manage the engagement and handle billing and payments;
- manage our relationship with you, including notifying you of changes to our terms or this policy;
- send you our newsletter and updates where you have asked to receive them (you can opt out at any time);
- operate, secure, maintain and improve our website, including analytics where you have consented; and
- comply with our legal and regulatory obligations and establish, exercise or defend legal claims.
Marketing
You will only receive our newsletter and marketing updates if you have asked for them. You can unsubscribe at any time using the link in any such message, or by contacting us at info@vsqlegal.com. We will always get your express consent before sharing your personal data with any third party for their own marketing. Opting out of marketing does not stop service-related messages that are necessary for an engagement.
5. Disclosures of your personal data
We may share your personal data with:
- Service providers who process data on our behalf, including our website host, our email delivery and mailing-list provider, our scheduling provider and our analytics provider (see section 6);
- professional advisers and, where you become a client, third parties reasonably required to deliver your matter;
- regulators, courts and law-enforcement or public authorities where we are required or permitted by law to do so; and
- a buyer or successor if we reorganise, sell or transfer parts of our business.
We require all third parties to respect the security of your personal data, to treat it in accordance with the law, and to use it only for the purposes we specify and on our instructions.
6. International transfers
Some of our service providers are based outside the United Kingdom, including in the United States (for example, our website hosting, analytics, scheduling and email providers). Where we transfer your personal data outside the UK to a country that is not covered by UK "adequacy" regulations, we ensure a similar degree of protection by relying on an appropriate safeguard, such as the UK International Data Transfer Agreement (or the UK Addendum to the European Commission's standard contractual clauses). You can ask us for details of the safeguards in place by contacting us at info@vsqlegal.com.
7. Data security
We have put in place appropriate technical and organisational measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We limit access to your personal data to those who have a business need to know, and they are subject to a duty of confidentiality. We have procedures to deal with any suspected personal-data breach and will notify you and any applicable regulator where we are legally required to do so.
8. Data retention
We keep your personal data only for as long as necessary to fulfil the purposes we collected it for, including to satisfy any legal, regulatory, tax, accounting or reporting requirements, and to establish, exercise or defend legal claims. Enquiry data that does not lead to an engagement is kept for a shorter period than client-matter records, which we retain for six years after the end of our engagement. Where appropriate, we anonymise your data so it can no longer be associated with you, in which case we may use it indefinitely.
9. Your legal rights
Under UK data protection law you have the right to:
- request access to your personal data;
- request correction of inaccurate or incomplete data;
- request erasure of your data in certain circumstances;
- object to processing that we base on our legitimate interests, and object at any time to direct marketing;
- request restriction of processing in certain circumstances;
- request transfer of your data to you or a third party in a structured, machine-readable format; and
- withdraw consent at any time where we rely on consent.
You will not usually have to pay a fee. We may need to verify your identity before responding. We aim to respond to all valid requests within one month, though it may occasionally take longer if the request is complex. To exercise any of these rights, contact us at info@vsqlegal.com.
10. Contact details
If you have any questions about this policy or wish to exercise your rights, contact us at info@vsqlegal.com or by post at VSQ Advisory & Capital Ltd, 85 Great Portland Street, London, England, W1W 7LT.
11. Complaints
You have the right to complain at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection, at ico.org.uk. We would, however, welcome the chance to address your concerns first, so please contact us before you approach the ICO.
12. Changes to this policy
We keep this policy under regular review and may update it from time to time. Any changes will be posted on this page with a revised date. Please keep us informed if your personal data changes during your relationship with us.
13. Third-party links
This website may contain links to third-party websites and services. We do not control those sites and are not responsible for their privacy practices. When you leave our website, we encourage you to read the privacy policy of every site you visit.
