Privacy and Cookies Policy

Welcome to Just Consultancies Limited privacy notice.

Just Consultancies Limited (“we”, “us” or “our”) 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 sites:https://www.justagroup.co.ukhttps://www.justaroundthecorner.co.uk [HU1] (each a “”site” and together “our sites”), (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

 

Navigating this page

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

Purposes for which we will use your personal data

-          Marketing

-          Promotional offers from us

-          Third-party marketing

-          Opting out

-          About Cookies

-          Change of purpose

5. Disclosures of your personal data

6. International transfers

7. Data Security

8. Data Retention

-          How long will you keep my personal data for?

9. Your legal rights

-          Marketing

-          Correction of information

-          Deletion of information

-          Object to processing

-          Restriction on processing

-          Access to information

-          Data Portability

10. Glossary

[HU2] 

 

 

 

 

1. Important Information and Who We Are

Purpose of this privacy notice

This privacy notice aims to give you information on how we collect and processes your personal data through your use of our sites, including any data you may provide through our sites when you sign up to our newsletter, register for an event, receive our services or register an account with us.

Our sites are 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

Just Consultancies Limited is the controller and responsible for your personal data (collectively referred to as "we", "us" or "our" in this privacy notice).

We have appointed a data privacy manager (DPM) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPM using the details set out below.

Contact details

Our full details are:

Full name of legal entity: Just Consultancies Limited

Name or title of DPM (Data Privacy Manager): Stephanie Dawson

Email address: admin@justagroup.co.uk

Postal address: Hume studio, The Rag Factory, 16-18 Heneage Street, London, E1 5LJ.

Telephone number: 0207 739 7620

Should you have any concerns, we would appreciate the chance to deal with them in the first instance. If you would like to speak to us in relation to any concerns you have, please contact us by email at admin@justagroup.co.ukor by telephone on 0207 739 7620

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).

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

This version was last updated on 16th January 2019 and can be obtained by contacting us.

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

Our sites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect 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 sites, 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 that you give us through our sites or by using our applications, purchasing our services or requesting referrals to our Brand and distribution partners, corresponding with us by phone, e-mail or otherwise, which we have grouped together as follows:

  • Identity Data includes first name, middle name, maiden name, last name, username or similar identifier.

  • Contact Data includes billing address, delivery address, email address and telephone numbers.

  • Financial Data includes bank account and payment card details.

  • Transaction Data includes details about payments to and from you and other details of products you have purchased from us.

  • 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 our sites.

  • Profile Data includes your appointment, referral details and arrangements, purchases or orders made by you. 

  • Usage Data includes information about how you use our sites, products and services.

  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

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 site 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.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

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). In this case, we may be unable to process an order for a product or we may have to cancel a product you have ordered 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, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email, through our sites, social media or otherwise. This includes personal data you provide when you;

  • purchase our services;

  • Request information and/or services from Northern Sole Supply Limited with whom we operate a referral partnership;

  • submit a comment on our sites;

  • interact with us on our social media;

  • submit an enquiry to us regarding our services and/or client products;

  • create an account on our sites;

  • subscribe to our newsletters;

  • register for and/or attend an event or showroom;

  • request marketing to be sent to you;

  • if you apply for a job with us; or

  • give us some feedback.

  • Automated technologies or interactions. As you interact with our sites, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see below for further details on cookies. We do not use other third parties to collect data about you;  

  • Third parties or publicly available sources. 

  • Technical Data fromanalytics providers such as Google based outside the EU.

  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside or outside the EU.

  • Identity and Contact Data from data brokers or aggregators.

  • Identity and Contact Data from publicly availably sources such as Companies House based inside the EU.

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:

  • where we need to perform the contract we are about to enter into or have entered into with you;

  • 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; and

  • to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling.

Generally, we do not rely on consent as a legal basis for processing your personal data. In event we do, please note that 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 (please see paragraph 10 (Glossary) for a definition of legitimate interest).

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 in the table below.

For the avoidance of doubt, you may fall into one or more of the below detailed categories (i.e. customer, job applicant or site user).

Profiling

Profiling is a form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to you, for example to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movement. 

Please note; we do not currently use profiling or take automated decisions about you.

Customers

For individual and business customers, we may collect and process your personal data as follows:

Purpose/Activity

 Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer

 (a) Identity

 (b) Contact

Performance of a contract with you (please see paragraph 10 (Glossary) for a definition of performance of a contract)

To process your order including:

(a) Manage payments, fees, refunds and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

c) To prevent and detect fraud against either you or Just Consultancies

d) Take payment and create refunds

To manage our relationship with you which will include:

(a)    provide our services

(b)    Notifying you about changes to our terms or privacy policy

(c)    Asking you to leave a review, feedback or take a survey

(d)    Dealing with an enquiry from you

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to provide our services, keep our customers updated, keep our records updated, to study how customers use our products/services and to develop customer relationships to help our business grow)

d) Help grow performance and consumer confidence by using reviews or our potential activities.

To administer and protect our business and our sites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) 

(a) Identity

(b) Contact

(c) Technical

(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 (please see paragraph 10 (Glossary) for a definition of comply with a legal or regulatory obligation)

To arrange meetings and appointments with our Brand clients and relationships.

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to provide our services, manage referrals and introductions, as well as meeting our customer expectations)

c) Help grow performance and consumer confidence by using reviews or our potential activities.

To make referrals to Northern Sole Supply Limited

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to provide and improve our services, and to meet our customer expectations)

(c) at your request or instruction (consent)

 

To register you for an event or a showroom visit

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(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, organise events and to develop customer relationships to help our business grow)

d) Help grow performance and consumer confidence by using reviews or our potential activities.

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

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

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)

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

(a) Technical

(b) Usage

a) Necessary for our legitimate interests (to define types of customers for our products and services, to keep our sites updated and relevant, to develop our business and to inform our marketing strategy)

b) To find out what you, and other customers, like

To make suggestions and recommendations to you about products or services that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(a) Necessary for our legitimate interests (to develop our products/services and grow our business)

(b) On the basis of your request for this information or by joining our emailing database (consent)

To provide customer service, support and manage returns

(a) Identity

(b) Contact

(c) Transaction

d) Profile

a) Send order updates and delivery alerts

b) Investigate any order queries

To train our staff

(a) Identity

(b) Contact

a)When you contact us you will receive the best service possible

 

 

 

 

 

Job applicants

For job applicants, we may collect and process your personal data as follows:

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

If you apply for a job with us

(a) Identity

(b) Contact

We will obtain your consent to process this data.

Site users

For site users, we may collect and process your personal data as follows:

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To administer and protect our business (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Technical Data

(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

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

We use the types of personal data outlined below to improve user experience and identify any on-site issues.

First name, last name, email address, user agent (browser), IP address, events, viewed products, order events, cart content, liked products, disliked products, external campaign attributions, clicked recommendations, order information, phone number, zip code, country code, sent emails.

(a) Usage Data

(b) Marketing Communications

(c) Technical

d) Identity

e) Contact

Necessary for our legitimate interests (to study how individuals use our sites, to develop it, to grow our business and to inform our marketing strategy)

To use data analytics to improve our sites, services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our services, to keep our sites updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about Brands or services that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

Necessary for our legitimate interests (to develop our products/services and grow our business)

To provide you with the best customer service by using what you say to us over the phone, instant chat, via emails or social media

a)Contact

b) Identity

Necessary in order to make improvements and solve any issues

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional Offers From Us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services, products and offers may be relevant for you (we call this marketing). If you have requested information from us or purchased services from us previously, we will rely on our legitimate interests to market to you in relation to similar services and information on our offers and news.

You will receive marketing communications from us if you requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing.

Business to Business Communications/Marketing

We do not collect personal data for our business customers, beyond business emails and a telephone number of you or your employees, as well as recording a history of contact.

We rely on legitimate interest to store and use this information, because we need to communicate with you in order to market to you, provide our services and perform our functions, as well as responding to requests for information and placing orders.  We believe it is within your reasonable expectations that we will process this minimal contract information and this will not impact the legal rights and freedoms of your and/or your employees. We also provide the opportunity for you to opt out of any marketing communications and you may exercise your data rights (set out below)

Third-Party Marketing

We will not share your information with any third parties for marketing purposes.

Opting Out

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

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 purchase, warranty registration, product experience or other transactions.

 

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our sites may become inaccessible or not function properly.

About Cookies

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

Cookies can be used by web servers to identity and track users as they navigate different pages on a website and identify users returning to a website.

Our Cookies

 

Please Note: We do not currently use cookies and will update this Notice in the event this changes.

Blocking cookies:

Most browsers allow you to refuse to accept cookies; for example:

  • in Internet Explorer (version 10) you can block cookies using the cookie handling override settings available by clicking "Tools", "Internet Options", "Privacy" and then "Advanced";

  • in Firefox (version 24) you can block all cookies by clicking "Tools", "Options", "Privacy", selecting "Use custom settings for history" from the drop-down menu, and unticking "Accept cookies from sites"; and

  • in Chrome (version 29), you can block all cookies by accessing the "Customise and control" menu, and clicking "Settings", "Show advanced settings" and "Content settings", and then selecting "Block sites from setting any data" under the "Cookies" heading.

Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all the features on our sites.

Deleting cookies:

You can delete cookies already stored on your computer; for example:

  • in Internet Explorer (version 10), you must manually delete cookie files (you can find instructions for doing so at http://support.microsoft.com/kb/278835);

  • in Firefox (version 24), you can delete cookies by clicking "Tools", "Options" and "Privacy", then selecting "Use custom settings for history", clicking "Show Cookies", and then clicking "Remove All Cookies"; and

  • in Chrome (version 29), you can delete all cookies by accessing the "Customise and control" menu, and clicking "Settings", "Show advanced settings" and "Clear browsing data", and then selecting "Delete cookies and other site and plug-in data" before clicking "Clear browsing data".

Deleting cookies will have a negative impact on the usability of many websites.

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 may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

  • Internal third parties such as our employees or officers.

  • Third party fashion agencies and Brands, so that you may receive product and sales information, and make appointments.

  • With Northern Sole Supply Limited when we make referrals for supply and distribution services, as well as in relation to Brands for which they hold licences.

  • External third parties including specialist IT support, data analytics and technology providers, suppliers and sub-contractors for the performance of our sites, our applications and any contract we enter into with them or you, including; Mailchimp, independent IT contractors (Titchener Brothers).

  • Professional advisers including lawyers, bankers, marketing agencies, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

  • Credit reference agencies, law enforcement and fraud prevention agencies to help us prevent and deal with fraud;

  • HM Revenue & Customs, regulators and other authorities who require reporting or processing activities in certain circumstances.

  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

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.

6. International Transfers

We do not currently transfer data outside the European Economic Area (EEA).

However, our employees and officers will be able to access emails and our IT systems whilst outside the EEA, in the course of their employment.  This does mean that your personal data is accessible whilst outside the EU, however, we have assessed the risk and ensured adequate safeguards are in place. For further details please contact us.

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.

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.

For clients:

Personal data

Your personal client (including the relevant employee contact at companies) data will be stored for no longer than 10 years from when you last engaged us, or 2 weeks following a request for this information to be deleted, providing we have no other legal basis or requirement to retain it.

Record of sale data

Data relating to purchase(s) will be stored for no longer than 10 years from when you last purchased a service from us, or 2 weeks following a request for this information to be deleted, providing we have no other legal basis or requirement to retain it.

Email & Marketing data

If you have requested product or service information then we will keep your personal data for 2 years from the last time we have communicated with you or provided marketing information. However, we will regularly contact you to ensure you are aware of our processing of your data, your data rights and options to stop communications. If you do not want to continue to receive emails, we will no longer send you updates and will automatically delete your personal data at that time, providing we have no other legal basis or requirement to retain it.

For site users, we will usually keep data for 2 years.

For job applicants, we will usually keep data for 12 months.

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.

Marketing

We will inform you (before collecting your data) if we intend to use your data for marketing purposes. We will only use your data for this if you have agreed in advance. 

 

Correction Of Information

If you notify us that the personal data we hold is complete or inaccurate we will correct or complete the information as soon as possible.

 

Deletion Of Information

You have the right to request that your personal data be deleted; including if we no longer need it for the purpose we collected it, or you withdraw your consent.

Following such a request we will erase your personal data without undue delay unless continued retention is necessary and permitted by law. If we made the personal data public, we will take reasonable steps to inform other data controllers processing about your erasure request.

Object To Processing

You have the right to object to us processing 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.

Restriction On Processing

You have the right to request that we suspend processing your personal data, but hold it for you, in the event the personal data we hold is inaccurate, the processing is unlawful or we no longer need the personal data. Once the processing is restricted, we will only continue to process your personal data if you consent or we have another legal basis for doing so.

Access To Information

You have the right to access information held about you and any access request will usually be free of charge. We will endeavour to provide information in a format requested, but we may charge you a reasonable fee for additional copies.

Data Portability

You have the right to receive a copy of your personal data which you gave to us. The copy will be provided in a commonly used and machine-readable format.  You can also have it transmitted directly from us to another data controller, where technically possible.

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.

Withdraw consent at any time

You may withdraw your 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.

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.