Privacy policy

Penningtons Manches Cooper LLP (‘we’ / ‘our’ / ‘us’) is a limited liability partnership registered in England and Wales (Registered No. OC311575) and is authorised and regulated by the Solicitors Regulation Authority. References to ‘partner’ include members and employees/consultants of equivalent standing within the LLP and its associated undertakings or businesses operating overseas.  A list of the members is open to inspection at its registered office, 125 Wood Street, London, EC2V 7AW.

We own and operate the following:

• Penntrust Limited (a private limited company registered in England and Wales (05710616) whose registered office is at 125 Wood Street, London, EC2V 7AW.
• Penningtons Insurance Limited (a private limited company registered in Guerney (1-26685) whose registered address is PO Box 33, Dorey Court, Admiral Park, St. Peter Port, Guerney, GY1 4AT.
• Bateson & Partners Law Firm (a Greek partnership trading under the name of Penningtons Manches Cooper Greece which is regulated by the Athens Bar Association under the number 80788) whose registered office is 4 Zalagou Street,153 43 Athens, Greece.
• Penningtons Manches Cooper (Singapore) LLP (a limited liability partnership registered in England and Wales (OC383589) whose registered office is Ibex House, 42 – 47 Minories, London EC3N 1HA, UK.
• Thomas Cooper LLP (a limited liability partnership registered in England and Wales (OC383641) whose registered office is Ibex House, 42 – 47 Minories, London EC3N 1HA, UK.

This privacy notice is issued on behalf of all the entities referred to in the paragraph above. Unless we inform you otherwise the relevant entity processing your data will be Penningtons Manches Cooper LLP and Penningtons Manches Cooper LLP is the data controller in respect of your personal information.

We collect personal information so that we can operate effectively and provide you with the best possible service. The information we collect depends on how you interact with our website and how you use our services. It also depends on the choices you make, for example the website functions you use and your privacy settings. You may choose not to provide certain information but if you do, and that information is necessary to provide a particular feature, then you may not be able to use that feature. We will only use your personal information where we have a lawful basis to do so.

The tables below summarises what information we collect about you, explains how we intend to use it and what our legal basis is for using it. Click on the links below to take you to the section which is relevant to you:

• Provision of legal and other services
• Response to enquiries and requests for information
• Organization of meetings, seminars and other hosted events
• Operation of our business
• Engagement of experts, advisers, and suppliers
• Marketing and business development
•  Use of our website

In the tables, the following types of information include:

• Identity information includes name, title, nationality, position, company or organization and user log-ins.
• Contact information includes postal addresses, email addresses and telephone numbers.
• Financial information includes bank account details, payment information, mortgage information, personal financial details and insurance information
• Employment information includes employment history, National Insurance number, salary and benefits details.
• Client Due Diligence Information includes name, address, date of birth, nationality, your image and all other details held within identification and address verification documents; records of political exposure, adverse media, sanction designations and all such information obtained by us for the purpose of meeting our Client Due Diligence obligations
• Special category information includes race or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, biometric data, health and medical records, sex life or sexual orientation.

We may, in providing our services and operating our businesses, share your personal information with other Penningtons Manches Cooper entities. We may also share your personal information with third parties where:

• you have consented to us sharing your personal information in this way;
• we are under a legal, professional or regulatory obligation to do so (such as to comply with money laundering requirements);
• it is necessary in order to apply or enforce our Terms of Business or where we have another legitimate interest in doing so that is not overridden by your interests and fundamental rights. For example, to protect our clients or to operate and maintain the security of our computer systems.

We use third party service providers to support us in the performance of the activities set out in the table above including:

• our professional advisors, professional indemnity insurers, bankers and auditors;
• third parties engaged in relation to client matters on which we are instructed such as barristers, foreign agents and lawyers (including those within the Multilaw global network of law firms), process servers, translators, transcribers and providers of data rooms and other technical solutions; suppliers of financial services including our bankers, credit card processors, debt collection, insurers, litigation funders, and credit reference agencies;
• we use a third party service provider to provide services that involve data processing including Williams Lea to whom we outsource our personal assistant, document production, facilities and reception requirements. We also use third party organisations to provide services such as telephony services and archiving;
• suppliers and consultants to whom we outsource IT services and technical solutions and which host our online job application system.

In the course of our business we may use artificial intelligence (AI) tools to enhance productivity. Generative AI tools may also be used, for example to summarise meetings. You can ask that generative AI is not used in any particular meeting that you attend. If you use your own AI tools to summarise meetings with us, you must not rely on any such summary as legal advice.

Further information on how client information may be shared and processed can be found in our Terms of Business. If you require further information regarding the identity of other third party service providers we use, please e-mail data@penningtonslaw.com or contact our Data Protection Officer at our Basingstoke office.

We may also share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or otherwise to comply with the law.

We require all our third party service providers to take appropriate and stringent security measures to protect your personal information in line with our policies. We do not allow our third party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes in accordance with our instructions.

In the course of providing our services and operating our business, it may be necessary for us to share personal information with our overseas offices, some of which are outside the UK and European Economic Area (EEA).

The level of protection in countries outside the UK and EEA may be less than that offered within the UK or EEA. To ensure that your personal information receives an adequate level of protection, we have put in place appropriate measures to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the EU and UK laws on data protection. Where our third party service providers process personal data outside the UK or EEA in the course of providing services to us, our contractual arrangements with these will include appropriate measures to meet UK or EU-approved data protection obligations, usually standard contractual clauses. If you require further information about these protective measures, please e-mail data@penningtonslaw.com or contact our Data Protection Officer at our Basingstoke office.

We will only retain your personal information for as long as is necessary to fulfil the purposes we collected it for or for as long as we have a lawful basis to retain it.

How long do we retain your personal data?
Your personal information will be retained in accordance with our data retention policy which categorises the information we hold and provides appropriate retention periods each category, based on the purpose for which the information is processed and taking into account legal and regulatory requirements, limitation periods for taking legal action, good practice and business requirements. For example, for legal reasons we may need to retain some of your personal information for 15 years (or 25 years where minors or disabilities are involved) after you engaged our services. In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. If you require further information regarding our data retention policy please e-mail data@penningtonslaw.com

Client due diligence information will be retained for five years from the conclusion of our business relationship with you, unless there is legitimate reason to retain it for a further five years.

If you become aware that your child or any child under your care has provided us with information without your consent please contact us at data@penningtonslaw.com.

All information that you provide to us is stored on secure servers. We have put in place appropriate measures to protect the security of your information.

The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of the information transmitted to our site and you acknowledge that any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access or inadvertent disclosure.

You are responsible for keeping confidential any passwords that you have to access our services (such as our extranets). Please do not share your password(s) with anyone else. If you lose control of your password you may lose control over your personal information. If your password has been compromised for any reason please let us know immediately by contacting us at: data@penningtonslaw.com.

We do not collect or store credit and debit card information. We limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. If you require further information regarding these measures please e-mail data@penningtonslaw.com.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

You have the right under data protection laws to access information held about you, subject to certain conditions, and to request its rectification or deletion.

You can see, review and update your marketing preferences via our website. Alternatively, or if you would like to access, update or amend any other information which we hold about you or would like us to stop using your personal information please contact data@penningtonslaw.com.

By law you have the right to:

• Request access to your personal information (commonly known as a “subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. This right is subject to a number of exemptions which allow information to be withheld in certain circumstances. For example, subject access rights are excluded where compliance would involve disclosing: information relating to another individual; data which consists of information which is subject to legal professional privilege; negotiations or confidential references.
• Request correction or erasure of your personal information (unless we have the legal right to retain it). You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information where we are relying on a legitimate interest (or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to check its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.
• Change your data processing preferences at any time. If you have changed your mind you can update your account settings by signing in via our website or by contacting us by email at data@penningtonslaw.com, in respect of marketing messages you can unsubscribe by using the “unsubscribe” link at the bottom of our marketing messages or by emailing data@penningtonslaw.com.

You should be aware that if you ask us to stop processing your personal information in a certain way or erase your personal information, and this type of processing or data is needed to facilitate your use of the website or to provide you with legal services you may not be able to use the website as you did before or we may not be able to continue advising you. This does not include your right to object to direct marketing, which can be exercised at any time without restriction.

If you want to exercise any of the above rights please contact us at / 01256 407100 / Matrix House, Basing View, Basingstoke, Hampshire, RG21 4DZ or by emailing us at data@penningtonslaw.com.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly excessive. Alternatively, we may refuse to comply with the request in such 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 the information (or to exercise any of your other rights). This is an appropriate security measure to ensure that personal information is not disclosed to a person who has no right to receive it.

RIGHT TO WITHDRAW CONSENT

In the limited circumstances where we are relying on your consent as the legal basis to process your personal information for a particular purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact data@penningtonslaw.com. Once we know that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

We would like to send you information about legal updates, client seminars and similar events which may be of interest to you (including, for example promotional materials and newsletters). We will do this if we have a lawful basis for doing so in compliance with relevant privacy law (see Marketing and business development above) or if you consented to us doing so (for example, when you registered via our website or instructed us). For a link to the subscription form we use when seeking such consent click here.

You have the right at any time to stop us from contacting you for marketing purposes or giving your information to other members of our group. If you no longer wish to be contacted for marketing purposes, you can unsubscribe by using the “unsubscribe” link at the bottom of our marketing messages or by emailing data@penningtonslaw.com. You can also update your marketing preferences.

We use and provide links to websites which are controlled by third parties and these include the following:

• Online recruitment portal
• Facebook where we have a social page
• Twitter, LinkedIn and Youtube where we have Penningtons Manches Cooper accounts and profiles

If you use or follow a link to any of these third party websites you should be aware that these websites have their own privacy policies and we cannot accept responsibility for their use of your information.

We keep our privacy policy under regular review and will post any updates on this webpage. This privacy policy was last updated in May 2023.

To learn more about what’s new see our website or contact our Data Protection Officer at our Basingstoke office.

In May 2018 we published a new privacy statement to improve usability and increase clarity and transparency.

In August 2019 we amended this policy to take into account the acquisition of Thomas Cooper LLP and its overseas offices.

In May 2020 we amended this policy to clarify how we process Client Due Diligence Information.

In May 2023 we updated the details of our Greek Partnership and the provisions on international transfers of personal data.

Penningtons Manches Cooper LLP (registered number OC311575) is the data controller in respect of your personal information. Penningtons Manches Cooper LLP’s registered office is at 125 Wood Street, London EC2V 7AW.

We have appointed a data protection officer to oversee compliance with this privacy policy. If you have any questions about this privacy policy, or how we handle your personal information, please contact our Data Protection Officer at / 01256 407100 / Matrix House, Basing View, Basingstoke, Hampshire, RG21 4DZ or by emailing data@penningtonslaw.com.

If for any reason you are not happy with the way that we have handled your personal information, please contact us at data@penningtonslaw.com or contact our Data Protection Officer at our Basingstoke office. If you are still not happy, you have the right to make a make a complaint to the Information Commissioner’s Office see: https://ico.org.uk/global/contact-us/.