Privacy Policy

Last updated: 12 January 2022

1.   Introduction   

This privacy policy provides you with details of how we collect and process your personal data through your use of our site and when you use our services.  

By providing us with your data, you agree to us that you are over 18 years of age.  

Paul Beare Limited is the data controller and we are responsible for your personal data hereon referred to as “we”, “us” or “our” in this privacy notice. 

We reserve the right to update this policy periodically.

Mr Paul Beare directly is in charge of privacy related matters for the company. If you have any questions about this privacy notice, please contact him direct using one of the contact details below.  

Our full contact details can be found here

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at  

2.  What data do we collect 

Personal data means any information capable of identifying an individual. It does not include anonymised data. 

We may process the following categories of personal data about you: 

  • Communication Data that includes any personal data contained in any of your communications with us, whether that be through the contact form on our website, through your calls with us, through email, text, social media messaging, social media posting or any other communication that you send us.
  • Client Data that includes data relating to any purchases of services such as your name, title, billing address, delivery address email address, phone number, contact details, job title, professional background, purchase details and your card details.
  • User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services.
  • Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system such as Google Analytics and Lead Forensics.
  • KYC Data that includes copies of your passport, national identity card, driving licence, utility bills, bank statements and results from background checks.

Sensitive Data and criminal convictions data   

We do not collect any Sensitive Data about you. Sensitive data refers to data that 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.

As part of our client onboarding procedures, we carry out background screening checks in relation to your business and associated individuals (such as directors, shareholders, ultimate beneficial owners etc.). The results of such background screening checks may result in us processing information about criminal convictions and offences relating to such individuals. 

3.  How we collect Personal Data 

We may collect data about you by you providing the data directly to us (for example by filling in forms on our site or by sending us emails).

We may also automatically collect certain data from you, including:

  • When you use our website, by using cookies and similar technologies. Please see our cookie policyfor more details about this. 
  • During some calls, we use  Dubber Notes, a third party service, to automatically record and transcribe calls on our behalf, unless you have asked us not to do so.

We may also receive data from third parties, including: 

  • analytics providers, such as Google based outside the EU;
  • advertising networks, such as Google Adwords based outside the EU;
  • search information providers, again such as Google based outside the EU;
  • client due diligence providers, including Veriphy and APLYiD;
  • providers of technical, payment and delivery services, such as data brokers or aggregators;
  • publicly availably sources, such as Companies House and the Electoral Register or the equivalents of these in your home country. 
  1. How we use your data?

As a data controller, we will only use your personal data if we have a legal basis for doing so. The table below sets out the purposes for which we use your personal data, as well as the categories of personal data required for that purpose and relevant legal bases which we rely on to carry out such processing.

Category of data

Purpose of processing

Lawful basis

Communication Data; Client Data

To provide you with our services, including communicating with you as required to perform our services.

Such processing is necessary in our legitimate interests, namely to carry out our business and provide our services.

Marketing our services, including sending you newsletters and inviting you to events that we consider may be of interest to you.

Such processing is necessary in our legitimate interests, namely to develop our business.

To respond to any queries you submit to us by email or via the website.

Such processing is necessary in our legitimate interests, namely to maintain proper customer relations.

To refer you to other professional services providers who can assist with your matters, if you have asked us to do so.

Such processing is in our and your legitimate interests, namely to source the services you require.

Client Data; KYC Data

Updating and maintaining client records

To comply with our legal and regulatory obligations.

We may also maintain client records where necessary in our legitimate interests, namely to keep proper accounts and records.

KYC Data; Client Data

To carry out background checks as part of our onboarding procedure.

Compliance with a legal obligation relating to anti-money laundering.

To the extent this results in us processing criminal convictions information, such processing is necessary for reasons of substantial public interest.

Communication Data

To record certain of our client calls using Dubber Notes.

Such processing is in our legitimate interests, namely to ensure we have an accurate record of your instructions.

User Data; Technical Data

To operate our website, including to ensure the security of our website, to maintain back- ups of our website/blog and/or databases and to enable publication and administration of our website, other online services and business.

Such processing is in our legitimate interests, namely to properly administer our website and our business.

To analyse your use of our website and other online services to ensure content is presented in the most effective way for you.


Client Data; User Data; Technical Data

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


5.  Personal Data Disclosure   

We may share your personal data with the parties set out below: 

  • Service providers, including those providing IT and system administration services and call recording and transcription services. 
  • Client due diligence providers, such as Veriphy and APLiD.
  • Professional advisers including lawyers, bankers, auditors and insurers and brokers.
  • Government bodies that require us to report processing activities. 
  • Third parties to whom we sell, transfer, or merge parts of our business or our assets.  

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions. 

6.  International Transfers 

Countries outside of the United Kingdom (UK) do not always offer the same levels of protection to your personal data as that provided in the UK, so UK law has prohibited transfers of personal data outside of the UK unless the transfer meets certain criteria. 

Some of our third parties service providers we use are based outside the UK, meaning their processing of your personal data will involve a transfer of your data outside the UK. 

Whenever we transfer your personal data out of the UK, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place: 

  • The transfer is to a country that the UK government has approved as providing an adequate level of protection for personal data by (which includes all member states of the European Economic Area, New Zealand and Canada); or 
  • Where we use certain service providers located in countries which are not recognised as having an adequate level of protection, we may enter Standard Contractual Clauses, approved by the European Commission and/or UK government, which oblige recipients of the data to take steps to protect it. 

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.  

For further information regarding the specific measures we take when transferring your personal information internationally, please contact us at or your usual Relationship Manager.

7.  Data Security   

We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential. 

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to. 

8.  Retention of Data   

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 any regulatory requirements.  

For tax and accounting purposes we are required to keep basic information about our clients (including Client, Communication and KYC Data) for seven years after they stop being clients. 

In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you. 

9.  Legal Rights of Personal Data   

Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent. 

You can see more about these rights at:  

If you wish to exercise any of the rights set out above, please email us at  

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 or refuse to comply with your request in these circumstances. 

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. 

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. 

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues ( We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you. 

For our Australia based clients: 

If you have any queries or complaints about our collection, use or storage of your personal information (including a complaint relating to any failure by us to comply with our obligations under the credit reporting provisions of the Privacy Act 1988 (Cth) or under the Credit Reporting Privacy Code), or if you wish to exercise any of your rights in relation to your personal information, please contact and address your email to The Privacy Officer. We will investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of your personal information. If you are dissatisfied with the handling of your complaint, you may contact the Office of the Australian Information Commissioner or Australian Financial Complaints Authority (ACFA): Office of the Australian Information Commissioner, GPO Box 5218, Sydney, NSW 2001. Telephone: 1300 363 992, Mail: GPO Box 5218, Sydney, NSW 2001, Fax: +61 2 9284 9666, Email:

  1. What about Third-Parties?  

This website 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 website, we encourage you to read the privacy notice of every website you visit.

  1. Cookies and tracking

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 this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy here