Website Privacy Notice

Contents

1.0 Introduction

2.0 Why we Collect your personal information

3.0 Lawful Basis Of Processing Information

4.0 What Information we collect and where from

4.1 Special Category Data

4.2 Third Party Collection of Personal Data

5.0 How Long we Keep Information For

6.0 Security of personal information

7.0 Your individual rights

8.0 Consent

9.0 Failure To Provide Personal Information

10.0 Cookies

11.0 Automated Decision Making

12.0 Transfers To Third Parties

13.0 Transfers Outside Of The EEA

14.0 Right to complaint

15.0 Additional information

16.0 Policy Review and Amendments

1.0 Introduction

We, Altima, take the protection of your personal data very seriously and strictly adhere to the rules laid out by the General Data Protection Regulation (UK GDPR), Data Protection Act of 2018 and Data Use and Access Act of 2025. This privacy notice gives you information on how we collect and process your personal data through your use of this site and any data you may provide if you contact us regarding our products and services. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the contact information in section 15 of this privacy notice.

2.0 Why we collect your personal information 

We collect your personal data for one of the following purposes:To manage communications between you and usWhere we need to perform the contract we have entered into with youTo provide you with information you have requested or which we may feel may be of interest to you To ensure the safe operation of our website and to monitor the performance of our websiteFor marketing and advertising purposes

3.0 Lawful Basis Of Processing Information

We only collect and use personal information about you when the law allows us to. Most commonly, we use it where: 

• The data subject (you) has given consent to the processing activity taking place.
• If the processing is necessary for the performance of a contract 
• If the processing is necessary for compliance with a legal obligation to which the controller is subject
• If the processing is necessary for the purpose of the legitimate interest pursed by us or our partners.
• If the processing is necessary for the purpose of recognised legitimate interest
  

Where legitimate interest is identified as a lawful basis, we will undertake a legitimate interest assessment which is a three-part test covering:

• The purpose test – to identify the legitimate interest
• Necessity test – to consider if the processing is necessary for the purpose identified
• Balancing test – considering the individual’s interests, rights or freedoms and whether these override the legitimate interests identified.

However, where processing is based on recognised legitimate interest, we would not conduct a balancing exercise of legitimate interest assessment.

4.0 What Information we collect and where from

We collect personal information from you, for example, if you register to our website, request product information, call us or use any of our services. The categories of personal information that we may collect, store and use about you include:

• First Name and Last Name 
• Company Name 
• Email Address
• Job title 
• Description of what you want.
• Location details

4.1 Special Category Data

We do not collect any special category data from you

4.2 Third Party Collection of Personal Data

We may also collect your data through Third Parties such as LinkedIn, Hublead, and Pitchbook. We use HubSpot as our customer relationship management (CRM) and marketing platform to process personal data collected through this website, including data submitted via enquiry and contact forms, and website usage data used for marketing communications.

5.0 How Long we Keep Information For

We pride ourselves on ensuring that your personal data is only retained for the period that we need it for, or in accordance with laws, regulations and professional obligations that we are subject to. All personal information collect has a defined retention period, which is in-line with our retention policy. If you would like to find out how long your information is being retained, please see "additional information", section 15 of this policy.

6.0 Security of personal information

We take the responsibility for protecting your privacy very seriously and we will ensure your data is secured in accordance with our obligations under the Data Protection laws. We have in place technical and organisational measures to ensure personal information is secured and to prevent your personal data from being accessed in an unauthorised way, altered or disclosed.  We have in place a robust access control policy which limits access to your personal data to those employees, contractors and other third parties who only have a business need to know. The processing of your personal data will only take place subject to our instruction.

We have policies and procedures to handle any potential data security breaches and data subjects, third parties and any applicable regulators will be notified where we are legally required to do so.

We have ensured that all employees have had information security and data protection training. If you would like more details of the security we have in place, please see "additional information", section 15 of this policy.

7.0 Your individual rights

In this Section, we have summarised the rights that you have under General Data Protection Regulation. Some of the rights are complex, and not all the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

Your principal rights under General Data Protection Regulation are:

• Right to Object
• Right of Access
• Right to be informed
• Right to Rectification
• Right to Erasure
• Right to Restrict Processing
• Right to Data Portability

The right to object

You can exercise this right if:

• Processing relies on legitimate interest
• Processing is for scientific or historical research
• Processing includes automated decision making and profiling
• Processing is for direct marketing purposes
  
  

• The right of access
  
  • You or any third party acting on your behalf with your authority may request a copy of the personal data we hold about you without charge. 
  • We will ask to verify your identity or request evidence from the third party that they are acting on your behalf before releasing any personal data we hold about you.
    
    
• The right to be informed
  
  • We are required to provide clear and transparent information to you about how we process your personal data. This privacy notice addresses this right.
    
    
• The right of rectification
  
  • If you believe the personal data we hold about you is incorrect or incomplete you have the right to correct this and you may exercise this right along with the right to restrict processing until these corrections are made.
    
    
• The right to erasure
  
  • If there is no legal basis or legitimate reason for processing your personal data, you may request that we erase it.  

• The right to restrict processing
  
  • You may ask us to restrict the processing of your personal data. This means we will still hold it but not process it. This is a conditional right which may only be exercised when:
  • Processing is unlawful
  • We no longer need the personal data, but it is required for a legal process
  • You have exercised your right to object to processing and require processing to be halted while a decision on the request to object is made. 
  • If you are exercising your right to rectification
    
• The right to data portability
  
  • You can request that your personal data is transferred to another controller or processor in a machine-readable format if:
  • Processing is based on consent
  • Processing is by automated means (i.e. not paper based)
  • Processing is necessary for the fulfilment of a contractual obligation

If you have any question about these rights, please see "additional information", section 15 of this policy.

8.0 Consent

Where you have given consent for processing, or explicit consent in relation to the processing of special category data, you have the right to withdraw this consent at any time, but this will not affect the lawfulness of processing based on consent before its withdrawal.

9.0 Failure To Provide Personal Information

Where we need to collect personal data by law or in order to process your instructions or perform a contract we have with you and you fail to provide that data when requested, we may not be able to carry out your instructions or perform the contract we have or are trying to enter into with you. In this case, we may have to cancel our engagement or contract you have with us, but we will notify you if this is the case at the time.

10.0 Cookies

Our website uses cookies. Please see our cookies policy for full details of the cookies used.

11.0 Automated Decision Making

Your personal data is not used in any automated decision making (a decision made solely by automated means without any human involvement) or profiling (automated processing of personal data to evaluate certain conditions about an individual).

12.0 Transfers To Third Parties

Altima may disclose your personal data, listed in section 4, to some third parties to help us deliver our services/products. All third parties are contractually bound to protect the personal data we provide to them. These include:

• HubSpot — our CRM and marketing automation platform, used to manage enquiries and marketing communications
• Google Analytics — web analytics provider, used to understand website usage and improve our services
• Cloudflare — security and performance provider (see our cookies policy for further detail)
• Business partners, suppliers, and contractors for the performance of any contract we enter into with them or you
• Professional advisors, e.g. lawyers, auditors
• Marketing services providers

13.0 Transfers Outside Of The EEA

In this section, we provide information about the circumstances in which your personal data may be transferred and stored in countries outside the European Economic Area (EEA).

We may share personal information to third parties outside of the European Economic Area (EEA). Any personal information transferred will only be processed on our instruction and we ensure that information security at the highest standard would be used to protect any personal information as required by the Data Protection laws. 

Where personal data is transferred outside of the EEA/UK to a country without an adequacy decision, we will ensure appropriate safeguards are in place prior to the transfer. These could include:

• EU Standard Contractual Clauses + UK Addendum
• International Data Transfer Agreement
• Binding Corporate Rules
• An exception as defined in Article 49 of the EU GDPR

For more information about transfers and safeguarding measures, please contact us using the information in section 15.

14.0 Right to complaint 

We take any complaints about our collection and use of personal information very seriously.

If you think that our collection or use of personal information is unfair, misleading, or inappropriate, or have any other concern about our data processing, please raise this with us in the first instance

To make a complaint, please contact us via email on dpo@wearealtima.co.uk.

Alternatively, you can contact us:

By Post: Altima, MYO, 123 Victoria Street, London, SW1E 6DE

By Phone: +44 (0) 20 3745 3780

Alternatively, you can make a complaint to the Information Commissioner’s Office:

By Post:

Information Commissioners Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

By Website: Click Here

By Email: Click Here

By Phone: 0303 123 1113 

15.0 Additional information

Your trust is important to us. That is why we are always available to talk with you at any time and answer any questions concerning how your data is processed. If you have any questions that could not be answered by this privacy policy or if you wish to receive more in-depth information about any topic within it, please contact our DPO and Compliance Team via email on dpo@wearealtima.co.uk.

16.0 Policy Review and Amendments

We keep this Policy under regular review. This Policy was last updated on 10/05/26

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

Lawton Gallagher Limited (trading as Altima) is registered in England, Company Number 04115357). Our registered address is at 123 Victoria Street, London, SW1E 6DE.

Altima is committed to being transparent about how it collects and uses the personal data of all individuals that it comes into contact with in the course of its business, and to meeting its data protection obligations. This policy sets out Altima's commitment to data protection, and individual rights and obligations in relation to personal data.

This policy applies to the personal data of potential candidates and candidates, referees, client contacts and other individuals that it comes into contact with in the search process, referred to below as ‘search-related personal data’.

Altima has appointed Jack Brownsword, Finance and Operations Manager, as the person with responsibility for data protection compliance within the organisation. Jack can be contacted at jack@wearealtima.com or on 02037453780. Questions about this policy, or requests for further information, should be directed to Jack.

Definitions

"Personal data" is any information that relates to an individual who can be identified from that information. Processing is any use that is made of data, including collecting, storing, amending, disclosing or destroying it.

"Special categories of personal data" means information about an individual's racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation and biometric data.

"Criminal records data" means information about an individual's criminal convictions and offences, and information relating to criminal allegations and proceedings.

Data protection principles

Altima processes search-related personal data in accordance with the following data protection principles:

• Altima processes personal data lawfully, fairly and in a transparent manner.
• Altima collects personal data only for specified, explicit and legitimate purposes.
• Altima processes personal data only where it is adequate, relevant and limited to what is necessary for the purposes of processing.
• Altima keeps accurate personal data and takes all reasonable steps to ensure that inaccurate personal data is rectified or deleted without delay.
• Altima keeps personal data only for the period necessary for processing.
• Altima adopts appropriate measures to make sure that personal data is secure, and protected against unauthorised or unlawful processing, and accidental loss, destruction or damage.

Altima tells individuals the reasons for processing their personal data, how it uses such data and the legal basis for processing in its privacy notices. It will not process personal data of individuals for other reasons.

Where Altima processes special categories of personal data or criminal records data to perform obligations or to exercise rights in employment law, this is done in accordance with a policy on special categories of data and criminal records data.

Altima will update search-related personal data promptly if an individual advises that his/her information has changed or is inaccurate.

Personal data gathered during the search process is held securely and confidentially in hard copy or electronic format, or both, and on our case management and other IT systems (including email). The periods for which Altima holds search-related personal data are contained in its privacy notices to individuals.

Altima keeps a record of its processing activities in respect of search-related personal data in accordance with the requirements of the General Data Protection Regulation (GDPR).

Individual rights

As a data subject, individuals have a number of rights in relation to their personal data.

Subject access requests

Individuals have the right to make a subject access request. If an individual makes a subject access request, Altima will tell him/her:

• whether or not his/her data is processed and if so why, the categories of personal data concerned and the source of the data if it is not collected from the individual;
• to whom his/her data is or may be disclosed, including to recipients located outside the European Economic Area (EEA) and the safeguards that apply to such transfers;
• for how long his/her personal data is stored (or how that period is decided);
• his/her rights to rectification or erasure of data, or to restrict or object to processing;
• his/her right to complain to the Information Commissioner if he/she thinks the organisation has failed to comply with his/her data protection rights; and
• whether or not the organisation carries out automated decision-making and the logic involved in any such decision-making.

Altima will also provide the individual with a copy of the personal data undergoing processing upon request. This will normally be in electronic form if the individual has made a request electronically, unless he/she agrees otherwise.

To make a subject access request, the individual should send the request to Jack Brownsword at jack@wearealtima.com. In some cases, Altima may need to ask for proof of identification before the request can be processed. Altima will inform the individual if it needs to verify his/her identity and the documents it requires.

Altima will normally respond to a request within a period of one month from the date it is received. In some cases, such as where Altima processes large amounts of the individual's data, it may respond within three months of the date the request is received. Altima will write to the individual within one month of receiving the original request to tell him/her if this is the case.

If a subject access request is manifestly unfounded or excessive, Altima is not obliged to comply with it. Alternatively, Altima can agree to respond but will charge a fee, which will be based on the administrative cost of responding to the request. A subject access request is likely to be manifestly unfounded or excessive where it repeats a request to which Altima has already responded. If an individual submits a request that is unfounded or excessive, Altima will notify him/her that this is the case and whether or not it will respond to it.

Other rights

Individuals have a number of other rights in relation to their personal data. They can require Altima to:

• rectify inaccurate data;
• stop processing or erase data that is no longer necessary for the purposes of processing;
• stop processing or erase data if the individual's interests override Altima’s legitimate grounds for processing data (where Altima relies on its legitimate interests as a reason for processing data);
• stop processing or erase data if processing is unlawful; and
• stop processing data for a period if data is inaccurate or if there is a dispute about whether or not the individual's interests override Altima’s legitimate grounds for processing data.

To ask Altima to take any of these steps, the individual should send the request to Jack Brownsword at jack@wearealtima.com.

Data security

Altima takes the security of search-related personal data seriously. Altima has internal policies and controls in place to protect personal data against loss, accidental destruction, misuse or disclosure, and to ensure that data is not accessed, except by employees in the proper performance of their duties.

Where Altima engages third parties to process personal data on its behalf, such parties do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.

Impact assessments

Some of the processing that Altima carries out may result in risks to privacy. Where processing would result in a high risk to individual's rights and freedoms, Altima will carry out a data protection impact assessment to determine the necessity and proportionality of processing. This will include considering the purposes for which the activity is carried out, the risks for individuals and the measures that can be put in place to mitigate those risks.

Data breaches

If Altima discovers that there has been a breach of search-related personal data that poses a risk to the rights and freedoms of individuals, it will report it to the Information Commissioner within 72 hours of discovery. Altima will record all data breaches regardless of their effect.

If the breach is likely to result in a high risk to the rights and freedoms of individuals, it will tell affected individuals that there has been a breach and provide them with information about its likely consequences and the mitigation measures it has taken.

International data transfers

Altima will only transfer data to countries outside the European Economic Area (EEA) for the purposes of processing it on cloud based IT and case management systems. Data is transferred outside the EEA in accordance with the conditions set out in the GDPR and only to countries that have been certified by the European Commission as having an adequate level of data protection in place.

Individual responsibilities

Individuals are responsible for helping Altima keep their personal data up to date, particularly as individuals will be the source of much of the personal data that Altima holds.

Altima staff may have access to the personal data of other individuals, including candidates, clients and referees, in the course of their employment, contract, volunteer period, internship or apprenticeship. Where this is the case, Altima relies on individuals to help meet its data protection obligations to those other individuals.

Individuals who have access to personal data are required:

• to access only data that they have authority to access and only for authorised purposes in accordance with a legitimate business requirement;
• not to disclose data except to individuals (whether inside or outside Altima) who have appropriate authorisation;
• to keep data secure (for example by complying with rules on access to premises, computer access, including password protection, and secure file storage and destruction);
• not to remove personal data, or devices containing or that can be used to access personal data, from Altima’s premises without adopting appropriate security measures (such as encryption or password protection) to secure the data and the device; and
• not to store personal data on local drives or on personal devices that are used for work purposes.

Failing to observe these requirements may amount to a disciplinary offence, which will be dealt with under Altima's disciplinary procedure. Significant or deliberate breaches of this policy, such as accessing candidate or client data without authorisation or a legitimate reason to do so, may constitute gross misconduct and could lead to dismissal without notice.

Training

Altima will provide training to all staff about their data protection responsibilities at regular intervals.

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