Privacy notice

Last updated 2 August 2019

This privacy notice applies between you, the User of (“this Website”) and Richard Barfield Advisory Services Limited (“Brexitfactbase”), the owner and provider of this Website.

Brexitfactbase take the privacy of your information very seriously. This privacy notice applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website.

Please read this privacy notice carefully.

Definitions and interpretation

  1. In this privacy notice, the following definitions are used:
Data collectively all personally identifiable information that you submit to Brexitfactbase via the Website or which we otherwise collect. This definition incorporates, where applicable, the definitions provided in the Data Protection Act 1998 and from 25 May 2018 the General Data Protection Regulation;
Cookies a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies);
Richard Barfield Advisory Services Limited,or us Brexitfactbase, a company incorporated in England and Wales with registered number 09993013 whose registered office is at 206 Upper Richmond Road West, London SW14 8AH.
UK and EU Cookie Law the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011 and any new applicable law relating to cookies;
User or you any third party that accesses the Website and is not either (i) employed by Brexitfactbase and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Brexitfactbase and accessing the Website in connection with the provision of such services; and
Website the website that you are currently using,, and any sub-domains of this site unless expressly excluded by their own terms and conditions.
  1. In this privacy notice, unless the context requires a different interpretation:

a. the singular includes the plural and vice versa;

b. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy notice;

c. a reference to a person includes firms, companies, government entities, trusts and partnerships;

d. “including” is understood to mean “including without limitation”;

e. reference to any statutory provision includes any modification or amendment of it;

f. the headings and sub-headings do not form part of this privacy notice.

Scope of this privacy notice

  1. This privacy notice applies only to the actions of Brexitfactbase and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.

Legal Basis

  1. Data we hold about you will be processed either because:

a. the processing is necessary in pursuit of a “legitimate interest”, a legitimate interest in this context means a valid interest we have or a third party has in processing your personal data which is not overridden by your interests in data privacy and security; or

b. the processing is necessary in order for us to comply with our obligations under a contract between you and us, specifically for the provision our Services.

Types of Data which we collect

  1. We may collect the following Data, which includes personal Data, from you:

a. Name and Contact Information such as email addresses (“Contact Information”);

b. Information required to register with and log-in to the Website (“Registration Information”)

c. payment information we may use to collect payment (if applicable to you, as an individual client) (“Payment Information”);

d. a record of any correspondence or communication between you and us and any information we may require from you when you report a problem or submit a complaint (“Communication Information”);

e.technical information about how you have used or interacted with the Website including your IP address and web browser information (“Technical Information”)

  1. You do not have to supply any Data to us but our services may not be available in practice without providing Data to us. You may withdraw our authority to process your Data (or request that we restrict our processing) at any time (but our services may not be available or may need to be withdrawn should you do so).

How we use your Data

  1. For purposes of the Data Protection Act 1998 and the General Data Protection Regulation, Brexitfactbase is the “data controller”.
  2. Please see the table below, which sets out the manner in which we will process the different types of personal data we hold:
Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
When you or your employer register with the Website

Contact Information

Registration  Information

Performance of a contract with you

Necessary for our legitimate interests (to establish necessary information about you in order to provide our services)

When we communicate with you about your use of our services

Contact Information

Registration Information

Performance of a contract with you

Necessary for our legitimate interests (for running our business and to provide you with our services)

When we collect payment from you

Contact Information

Registration Information

Payment Information

Performance of a contract with you

Necessary for our legitimate interests (for running our business and to provide you with our services)

To manage our relationship with you

Contact Information

Registration Information

Communication Information

Technical Information

Performance of a contract with you

Necessary to comply with a legal obligation

Necessary for our legitimate interests

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

Contact Information

Registration Information

Payment Information

Technical Information

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)

Necessary to comply with a legal obligation.

Data retention

  1. Our current data retention policy is to delete or destroy (to the extent we are able to) the personal data we hold about you in accordance with the following timescales:

a. Records relevant for contract purposes – 7 years from either the end of the contract or the date you last used our Service, being the length of time following a breach of contract in which you are entitled to make a legal claim

b. Records for tax purposes – 8 years from the end of the year to which the records relate

c. Records relating to marketing – 1 year from the last date on which a data subject has interacted with us

d. Other Data (not included above) – 1 year from the end of an applicable agreement or interaction with the data subject.

  1. The retention periods stated in this notice can be prolonged or shortened as may be required (for example, in the event that legal proceedings apply to the data or if there is an on-going investigation into the data).
  2. We review the personal data (and the categories of personal data) we are holding on a regular basis to ensure the data we are holding is still relevant to our business and is accurate. If we discover that certain data we are holding is no longer necessary or accurate, we will take reasonable steps to correct or delete this data as may be required.

Sharing your information

  1. We do not disclose any information you provide to any third parties other than as follows:

a. If you have registered with the Website on behalf of your employer then we may disclose information about your registration and use of the Website with your employer;

b. if we are under a duty to disclose or share your personal data in order to comply with any legal obligation (for example, if required to do so by a court order or for the purposes of prevention of fraud or other crime);

c. in order to enforce any terms and conditions or agreements for our services that may apply;

d. as part of a sale or transfer of the Website or its business or a restructuring your Data may be transferred to a successor, but we will take steps to ensure that your rights are protected;

e. to protect our rights, property and safety, or the rights, property and safety of our users or any other third parties. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

  1. Other than as set out above, we shall not disclose any of your personal information unless you give us permission to do so. If we do supply your personal information to a third party we will take steps to ensure that your privacy rights are protected and that third party complies with the terms of this notice.

Third party websites and services

  1. Brexitfactbase may, from time to time, employ the services of other parties for dealing with certain processes necessary for the operation of the Website. The providers of such services do not have access to certain personal Data provided by Users of this Website.

Links to other websites

  1. This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy notice does not extend to your use of such websites. You are advised to read the privacy notice or statement of other websites prior to using them.

Changes of business ownership and control

  1. Brexitfactbase may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Brexitfactbase. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy notice, be permitted to use the Data for the purposes for which it was originally supplied to us.
  2. We may also disclose Data to a prospective purchaser of our business or any part of it.
  3. In the above instances, we will take steps with the aim of ensuring your privacy is protected.

Controlling use of your Data

  1. Wherever you are required to submit Data, you will be given options to restrict our use of that Data. This may include the following:

a. use of Data for direct marketing purposes; and

b. sharing Data with third parties.

Functionality of the Website

  1. To use all features and functions available on the Website, you may be required to submit certain Data.
  2. You may restrict your internet browser’s use of Cookies. For more information see the clause below (Cookies).

Your Data Rights

  1. You have the following rights in relation to Data we hold about you:

a. Right to be Informed – You have a right to know about our personal data protection and data processing activities, details of which are contained in this notice

b. The right of access – You can make what is known as a Subject Access Request (“SAR”) to request information about the personal data we hold about you (free of charge, save for reasonable expenses for repeat requests). If you wish to make a SAR please contact us as described below.

c. The right to correction – Please inform us if information we hold about you is incomplete or inaccurate in any way and we will update our records as soon as possible, but in any event within one month. We will take reasonable steps to communicate the change to any third parties to whom we have passed the same information

d. The right to erasure (the ‘right to be forgotten’)- Please notify us if you no longer wish us to hold personal data about you (although in practice it is not possible to provide our Service without holding your personal data and we may need to keep your data in some circumstances). Unless we have reasonable grounds to refuse the erasure, on receipt of such a request we will securely delete the personal data in question within one month. The data may continue to exist in certain backup, but we will take steps to ensure that it will not be accessible

e. The right to restrict processing- You can request that we no longer process your personal data in certain ways, whilst not requiring us to delete the same data. However again, some of our Services will not be available if processing is restricted

f. The right to data portability- You have right to receive copies of personal data we hold about you in a commonly used and easily storable format (please let us know a format which suits you). You may also request that we transfer your personal data directly to third party (where technically possible)

g. The right to object- Unless we have overriding legitimate grounds for such processing, you may object to us using your personal data for direct marketing purposes (including profiling) or for research or statistical purposes. Please notify your objection to us and we will gladly cease such processing

h. Right to withdraw consent- If we are relying on your consent as the basis on which we are processing your personal data, you have the right to withdraw your consent at any time. Even if you have not expressly given your consent to our processing, you also have the right to object (see above).

  1. All SARs and other requests or notifications in respect of your above rights must be sent to us in writing to 206 Upper Richmond Road West, London SW14 8AH.
  2. We will endeavour to comply with such requests as soon as possible but in any event we will comply within one month of receipt (unless a longer period of time to respond is reasonable by virtue of the complexity or number of your requests).


  1. Data security is of great importance to Brexitfactbase and to protect your Data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure Data collected via this Website.
  2. If password access is required for certain parts of the Website, you are responsible for keeping this password confidential.
  3. We endeavour to do our best to protect your personal Data. However, transmission of information over the internet is not entirely secure and is done at your own risk. We cannot ensure the security of your Data transmitted to the Website.
  4. If personal data we hold about you is subject to a breach or unauthorised disclosure or access, we will report this to the Information Commissioner’s Office (ICO).
  5. If a breach is likely to result in a risk to your data rights and freedoms, we will notify you as soon as possible.


  1. This Website may place and access certain Cookies on your computBrexitfactbase uses Cookies to improve your experience of using the Website and to improve our range of services. Brexitfactbase has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.
  2. All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.
  3. Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling Brexitfactbase Limited to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.
  4. This Website may place cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
  5. You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.
  6. You can choose to delete Cookies at any time; however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.
  7. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.

Direct marketing

  1. We may ask for your consent for direct marketing purposes.

Transfers outside the European Economic Area

  1. Data which we collect from you may be stored and processed in and transferred to countries outside of the European Economic Area (EEA). For example, this could occur if our servers are located in a country outside the EEA or one of our service providers is situated in a country outside the EEA. These countries may not have data protection laws equivalent to those in force in the EEA.
  2. If we transfer Data outside the EEA in this way, we will take steps with the aim of ensuring that your privacy rights continue to be protected as outlined in this privacy notice. You expressly agree to such transfers of Data.


  1. You may not transfer any of your rights under this privacy notice to any other person. We may transfer our rights under this privacy notice where we reasonably believe your rights will not be affected.
  2. If any court or competent authority finds that any provision of this privacy notice (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy notice will not be affected.
  3. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
  4. This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.

Changes to this privacy notice

  1. Brexitfactbase reserves the right to change this privacy notice as we may deem necessary from time to time or as may be required by law. We encourage you to review this page periodically. The effective date of the current privacy notice is noted at the top of this page. You may contact Brexitfactbase by email at