Privacy Policy
Privacy Policy
1 Introduction
This Privacy Policy explains how Mike Golf Security & Investigation collects, uses, stores, shares, and protects personal data.
It applies to personal data collected through our website, by email, telephone, messaging services, social media, written correspondence, in person, and during the provision of our security and investigative services.
We are committed to handling personal data lawfully, fairly, securely, and transparently in accordance with applicable data protection law.
By using our website, contacting us, submitting an enquiry, or engaging our services, you acknowledge that your personal data may be processed in accordance with this Privacy Policy.
2 Who We Are
Mike Golf Security & Investigation is the trading name under which the relevant services are provided.
For the purposes of applicable data protection law, the data controller is the operator of Mike Golf Security & Investigation.
If you have any questions about this Privacy Policy or about how your personal data is handled, please contact us using the contact details published on this website.
3 The Personal Data We May Collect
We may collect, use, store, and process personal data including:
a. identity data, such as names, titles, dates of birth, photographs, and identifying details;
b. contact data, such as addresses, email addresses, telephone numbers, and social media details;
c. client data, such as enquiry details, instructions, booking information, account information, and communications;
d. billing and transaction data, such as invoice details, payment information, and records of fees and expenses;
e. technical data, such as IP addresses, browser type, device information, operating system details, website usage data, and cookies data;
f. operational data, such as logs, notes, reports, images, audio, video, statements, surveillance material, service records, and related evidential or intelligence material;
g. background information, such as employment history, business connections, publicly available profile information, and other relevant due diligence material;
h. correspondence data, such as emails, telephone records, messages, and notes of communications; and
i. any other personal data reasonably required in connection with an enquiry, instruction, investigation, security task, legal support task, or related business function.
Depending on the nature of the work, we may also process more sensitive categories of information, including special category data and, where lawful, criminal offence data.
4 How We Collect Personal Data
We may collect personal data:
a. directly from you;
b. from your representatives, advisers, referees, witnesses, or authorised contacts;
c. from publicly available sources;
d. from open-source research and publicly accessible online platforms;
e. from clients who instruct us;
f. from service providers, contractors, agents, subcontractors, and professional advisers;
g. through website forms, email, telephone calls, messaging services, cookies, analytics tools, and other digital communications; and
h. in the course of carrying out security, investigative, process serving, tracing, surveillance, background checking, evidential, or related operational activities.
5 How We Use Personal Data
We may use personal data for the following purposes:
a. to respond to enquiries and assess prospective instructions;
b. to verify identity, contact details, instructions, and authority;
c. to open, manage, and administer client matters and client accounts;
d. to provide security, investigative, process serving, surveillance, tracing, and related services;
e. to prepare reports, statements, evidence packs, service records, and related deliverables;
f. to communicate with clients, prospective clients, third parties, contractors, and professional advisers;
g. to manage billing, invoicing, payments, debt recovery, and financial administration;
h. to maintain internal records, quality assurance, training, compliance, governance, and risk management processes;
i. to monitor, review, and protect our website, systems, operations, personnel, and business;
j. to prevent, detect, investigate, document, or report unlawful acts, misconduct, fraud, threats, abuse, or other improper activity where appropriate;
k. to establish, exercise, or defend legal claims;
l. to comply with legal, regulatory, insurance, tax, safeguarding, and professional obligations; and
m. to improve our website, services, and business operations.
6 Lawful Bases for Processing
We process personal data only where we have a lawful basis to do so.
Depending on the circumstances, we may rely on one or more of the following lawful bases:
a. contract, where processing is necessary to take steps at your request before entering into a contract or to perform a contract with you;
b. legal obligation, where processing is necessary for compliance with a legal or regulatory obligation;
c. legitimate interests, where processing is necessary for our legitimate business, operational, evidential, security, investigative, administrative, or legal interests, provided those interests are not overridden by the rights and freedoms of the individual concerned;
d. consent, where consent is required or otherwise appropriate; and
e. vital interests, where processing is necessary to protect someone’s vital interests in an emergency.
Where we process special category data or criminal offence data, we will do so only where we have an additional lawful condition permitting that processing under applicable law.
7 Legitimate Interests
Where we rely on legitimate interests, those interests may include:
a. operating and administering our business;
b. managing enquiries, instructions, bookings, and client relationships;
c. providing lawful security and investigative services;
d. documenting events, service attempts, relevant activity, and evidential matters;
e. protecting our legal rights, commercial position, personnel, and operations;
f. maintaining records, standards, quality assurance, and internal review processes;
g. preventing and addressing fraud, misuse, abuse, threats, and unlawful conduct; and
h. establishing, exercising, or defending legal claims.
8 Special Category Data and Criminal Offence Data
Given the nature of our work, we may in limited circumstances process special category data or criminal offence data where this is lawful, necessary, and proportionate.
This may include data that arises in connection with investigations, security matters, due diligence, safeguarding concerns, legal proceedings, evidential review, or related operational work.
Where required, we will seek to identify and rely on an appropriate additional condition under applicable data protection law before carrying out such processing.
9 Disclosure of Personal Data
We may disclose personal data where reasonably necessary to:
a. clients and prospective clients;
b. contractors, subcontractors, operatives, agents, and associates engaged in connection with the work;
c. professional advisers, including solicitors, accountants, insurers, compliance advisers, and debt recovery providers;
d. courts, tribunals, regulators, law enforcement bodies, government authorities, or other official bodies;
e. process servers, enquiry agents, tracing agents, security personnel, and specialist service providers;
f. IT providers, cloud storage providers, website hosts, analytics providers, and other business support providers; and
g. any other person where disclosure is required or permitted by law, necessary for the performance of the services, or necessary for the establishment, exercise, or defence of legal claims.
We do not sell personal data.
10 International Transfers
We aim to store and process personal data within the United Kingdom or in jurisdictions that provide an appropriate level of protection.
Where personal data is transferred outside the United Kingdom, we will take reasonable steps to ensure that appropriate safeguards are in place where required by law.
11 Data Security
We take reasonable and proportionate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other misuse.
However, no system, website, transmission method, or storage arrangement can be guaranteed to be completely secure, and we cannot guarantee absolute security.
12 Data Retention
We retain personal data only for as long as is reasonably necessary for the purposes for which it was collected, including for operational, evidential, legal, insurance, tax, regulatory, complaint-handling, and record-keeping purposes.
Retention periods may vary depending on the nature of the matter, the type of data, the purpose of the processing, and any legal, regulatory, contractual, or evidential requirements.
When personal data is no longer required, we will seek to delete, destroy, anonymise, or securely archive it as appropriate.
13 Your Data Protection Rights
Subject to applicable law, you may have rights including:
a. the right to be informed about how your personal data is used;
b. the right to request access to your personal data;
c. the right to request correction of inaccurate or incomplete personal data;
d. the right to request erasure of personal data in certain circumstances;
e. the right to request restriction of processing in certain circumstances;
f. the right to object to certain types of processing;
g. the right to data portability in certain circumstances; and
h. rights relating to automated decision-making where applicable.
These rights are not absolute and may be limited, restricted, or disapplied in certain circumstances under applicable law.
14 Exemptions and Restrictions
Because of the nature of our work, there may be circumstances in which we are lawfully entitled to restrict, withhold, or refuse information or action in response to a data protection request.
This may apply, for example, where compliance with a request would be likely to prejudice investigations, legal proceedings, regulatory functions, the rights and freedoms of others, or another exemption under applicable law.
Where appropriate, we may also decline to confirm whether or not we hold particular personal data.
15 Cookies and Website Data
Our website may use cookies, analytics tools, server logs, and similar technologies to help operate the website, improve user experience, monitor performance, enhance security, and understand website usage.
You can usually control cookies through your browser settings. If you disable cookies, some parts of the website may not function properly.
Where required by law, we will request consent before using non-essential cookies.
16 Third-Party Websites
This website may contain links to third-party websites or services. We are not responsible for the privacy practices, content, or security of third-party websites or services.
You should review the privacy policies of any third-party websites you visit.
17 Marketing Communications
Where permitted by law, we may contact you about our services, updates, or relevant business communications.
Where consent is required for marketing communications, we will seek that consent before sending them.
You may request that we stop sending marketing communications at any time.
18 Children’s Data
Our services and website are not directed at children. We do not knowingly collect personal data from children except where this arises incidentally and lawfully in connection with a legitimate instruction, legal matter, safeguarding matter, or related operational context.
19 Complaints
If you have any concerns about how we handle personal data, please contact us first so that we have the opportunity to review and address the matter.
You also have the right to complain to the Information Commissioner’s Office if you believe your data protection rights have been breached.
20 Changes to This Privacy Policy
We may update this Privacy Policy from time to time by publishing a revised version on this website.
The latest version published on the website will apply from the date of publication.
21 Contact
If you have any questions about this Privacy Policy or wish to exercise any of your data protection rights, please contact us using the contact details published on this website.
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