Last updated: 25/3/2018
At BHB, we respect your privacy and we are committed to protecting your personal data. This privacy notice informs you about how we look after your personal data when you visit our website, use our services or otherwise conduct business with us, and it explains your privacy rights and how the law protects you.
1. Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how we collect and process your personal data through your use of this website, use of our services or other business you may conduct with us.
This website is not intended for children and we do not knowingly collect data through our website relating to children.
We are BHB Partners Limited. BHB Partners Limited is a controller of and is responsible for your personal data. Our address is 75 Kenton Street, London, WC1N 1NN, UK. We are registered with the Information Commissioner’s Office and our registration number is ZA144927.
If you have any questions about this policy, you can contact us by emailing email@example.com.
Changes to the privacy notice and your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We collect only that personal data from you that we need in order to provide you with the services you request and otherwise, in order to operate our business in the way that you would anticipate. Where you provide us with information about others, you confirm that you have all necessary consents or permissions or authority in order to do so.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
includes first name, last name and email address, telephone number, residential address(es)
Other Identifier Data
includes passport details, date of birth, marital status, job, employer/company details.
includes bank account and payment card details, billing address
includes details about payments to and from you and other details of services you have purchased from us.
Cultural and Preference Data
includes information about your personal preferences and other details that may help us to tailor our service to you, provided by you only if you would like us to have this information to better inform our service provision.
Friends and Family Data
Includes information about your friends and family members who you would like to include in our tailored service, provided by you only if you would like us to have this information to better inform our service provision.
includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
includes information about your use of our service, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); elements you viewed or words you searched for; page response times; download errors; length of visits; interaction information (such as scrolling, clicks, and mouse-overs).
includes emails, notes of conversations, and records of conversations.
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. We only collect this information if you choose to give it to us because you think that it will assist us in the provision of a tailored service to you and we only collect this information where you choose to give it to us on the basis of the provision of a particular service you have asked us to provide.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
· Direct interactions. You may give us your Identity, Contact, Financial, Cultural and Preference, Friends and Family, Communications and Sensitive Data by submitting information on our website or by corresponding with us by phone, post, email, messaging system or otherwise. This includes personal data you provide when you:
o enquire about our services;
o contract to receive our services;
o discuss with us your particular requirements in connection with our services;
o otherwise use our services.
· Automated technologies or interactions. As you interact with our website, we may automatically collect Technical and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
· Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
o Technical Data from analytics providers such as Google based outside the EU who provide server monitoring tools to monitor the status of our APIs and the type and volume of queries being made to them.
o Contact, Financial and Transaction Data from providers of technical, payment and delivery services which may have servers outside the EEA.
o Contact and Other Identifier Data from publically available sources such as Companies House and the Electoral Register, based in the EEA.
o Contact and Other Identifier Data from your contacts that wish us to provide a service for your benefit.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
· Where we need to perform the contract we are about to enter into or have entered into with you.
· Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
· Where we need to comply with a legal or regulatory obligation.
In respect of your Sensitive Data, we will only collect this from you where you provide this information voluntarily because you think that we need to be fully informed of the specific service that you are asking us to provide. Where you do so, we will take this as a clear affirmative action signifying your agreement to the processing of your Sensitive Data. You may withdraw our right to process your Sensitive Data on your behalf at any time.
From time to time, we will send you marketing communications by email about our services. We offer you the chance to opt out of receiving such emails at the point that you register your contact details with us and whenever we send such a communication, we include an option for you to unsubscribe from receiving further such communications.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at firstname.lastname@example.org if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
You can ask us to stop sending you marketing messages at any time and to stop processing any of your Sensitive Data or your Cultural and Preferences or Friends and Family at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at email@example.com.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
If you don’t provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you (such as the Contact and Financial Data) and you don’t provide that data when requested, we may not be able to perform our service contract we have or are trying to enter into with you. In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
5. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
· Third parties who support our business functions like, by way of example, mailchimp (for email services), Salesforce (our secure CRM system), Spike Globals (the company that provides an app which we use) and Square Space (our web host).
· Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
All third parties are required to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
To support our business functions, we may need to send your personal data to companies that may have servers based outside the EEA. We may also need to send your personal data to companies outside the EEA where you ask us to provide you with a specific service.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it.
Please contact us at firstname.lastname@example.org if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
How long will you use my personal data for?
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 satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data: see section 9 below.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. Your legal rights
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns about data protection before you approach the ICO so please contact us in the first instance.
You also have the right in certain circumstances to:
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights).
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 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.
Time limit to respond
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 and keep you updated.