PRIVACY & PERSONAL DATA PROTECTION TERMS

These Privacy & Personal Data Protection Terms ("Privacy Policy") are an integral part of the “Website Terms of Use” (posted elsewhere on this website) and set out the terms on which we process your personal data as well as our privacy obligations to you.

1. POLICY-SPECIFIC DEFINITIONS 

In addition to the terms already defined in the “Website Terms of Use”, data processing terms, whether or not they are capitalized, shall be defined as in the General Data Protection Regulation (“GDPR”, EU Reg. n° 2016/679) and the UK DPA 2018, or, where applicable, the California Consumer Privacy Act of 2018 (CCPA).

2. DATA PROCESSING PRINCIPLES 

We process your personal data in conformity with the following principles:

2.1. Lawfulness, Fairness & Transparency : in compliance with all the relevant laws, fairly and in a transparent manner

2.2. Purpose Limitation : only for specified and legitimate purposes as described in this Privacy Policy

2.3. Data Minimization : only what is needed for the purposes defined in this Privacy Policy

2.4. Accuracy : in a way that reflects accurately on the situation in fact

2.5. Storage Limitation : only until the data is needed for the purposes defined in this Privacy Policy

2.6. Integrity & Confidentiality (Security) : in a confidential and secure manner, that seeks to prevent unauthorized or unlawful processing, loss, destruction or damage to your data

2.7. Accountability Principle : keeping records of our compliance with these principles and our relevant requirements

3. DATA CONTROLLERS & DATA PROCESSORS 

The data controller (and under CCPA the service provider) for your personal data is, unless otherwise specified:

BSD 613 Limited, a company registered in England at Companies House under n° 13204748, having its registered address at 82 King Street, Manchester, M2 4WQ, England, represented by its Director.

4. DATA PROCESSING PURPOSES & LEGAL BASIS 

Your personal data is processed for the purposes and according to the methods defined in the tables below, depending on the category of data and/or your relationship to us.

4.1. Website Use Data 

If you use the Website, your data is processed as described in the table below:

4.2. Newsfeed Email Alerts Data 

If you subscribe to the email newsfeed, your data is processed as described in the table below:

4.3. Cookie Data 

This website does not use cookies, as you can verify in your browser’s settings. As delicious as cookies may be in real life, they are not healthy foods, and similarly, computer cookies are not good for the data health of our Clients, which is why we don’t use them or any other trackers.

5. YOUR RIGHTS 

You have the following rights in relation to your personal data:

5.1. Right to be informed 

You have the right to be informed about the collection and use of your personal data in a clear and transparent way. Please consult the tables appearing in the section titled “Data Processing Purposes & Legal Basis” and in case of questions, contact us at the number or address posted on the “Contact” page of this website.

5.2. Right to access 

You have the right to request access to your personal data and obtain information regarding the purpose of processing, what categories of personal data are processed, data processors, length of processing, your rights relating to our processing, your right to lodge a complaint with a supervisory authority regarding our processing, information on third party sources of your personal data communicated to us, and the existence of automated decision-making and related information, including the logic involved, as well as the significance and the envisaged consequences of such processing for you, whether your personal data is transferred outside the EEA, and the conditions of these transfers.

5.3. Right to rectification 

You have the right to request rectification or completion of your personal data.

5.4. Right to erasure 

You have the right to request erasure of your personal data without delay if:

- your personal data is no longer necessary for the purpose under which it was collected;

- you withdraw your consent and there is no other legal basis for processing;

- you object to the processing and there are no overriding legitimate grounds for the processing;

- your personal data has been processed unlawfully;

- your personal data has to be erased according to relevant laws.

Please note that we are entitled to not erase your personal data if it is necessary for legal or regulatory purposes.

5.5. Right to restrict processing 

You have the right to restrict processing of your personal data if:

- you have contested the accuracy of your personal data, for a period enabling us to verify the accuracy of your personal data;

- the processing is unlawful and you oppose the erasure of your personal data and request the restriction of its use instead;

- they are required by you for the establishment, exercise or defense of legal claims.

Where processing has been restricted, such personal data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise or defense of legal claims, for the protection of the rights of another natural or legal person, or for reasons of public interest as such is defined in the EU.

5.6. Right to object to processing 

Where personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.

You also have the right to object to the processing of personal data where the legal basis of processing activity is our legitimate interest, or the legitimate interest of a third party.

5.7. Right to data portability 

You have the right to receive the personal data in our possession or control in a structured, commonly used and machine-readable format, and have the right to transmit that data to another data controller without hindrance from us. You also have the right to have your personal data transmitted directly from us to another data controller where technically feasible.

5.8. Right to withdraw your consent / opt out / DO NOT SELL 

You have the right to opt-out of or withdraw any consent you have given at any time, and to request that we do not sell your personal information, without affecting the lawfulness of processing based on your consent given previously.

You can do this by contacting us at the numbers or address posted on the “Contact” page of this website.

5.9. Rights related to automated decision making including profiling 

No automated decision making is carried out based on your data.

5.10. Right to lodge a complaint with a supervisory authority 

You have the right to lodge a complaint with the (governmental) authority supervising data protection in your jurisdiction.

6. ACCOUNTABILITY 

For queries relating to your data or this Privacy Policy, please contact us at the numbers or address posted on the “Contact” page of this website.

7. DATA SECURITY 

When you submit personal data online or via an application you accept the unavoidable risks associated with such technologies. WE DECLINE ALL LIABILITY RELATING TO LOSS OR CORRUPTION OF YOUR PERSONAL DATA AND ANY CONSEQUENCE THEREOF, unless we have breached the standards of care required of data processors based in the EU.

8. INTERNATIONAL DATA TRANSFERS 

All data processing and all servers are located within the EEA.

9. CALIFORNIA RESIDENTS ONLY 

This section applies only to residents of the State of California.

The types, methods, uses, sharing (including any sale) and recipients of personal information are listed in the tables in the section titled “Data Processing Purposes & Legal Basis”. Your rights, including opt-out rights, are listed in the section titled “Your Rights”, including your right to request that we DO NOT SELL your personal information.

Version: 6.3 // Updated : Nov. 2022