BPD HOLDINGS LIMITED
BPD Holdings Limited (collectively referred to as “BPD”, “Company”, “we”, “us” or “our” in this privacy notice) and its subsidiaries are committed to protecting and respecting your personal data.
Our websites are not intended for children and we do not knowingly collect data relating to children.
BPD Holdings Limited (Company Registered Number 04436966) of 2 Brooklands Road, Sale, Cheshire M33 3SS is the data controller and responsible for your personal data.
We have appointed a Data Enquiry Representative, who is responsible for overseeing questions in relation to this privacy notice including any requests to exercise your legal rights. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Data Enquiry Representative at the address above, by telephone on 0161 905 5700, or by email at email@example.com.
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 before you approach the ICO so please contact us in the first instance.
THE DATA WE MAY COLLECT ABOUT YOU
Personal data 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).
Information you give us. You may give us information about you by filling in forms on our BPD Store website or our websites or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our sites, subscribe to our service, search for a product, place an order on our site and when you report a problem with our site.
Information we collect about you.
We may collect, process, store and transfer the following kinds of personal data about you:
- Identity Data which may include first name, last name, user name or similar identifier, title and position
- Contact Data which may include invoicing and delivery address, email address, telephone numbers.
- Financial Data may include payment card details (in the case of BPD Store)
- Transaction Data may include details about payments to and from you and other details of products and services you have purchased from us (in the case of BPD Store)
- Technical Data, including Internet protocol (IP) address used to connect your computer to the Internet, your login information browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
- Profile Data may include your purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data may include information about how you use our services and website. It also includes information about your visit, including the Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer services number.
- Marketing and Communications Data includes your preferences in receiving marketing from us.
- 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.
- We do not collect any Special Categories of Personal Data about you (this 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). Nor do we collect any information about criminal convictions and offences.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
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 and Financial Data when filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- enquire about and/or contract with us for our products and services;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us some feedback.
- Third parties or publicly available sources. We may receive personal data about you from various third parties such as
- Technical Data from the following parties:
- analytics providers;
- advertising networks; and
- search information providers.
- Identity, Contact, Financial and Transaction Data from providers of technical payment and delivery services.
- Identity and Contact Data from data brokers or aggregators.
- Identity and Contact Data from publicly available sources.
- Technical Data from the following parties:
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. These cookies allow us to distinguish you from other users of our website, which helps us to provide you with a good experience when you browse our website and allows us to improve our site.
The cookies we use are required for the operation of our website. They include, for example, cookie that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services, Analytical/performance cookies allowing us to recognise and count the number of visitors and to see how visitors move around our site when they are using it. This helps us to improve the way our website works, for example by ensuring that users are finding what they are looking for easily. This enables us to personalise our content for you, greet you by name and remember your preferences. We also use Targeting cookies which record your visit to or website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
Except for essential cookies, all cookies will expire after 30 days.
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.
- Sending e-mail marketing communications that you have already given us prior consent to receive.
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.
|Purpose/Activity||Type of data||Lawful Basis for processing including|
|basis of legitimate interest|
|To register you as a new customer||(a) Identity||(a) Performance of a contract with you|
|To process and deliver your order including:||(a) Identity||(a) Performance of a contract with you|
|(a) Manage payments, fees and charges||(b) Contact||(b) Necessary for our legitimate interests|
|(b) Collect and recover money owed to us||(c) Financial||(to recover debts due to us)|
|(e) Marketing and Communications|
|To manage our relationship with you which||(a) Identity||(a) Performance of a contract with you|
|will include:||(b) Contact||(b) Necessary to comply with a legal|
|(a) Notifying you about changes to our terms||(c) Profile||obligation|
|(b) Asking you to leave a review or take a||(to keep our records updated and to study|
|survey||how customers use our products/services)|
|To enable you to take part in a prize draw,||(a) Identity||(a) Performance of a contract with you|
|competition or complete a survey||(b) Contact||(b) Necessary for our legitimate interests|
|(c) Profile||(to study how customers use our products/|
|(d) Usage||services, to develop them and grow our|
|(e) Marketing and Communications||business)|
|To administer and protect our business and||(a) Identity||(a) Necessary for our legitimate interests|
|this website||(b) Contact||(for running our business, provision of|
|(including troubleshooting, data analysis,||(c) Technical||administration and IT services, network security,|
|testing, system maintenance, support,||to prevent fraud and in the context of a business|
|reporting and hosting of data)||reorganisation or group restructuring exercise)|
|(b) Necessary to comply with a legal|
|To make suggestions and recommendations||(a) Identity||(a) Necessary for our legitimate interests (to|
|to you about goods or services that may be||(b) Contact||develop our products/services and grow|
|of interest to you||(c) Technical||our business)|
|Marketing & Measurement||Type Of Data||Lawful Basis|
|To use data analytics to improve our website,||(a) Technical||Necessary for our legitimate interests (to|
|products/services, marketing, customer||(b) Usage||define types of customers for our products and|
|relationships and experiences||services, to keep our website updated and|
|relevant, to develop our business and to inform|
|our marketing strategy).|
|To undertake segmentation and profiling||(a) Identity||Necessary for our legitimate interests (to provide|
|(b) Contact||targeted and appropriate marketing messages).|
|(c) Marketing and Communications|
|To send email marketing messages about||(a) Identity||We require consent for email marketing activity|
|promotional offers, products and services||(b) Contact||(BPD Store)|
|we offer, and content that we create||(c) Marketing and Communications||Users can opt themselves into receiving our|
|email marketing on one of the contact forms|
|on our websites. Users can opt out of marketing|
|activity by clicking the unsubscribe link in the|
|emails they receive, or by contacting us directly.|
|Records of consent are maintained in our internal|
|To send postal marketing about offers and||(a) Identity||Necessary for our legitimate interests (direct|
|products and services we offer||(b) Contact||marketing).|
|(c) Marketing and Communications||Users can opt out of postal marketing activity by|
|or by contacting us directly.|
|To target display advertising to users that||(a) Technical||Necessary for our legitimate interests (to define|
|have previously visited our websites and||(b) Usage||customer types and serve relevant messaging|
|shown interest in our products and services.||(c) Profile||to users that are interested in our products &|
|No Identity or Contact data is used in this process.|
|Users can opt out of processing in this way by|
|To analyse user’s sessions on our websites,||(a) Technical||Necessary for our legitimate interests (to keep our|
|by recording their mouse movements and||(b) Usage||website updated, free from issues, and provide|
|website behaviours to identify website issues||(c) Profile||the best possible user experience).|
|and improve the users experience.||We use this data to measure how users are|
|interacting with our site, which elements of the site|
|are causing problems with the user experience,|
|and if there are any errors with the site. This also|
|includes replaying sessions and watching|
|No Contact or Identity information is recorded or|
|processed. Users can opt out by blocking cookies.|
|To measure interactions with, and how you||(a) Technical||Necessary for our legitimate interests (to allow|
|share our content on social networks.||(b) Usage||users to click through to, follow and like, or share|
|(c) Profile||our content on social media).|
|Data is collected by social media platforms when|
|users use their share, like and follow buttons. For|
|access to this information, or to opt out, users|
|can adjust their account settings on the relevant|
We will get your opt-in consent before we share your personal data with any company outside the Company for marketing purposes.
You can ask us to stop sending you marketing messages at any time by contacting us at any time at firstname.lastname@example.org or by clicking on the unsubscribe link found on all our electronic communications.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.
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.
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.
DISCLOSURE OF YOUR INFORMATION
We may share your personal information with any member of our Group, which means our subsidiaries, our ultimate holding company and its subsidiaries.
We may share your information with selected external third parties for the purposes set out in the table above including:
- Service providers acting as processors based inside the EU who provide IT and system administration services;
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services;
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
- 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.
We require all third parties 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.
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services.
We ensure your personal data transferred within our group of companies is protected by requiring all our group companies to follow the same rules when processing your personal data. These rules are called "binding corporate rules".
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
- where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe;
- where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are as follows:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with the law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
USUALLY NO FEE TO ACCESS YOUR INFORMATION
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
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.
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.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
WHERE WE STORE YOUR PERSONAL DATA
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using TLS technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
HOW LONG WILL YOU RETAIN 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.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data.
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.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This version was last updated on 22 June 2018.
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.
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