BDQ Privacy Policy

1. Introduction

1.1    We are committed to safeguarding the privacy of our website visitors, service users and customer personnel.

1.2    This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.

1.3    In this policy, "we", "us" and "our" refer to Business Data Quality Limited. For more information about us, see Section 16.

2. The personal data that we collect

2.1    In this Section 2 we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.

Category	Details	Sources
Customer relationship data – data relating to our customers and prospective customers	Your name, the name of your business or employer, your job title or role, your contact details and information contained in or relating to communications between us and you, or between us and your employer	You or your employer; also, metadata associated with communications may be generated by our contact forms
General communications data – other data contained in or relating to communications	The general communication data may include the communication content and metadata associated with the communication For the purposes of this policy, the general communication data does not include any data that constitutes customer relationship data	You or your employer; also, metadata associated with communications may be generated by our contact forms
Accounting data – data relating to financial transactions	The accounting data may include your name, your contact details, your payment card details (or other payment details) and the transaction details	You, your employer and/or our relevant payment services provider
Analytics data – data concerning the use of our website and services	Your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use	Our analytics software and services

 

3. Purposes of processing and legal bases

3.1    In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.       

Purpose	Description	Legal basis or bases
Operations	We may process your personal data for the purposes of operating our website, publications, the processing and fulfilment of orders, providing our services, generating invoices, bills and other payment-related documentation, and credit control.	The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business.
Relationships and communications	We may process customer relationship data, general communication data and/or accounting data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, fax and/or telephone, providing support services and complaint handling.	The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, individual customers and customer personnel, the maintenance of our relationships, enabling the use of our services, and the proper administration of our website, services and business.
Direct marketing	We may process customer relationship data for the purposes of creating, targeting and sending direct marketing communications by email, SMS, post and/or fax and making contact by telephone for marketing-related purposes.	The legal basis for this processing is usually consent; in some specific cases, we may also conduct direct marketing on a legitimate interests basis (i.e. based on our legitimate interest in lawfully promoting our business and services).
Research and analysis	We may process analytics data and/or accounting data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business.	The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.
Record keeping	We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally.	The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
Security	We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity.	The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.
Insurance and risk management	We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice.	The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
Legal claims	We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.	The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
Legal compliance and vital interests	We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.	The legal basis here is compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.

 

4. Providing your personal data to others

4.1    We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.

4.2    We may disclose your personal data to our service providers, suppliers or subcontractors identified at on our website insofar as reasonably necessary for the purposes set out in this policy.

4.3    We may disclose contact information included in customer relationship data to partner companies for the purpose of join consent-based marketing initiatives.

4.4    In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

5. International transfers of your personal data

5.1    In this Section 5, we provide information about the circumstances in which your personal data may be transferred to a third country under UK and/or EU data protection law.

5.2    We may transfer your personal data from the European Economic Area (EEA) to the UK and process that personal data in the UK for the purposes set out in this policy, and may permit our suppliers and subcontractors to do so, during any period with respect to which the UK is not treated as a third country under EU data protection law or benefits from an adequacy decision under EU data protection law; and we may transfer your personal data from the UK to the EEA and process that personal data in the EEA for the purposes set out in this policy, and may permit our suppliers and subcontractors to do so, during any period with respect to which EEA states are not treated as third countries under UK data protection law or benefit from adequacy regulations under UK data protection law.

5.3    We may also transfer your personal data to those services providers / jurisdictions specified on our website. Where required by law, such transfers will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the competent data protection authorities.

5.4    You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

6. Retaining and deleting personal data

6.1    This Section 6 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2    Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6.3    We will retain your personal data as follows:

Category	Minimum retention period	Maximum retention period
Customer relationship data	6 years following the end of the relevant customer relationship	7 years following the end of the relevant customer relationship
General communications data	6 years following the date of the communication	7 years following the date of the communication
Accounting data	6 years following the end of the accounting period to which the data relates	11 years following the end of the accounting period to which the data relates
Analytics data	36 months following collection	36 months following collection

 

6.4    If you grant to us a licence to publish any of your personal data, we may continue to retain and publish that personal data after the end of the relevant retention period specified in this Section 6 in accordance with the applicable licence terms, subject to your data subject rights. If we cease to publish such personal data after the end of the relevant retention period specified in this Section 6, that personal data will be retained for a minimum period of 6 years and a maximum period of 7 years following the date that publication ceases.

6.5    Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

7. Your rights

7.1    In this Section 7, we have listed the rights that you have under data protection law.

7.2    Your principal rights under data protection law are:

(a)    the right to access - you can ask for copies of your personal data;

(b)    the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;

(c)    the right to erasure - you can ask us to erase your personal data;

(d)    the right to restrict processing - you can ask us to restrict the processing of your personal data;

(e)    the right to object to processing - you can object to the processing of your personal data;

(f)     the right to data portability - you can ask that we transfer your personal data to another organisation or to you;

(g)    the right to complain to a supervisory authority - you can complain about our processing of your personal data; and

(h)    the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

7.3    These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines-recommendations-best-practices_en and https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/ .

7.4    You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.

8. Third party websites

8.1    Our website includes hyperlinks to, and details of, third party websites.

8.2    In general we have no control over, and are not responsible for, the privacy policies and practices of third parties.

9. Updating information

9.1    Please let us know if the personal information that we hold about you needs to be corrected or updated.

10.   Acting as a data processor

10.1  In respect of certain data, such as data that we host on behalf of a customer,  we do not act as a data controller; instead, we act as a data processor.

10.2  Insofar as we act as a data processor rather than a data controller, this policy shall not apply. Our legal obligations as a data processor are instead set out in the contract between us and the relevant data controller.

11.   About cookies

11.1  A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

11.2  Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

11.3  Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.

12.   Cookies that we use

12.1  We use cookies for the following purposes:

(a)    authentication and status - we use cookies to identify you when you visit our website and as you navigate our website, and to help us determine if you are logged into our website;

(b)    security - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;

(c)    social media – to link our website to third party social media services;

(d)    analysis - we use cookies to help us to analyse the use and performance of our website and services; and

(e)    cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally.

12.2  If you have any questions about the cookies used by our website and services, please do let us know.

13.   Cookies used by our service providers

13.1  We use services from Google Analytics, LinkedIn, Facebook and Twitter to gather information about the use of our website by means of cookies. The information gathered is used to create reports about the use of our website, including the source of website traffic.

13.2  You can find out more about our service providers' use of information gathered via these cookies by following these links:

(a)    Google: https://policies.google.com/privacy and https://policies.google.com/technologies/cookies ;

(b)    LinkedIn: https://linkedin.com/legal/privacy-policy  and  https://www.linkedin.com/legal/cookie-policy;

(c)    Facebook: https://www.facebook.com/about/privacy and https://www.facebook.com/policy/cookies/ ; and

(d)    Twitter: https://twitter.com/en/privacy and https://help.twitter.com/en/rules-and-policies/twitter-cookies.

14.   Managing cookies

14.1  Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a)    https://support.google.com/chrome/answer/95647 (Chrome);

(b)    https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop (Firefox);

(c)    https://help.opera.com/en/latest/security-and-privacy/ (Opera);

(d)    https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e)    https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and

(f)     https://support.microsoft.com/en-gb/help/4468242/microsoft-edge-browsing-data-and-privacy (Edge).

14.2  Blocking all cookies will have a negative impact upon the usability of many websites.

14.3  If you block cookies, you will not be able to use all the features on our website.

15.   Amendments

15.1  We may update this policy from time to time by publishing a new version on our website.

15.2  You should check this page occasionally to ensure you are happy with any changes to this policy.

16.   Our details

16.1  This website is owned and operated by Business Data Quality Limited.

16.2  We are registered in England and Wales under registration number 04497196, and our registered office is at Leytonstone House, 3 Hanbury Drive, Leytonstone, London E11 1GA.

16.3  Our principal place of business is at Leytonstone House, 3 Hanbury Drive, Leytonstone, London E11 1GA.

16.4  You can contact us:

(a)    by post, to the postal address given above;

(b)    using our website contact form;

(c)    by telephone, on the contact number published on our website; or

(d)    by email, using the email address published on our website.

17.   Data protection registration

17.1  We are registered as a data controller with the UK Information Commissioner's Office.

17.2  Our data protection registration number is ZA265009.

18.   Data privacy officer

18.1  Our data privacy officer's contact details are:

       Dominic Bush, CTO, support@bdq.cloud