Introduction

BDP Agency respects your privacy and is committed to protecting your personal data. This will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or use our services and tell you about your privacy rights and how the law protects you.

BDP Agency is committed to the protection of personal data and the fundamental rights of data subjects, in compliance with relevant laws such as the Data Protection Act 1998, The General Data Protection Regulation (GDPR) and the Privacy & Electronic Communications Regulations or any data protection, electronic communications or e-privacy laws, rules or guidance that come into force in the UK from time to time.

Purpose of this privacy notice

This privacy notice aims to give you information on how BDP Agency collects and processes your personal data through your use of this website or our services, including any data you may provide through this website when you sign up to our services, visit our web pages or contact us.

This website and our services are not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements any other notice or policies and is not intended to override them. The information contained within this website is no substitute for specific advice and we will not accept liability if you rely solely on information from the website.

Roles and responsibilities

BDP Agency (collectively referred to as BDP Agency, ‘we’, ‘us’ or ‘our’ in this privacy notice) is the controller and responsible for your personal data; except when we are processing your personal data on behalf of a third party in accordance with their strict instructions, we are then acting as a processor.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager.

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. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

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.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

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 may collect, use, store and transfer various kinds of personal data about you which we have grouped together as follows:

  • Identity Data – includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data – includes company address, email address, telephone numbers and social media profiles.
  • Financial Data – includes details about payments to and from you and other details of products and service you have purchased from us.
  • Technical Data – 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 and our product.
  • Profile Data – includes your username, password, purchases and order made by you, your interests, preferences, feedback and survey responses.
  • Usage Data – includes information about how you use our website, products and services.
  • Marketing and Communications Data – includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We may 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 however is not considered personal data in law as this data does not directly or indirectly reveal your identity.

For example, we may aggregate your 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.

In general, and with the exception of specific circumstances (for example if you are one of our employees including situations where candidates could become employees) we do not collect any special categories of personal data about you including 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 or information about criminal convictions and offences.

If you are unable 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 goods or services). In this case, we may have to cancel a product or service you have with us or we might be unable to start providing the services, however we will notify you if this is the case at the time.

How is your personal data collected

How your personal data is collected will depend on your relationship with us. 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 by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • ask us for advice; or liaise with us for any other business purpose;
  • interact with one of our marketing links;
  • apply for our products or services;
  • wish to become our client;
  • subscribe to our service, or mailing list or complete our contact forms;
  • request marketing / information to be sent to you;
  • enter a competition, promotion or survey;
  • apply to do a work placement with us;
  • apply for a position with us;
  • engage with us on our social media platforms; or
  • provide us with feedback.

Automated technologies or interactions.

As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

Third parties or publicly available sources.

We may receive personal data about you from various third parties and sources in the public domain, as set out below including technical data from the following parties:

  • Analytics providers such as Google
  • Advertising networks
  • Search Information and other Data Providers
  • Providers of technical, payment and delivery services
  • Publicly available sources such as Companies House

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 or with other third parties.
  • 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.

Generally, we do not rely on consent as a legal basis for processing your personal data including in relation to sending direct marketing communications to you via email. You have the right to opt out of marketing or ask any questions about how we process your personal data by contacting us at any time.

Purposes for which we will use your personal data

We have set out below some examples of the ways that 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 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.

Purpose/ActivityLawful basis for processing including basis of legitimate interest
To register you as a new customerPerformance of a contract with you
To process and deliver your order and perform our services to you including: manage payments, collect and recover money owed to usPerformance of a contract with you
To manage our relationship with you including: notifying you about changes to our terms or privacy policy, asking you to leave a review or take a survey for market researchPerformance of a contract with you
To comply with a legal obligation
Legitimate Interests
To enable you to partake in a prize draw, competition or complete a surveyPerformance of a contract with you
Legitimate Interests
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)To comply with a legal obligation
Legitimate Interests
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to youLegitimate Interests
To make suggestions and recommendations to you about goods or services that may be of interest to you from our business or 3rd partiesLegitimate Interests

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising from our business and 3rd parties.

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications if you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us or by following the opt-out links on any marketing message sent to you at any time.

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 in relation not performance of a contract with you.

Cookies

This website uses cookies. A cookie is a small text file stored in your computer containing text data. We use cookies for certain functions to improve the usability of the website. These cookies do not contain any personal information about you. However, enabling cookies in your web browser is necessary if you wish your selections to be remembered for future visits on the same computer. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

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.

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 above.

  • Service providers acting as processors who provide IT and system administration services
  • Professional advisors acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers and who may require reporting of processing activities in certain circumstances
  • Our customers or clients (for product personal data) and for all personal data, other third parties from time to time which may include market researchers or fraud prevention agencies.

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 policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We only permit third party service providers to process your personal data for specified purposes and in accordance with our instructions.

Personal data breaches

BDP Agency has established a personal data breach response procedure, related to notification of personal data breaches in line with the current laws.

Data retention

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. For example, by law we have to keep basic information about our customers (including Contact, Identity and Financial Data) for 6 years after they cease being customers for tax and legal purposes.

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.

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.

International transfers

From time to time, we may share your personal data which involves transferring it to third parties who may be established outside the European Economic Area (EEA).

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. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
  • 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. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
  • 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 the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

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 rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Pleas see the glossary for further information on these rights.

What we 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 with our form 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.

 

Glossary

Definitions

In this document, we adopt the same definitions as the GDPR, in particular:

Personal data ‘means any information relating to an identified or identifiable natural personal (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person’.

Processing ‘means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction’.

Controller ‘means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law’.

Data Subject ‘means a natural person whose personal data is processed by a controller or processor’.

Processor ‘means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing’.

Personal data breach ‘means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed’.

Lawful basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject where applicable, namely;

Your rights

You have the right to:

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 to delete or remove personal data where there is no good reason for us continue 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 local 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.