PRIVACY POLICY

Welcome to BCB Group’s privacy policy.

We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and/or use our services, and tell you about your privacy rights and how the law protects you.

By using our website or our services, you agree to be bound by this privacy policy and that we proceed to the processing of personal data on the terms outlined below.

References to “you” or “your” are to you as an individual using our website or otherwise contacting us (whether on behalf of yourself, or another individual, or organisation).

1. Important Information

Purpose of this privacy policy

This privacy policy aims to give you information on how BCB Group collects and processes your personal data through your use of this website, including any data you may provide through this website when you visit our website, sign up for our newsletter, give us feedback or contact us.

It is important that you read this privacy policy, together with any other privacy policy or fair processing policy 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 policy supplements other notices and privacy policies and is not intended to override them.

This website is not intended for children and we do not knowingly collect data relating to children.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 4 March 2022. Historic versions can be obtained by contacting us.

We reserve the right to make amendments to our privacy policy at any time.

Unless otherwise provided in this privacy policy, 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 third-party links or enabling third-party 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 policy of every website you visit.

2. About us

Controller

The following BCB Group companies have adopted this privacy policy:

BCB Payments Limited (incorporated in England and Wales with number 11313622)

BCB Digital Limited (incorporated in England and Wales with number 12071985)

BCB Prime Services Limited (incorporated in England and Wales with number 10868869)

This privacy policy is issued on behalf of the above companies so when we mention “BCB Group”, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the BCB Group responsible for processing your data. Here, BCB Digital Limited is the controller and is responsible for this website.

We are responsible for your personal data, except where we process your personal data because you use our services as a result of your relationship with a customer who we supply our services to (for example, if you use our services as a result of your being our customer’s employee or client).

Where we process your personal data because you use our services as a result of your relationship with a customer who we supply our services to, we are not the data controller as we would be processing personal data on behalf of our customer as a data processor.

Where we are processing your personal data on behalf of our customer, the privacy policy that you should be referring to would be our customer’s privacy policy. Our customer’s privacy policy should inform you as to how your personal data will be processed.

We are bound by applicable data protection laws in respect of the handling and collection of your personal data. The following companies in the BCB Group are registered as data controllers in England and Wales and their registration numbers with the Information Commissioner’s Office (“ICO”) are as follows:

  • BCB Digital Ltd (ICO registration number ZB236667)
  • BCB Prime Services Limited (ICO registration number ZB081293)
  • BCB Payments Limited (ICO registration number ZA569012)

 

Contact details

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

Email address: [email protected]

Postal address: 5 Merchant Square, London, England, W2 1AS

3. The personal 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 different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, last name, username or similar identifier, marital status, title, job title, date of birth and gender.
  • Contact Data includes billing address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services 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.
  • Profile Data includes your username and password, purchases or orders 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 could be derived from your personal data but is not considered personal data in law as this data will 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 policy.

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 ask you for 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 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.

4. 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 by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • (a)   sign up for our newsletter;
    • (b)   give us feedback or contact us; or
    • (c)   sign up for and download any content we may provide on the website from time to time.
  • Automated technologies or interactions. As you interact with the website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs/log files and other similar technologies such as tracking pixels, web beacons and tags. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy at www.bcbgroup.com/cookie-policy for further details.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties (including public sources) worldwide (who may be based outside the UK, the European Economic Area (“EEA”) and/or Switzerland, as applicable) as set out below:
    • (a) Technical Data from parties such as:
      • (i) analytics providers;
      • (ii) search information providers; and
      • (iii) advertising networks.
    • (b) Contact, Financial and Transaction Data from providers of technical and payment services.
    • (c) Identity and Contact Data from data brokers or aggregators.
    • (d) Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.
    • (e) Identity and Contact Data from conference or event providers and media outlets.

5. 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 obligation.

The type of lawful bases that we will rely on to process your personal data are set out in the Glossary.

Generally, we do not rely on consent as a legal basis for processing your personal data, although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

(A) Purposes for which we will use your personal data

We have set out below 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 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 below.

Purpose/Activity Type of Data Lawful basis for processing including basis of legitimate interest
To manage our relationship with you which may include:

(a)   Notifying you about changes to our terms of privacy policy

(b)   Asking you to leave a review or take a survey

(c) Adding you to our mailing list

(a)   Identity

(b)   Contact

(c) Profile

(d)   Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to complete a survey or similar (a)   Identity

(b)   Contact

(c) Profile

(d)   Usage

(e)   Marketing and Communications

(a)   Performance of a contract with you

(b)   Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a)   Identity

(b)   Contact

(c) Technical

(a)   Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b)   Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a)   Identity

(b)   Contact

(c) Profile

(d)   Usage

(e)   Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To be as responsive as possible to you, for example, when answering your customer support queries (a)   Identity

(b)   Contact

(c) Profile

(d)   Technical

(e)   Usage

(f) Marketing and Communications

Necessary for our legitimate interests (for example, to provide you with good service) and for your legitimate interest (for example, to receive assistance promptly)

 

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a)   Technical

(b)   Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

 

(B) Marketing

We may send you marketing communications by email, telephone, or mail.

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

(C) Promotional material from us

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 may receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

We may use provide you targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s educational page at:

http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt-out of certain targeted advertising by visiting the site links below:

For Facebook – https://www.facebook.com/settings/?tab=ads

For Google – https://www.google.com/settings/ads/anonymous

You may also opt out of some other targeted advertising by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

(D) Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

(E) Opting out

You can always ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time to exercise your right to object and withdraw your consent.

Where you opt out of receiving marketing messages, this will not apply to personal data you provided to us as a result of a product/service purchase, product/service experience or other transactions.

If you choose to object to the communications, unsubscribe or withdraw your consent, this will not make our processing of your personal data before you withdrew your consent unlawful.

(F) Cookies and other similar technologies

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. For more information about the cookies and other similar technologies we use, please see our Cookie Policy at https://www.bcbgroup.com/cookie-policy/.

(G) 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.

(H) Automated decision-making

We do not make automated decisions. Automated decisions are made by technological means, mostly based on algorithms subject to predefined criteria. Such automated decision-making, taken solely by technological means without any human intervention, may have legal effects or similarly significant effects on you.

(I) Push notifications and email notifications

This website may send you push notifications and we may send you email notifications to achieve the purposes outlined in this privacy policy.

You may, in most cases, opt-out of receiving push notifications by visiting your device settings (such as the notification settings for mobile phones and then change those settings for the website).

Note that disabling push notifications may negatively affect your use of this website.

6. Disclosures of your personal data

For the purposes set out in the “Purposes for which we will use your personal data” section above, we may share your personal data with certain parties as set out below:

  • External third parties including:
    • (a) professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK, EEA and Switzerland who provide consultancy, banking, legal, insurance and accounting services;
    • (b) HM Revenue & Customs, regulators and other authorities based in the UK, EEA, and Switzerland who require reporting of processing activities in certain circumstances; and
    • (c) our service providers acting as subcontractors or sub-processors which we use from time to time including, for example:
      • (i) Google Analytics; and
      • (ii) HubSpot CRM platform.
  • Internal third parties which are companies in the BCB Group acting as joint controllers or processors and provide services including IT and system administrative services and undertake certain reporting functions.
  • 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 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.

7. International transfers

We share your personal data within the BCB Group. This may involve transferring your data outside the UK and/or the EEA.

Our external third parties are based in many countries so their processing of your personal data will involve a transfer and/or storage of personal data worldwide (including outside the UK and/or the EEA (as applicable)).

Whenever we transfer your personal data out of the UK and/or the EEA (as applicable), 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.
  • If we transfer your personal data to any other country which is not subject to an adequacy decision of the UK or the European Commission (as applicable) regarding an adequate level of protection of personal data, we will ensure that there is a legal basis and, if required, a relevant safeguard method for such data transfer so that your personal data are treated in a manner that is consistent with, and respects the applicable laws and regulations on data protection in the UK or the EEA (as applicable).
  • Where we use certain service providers outside of the UK and/or the EEA (as applicable), we may use specific contracts approved for use in the UK and/or the EEA (as applicable) which give personal data the same protection it has in the UK and/or the EEA (as applicable).

 

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK and/or the EEA.

8. 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.

9. Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, 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, regulatory, tax, accounting, or other requirements.

We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

In some circumstances you can ask us to delete your data. Please see your legal rights below for further information.

In some circumstances we will 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.

10. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

  • 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 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 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 withdrew your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

You also have the right to make a complaint at any time to the ICO, the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with concerns before you approach the ICO so please contact us in the first instance.

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). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could 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 could 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.

11. Glossary

LAWFUL BASES

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. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

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 obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.