As the operators of the website www.bethebrand.com (“Website”), Be The Brand Experience Limited (“We“, “Us”) is committed to protecting and respecting your privacy. This Privacy and Cookies Policy (“Policy”) (together with and any other documents referred to therein) sets out the basis on which the personal data collected from you, or that you provide to Us will be processed by Us. Please read the following carefully to understand our views and practices regarding your personal data and how We will treat it.
For the purpose of the General Data Protection Regulation (“GDPR”, from the GDPR implementation date) or, until GDPR implementation date, the Data Protection Act 1998, (collectively the “Data Protection Laws”) the Data Controller is Be The Brand Experience Limited.
YOUR PERSONAL INFORMATION
Information we collect from you
We collect and process some or all of the following types of information from you in the course of e.g. your use of the website or providing our services:
Information that you provide by filling in forms on the Website We may also ask you for information when you report an issue on our Client applications via our support process.
Specifically, personal details such as name, email address, job title or any information input by when using our Services are collected and recorded.
If you contact Us, We may keep a record of that correspondence.
If we contact you, We may keep a record of that correspondence and /or record details of the interaction.
Personal Data entered/ uploaded onto be the brand Client Applications subject to separate Data Protection agreements with Clients.
Data contained in emails you send to a be the brand email address.
The provision of your name and e-mail address is required from you to enable Us to respond to your enquiries submitted via our website and via support.
Information We Collect From Other Sources
We will also obtain personal data from other sources as follows:
Contact information and contact history from our own research and third parties and from us recording the outcome of calls and interactions.
USES MADE OF YOUR INFORMATION
Lawful basis for processing
If you are acting on behalf of one of Be The Brand’s clients or suppliers we process your data in order to perform our obligations pursuant to any contracts entered into between us. Accordingly, we rely on “legitimate interest” and the legitimate interest is “carrying out a contract with the party by which the data subject is engaged as an employee or sub-contractor”.
Where you have contacted us via the website, e-mail and telephone, we rely on “legitimate interest” and the legitimate interest is “responding and contacting you regarding the enquiries you have made in relation to the services we offer”.
Where We have researched your details and contacted you (via email or phone call) we rely on “legitimate interest” and the legitimate interest is direct marketing activities to introduce our services to you. Where we rely on such legitimate interest to contact you we will do sufficient research to ensure that you are in a role that will benefit from our services. Once initial contact is made we will ask for your consent to continue to contact you and process your data.
Where consent if not forthcoming we will retain a record of your name and the consent status solely to ensure that we do not contact you in the future.
Purposes of processing
We use information held about you in the following ways:
To provide you, your employer (or other organisation that has engaged you) with our services.
To ensure that content on the Website is presented in the most effective manner for you and for the device(s) you use to access and view the Website;
To provide you with information, products and offers that you request from Us or which We feel may interest you.
To carry out our obligations arising from any contracts entered into between your employer (or other organisation that has engaged you) and Us.
To notify you about changes to our service.
To introduce you to our services where we believe such services will benefit you and/ or the organisation you work for.
To avoid contacting you if you have expressed a desire that we do not do so
We will not sell, or pass on to third parties, your data.
In addition to the above uses We may use your information (and, where you have consented, permit selected third parties acting on our behalf to use your information), to notify you about goods or services which may be of interest to you. Where We do this, We will contact you by electronic means email or phone calls (e-mail or SMS). If you do not want Us to use your data in this way please either (i) unsubscribe from our electronic communications using the method indicated in the relevant communication; or (ii) inform Us at any time by contacting Us at the contact details set out below.
DISCLOSURE OF YOUR INFORMATION
We routinely disclose your personal data to third parties as follows:
We may pass your information to our third party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (e.g. to host our servers).
We may also disclose your personal data to third parties:
in the event that We sell or buy any business or assets, in which case We may disclose your personal data to the prospective seller or buyer of such business or assets; or
if We or substantially all of our assets are acquired by a third party, in which case personal data held by Us about our customers will be one of the transferred assets; or
if We are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Website Terms and Conditions and other agreements; or
to protect Our rights, property, or safety or that of our affiliated entities and our users and any third party We interact with the to provide the Website; or
Other than as set out above, and save insofar as is necessary in order for Us to carry out our obligations arising from any contracts entered into between and Us, We will not share your data with third parties unless We have procured your express consent to do so.
STORING YOUR PERSONAL DATA
We take appropriate measures to ensure that any personal data are kept secure, including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security 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 the Website; 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.
Keeping your personal data up to date
If your personal details change you may update them by contacting Us using the contact details below. If you have any questions about how We use data collected which relates to you, please contact Us by email to firstname.lastname@example.org
We will endeavour to update your personal data within seven (7) working days of any new or updated personal data being provided to Us, in order to ensure that the personal data We hold about you is as accurate and up to date as possible.
How long we keep your personal data
Sales contacts with contact consent withdrawn or negative outcome will be kept for 5 years in a “do not call” status to avoid breaching a request not to contact.
Emails will be deleted after 5 years
Data held in files will be deleted after 7 years
Personal data relating to contractual obligations to clients will be held for the duration of the contract and will be deleted 3 months after contract termination.
Where we store your personal data
All information we hold about you is stored on our secure servers within the EEA.
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
- access to your personal data and to certain other supplementary information that this Policy is already designed to address
- require Us to correct any mistakes in your information which We hold
- require the erasure of personal data concerning you in certain situations
- receive the personal data concerning you which you have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
- object at any time to processing of personal data concerning you for direct marketing
- object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
- object in certain other situations to our continued processing of your personal data
- otherwise restrict our processing of your personal data in certain circumstances
- claim compensation for damages caused by our breach of any data protection laws.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
- email, call or write to email@example.com
- let Us have enough information to identify you name and client application.
- let Us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
- let Us know the information to which your request relates
HOW TO COMPLAIN
We hope that we can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.
We may collect information about your mobile phone, computer or other device from which you access the Website including where available your IP address, operating system and browser type, for systems administration and to report aggregate information to third parties affiliates. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
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. Cookies contain information that is transferred to your computer’s hard drive.
The cookies We use include:
“Analytical” cookies. They allow Us to recognise and count the number of visitors and to see how visitors move around the Website 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.
“Functionality” cookies. These are used to recognise you when you return to our Website. This enables Us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
We used google analytics to achieve the analytical cookie information.
All questions, comments and requests regarding this Privacy and Cookies Policy should be addressed to firstname.lastname@example.org