Bright Partnerships Worldwide Limited, a company incorporated in England and Wales whose registered office is at Albany House, Claremont Lane, Esher, Surrey, KT10 9FQ, and trading at 8 Boundary Row, London, SE1 8HP (registered number 08828386) (“we/us/our”) collects and uses personal data about our clients, suppliers and other individuals (“you”) for a variety of business purposes.
It is important to us to be transparent and provide accessible information about how we will use your personal data. We are committed to respecting your privacy and to complying with applicable data protection and privacy laws.
In this notice, we us the term “personal data” to mean any information relating to an identified or identifiable individual. Such individuals may include our clients, customers of our clients, suppliers, marketing contacts, and others.
About this notice
This notice sets out the basis on which we will collect and use personal data about you. It applies to all products and services provided by us. Where we process personal data on behalf of our client, information about how your personal data is processed will be contained in the privacy notice of that client.
This policy was last updated on 7 February 2023.
Our privacy and cookie notice will be reviewed and enhanced from time to time. Please check our website or contact us for a copy of the current privacy and cookie notice. If you have any questions in relation to this privacy and cookie notice, please contact us.
Responsibility for this Notice
Our Data Protection Officer has overall responsibility for the day-to-day implementation of this notice.
Post: 8 Boundary Row, London, SE1 8HP
Telephone: +44 (0)203 714 3850
2. THE INFORMATION WE COLLECT
Depending on your relationship with us, we may collect the following data about you:
- Full name and job title
- IP address and other data associated with your computer
- Demographic information e.g. postcode
- Additional information provided by you may include:
- Preferences and reminders
- Home address
- Telephone number
- Mobile phone number
- Date of birth
- Automatically generated information created while you use this website may include:
- Transactional information
- Clickstream information
Information about the personal data we collect and use about our employees and job applicants is set out on a separate privacy notice.
We do not regularly collect any ‘special categories of personal data’ about you (this means information 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) and we do not collect any information about criminal convictions and offences.
If we do need to collect any of these types of data, for example to ask you about any medical conditions prior to attending one of our events, we will generally seek your consent at that time.
3. HOW WE COLLECT YOUR DATA
We may collect personal data:
- When we meet you in person;
- When we speak to you by telephone;
- When you correspond with us by email;
- When you participate in any activities or promotions administered by us;
- When you contract with us for services we provide;
- When you fill in forms and questionnaires; or
- When you visit our website.
4. HOW WE USE YOUR DATA
We will use your personal data for our legitimate business purposes, to provide our services to our clients and to run our business.
Specific uses of your data depend on our relationship with you, but may include:
- To process and deliver services to you or to pay for services we use including:
- management of payments, fees and charges
- the collection and recovery of money owed to us
- To improve our products and services; provide relevant offers and fulfil transactions
- Internal record keeping.
- Compliance with our legal, regulatory and corporate governance obligations and good practice.
- Gathering information as part of investigations by regulatory bodies or in connection with legal proceedings or requests.
- Operational reasons, such as training and quality control, ensuring the confidentiality of commercially sensitive information, security vetting, credit scoring.
- Investigating complaints.
- Marketing our business, including but not limited to:
- Promotional emails and updates about new products, special offers or other information we may think is of interest to you
- Market research purposes, by email, phone or mail
In accordance with data protection law, we must always have a valid lawful basis for collecting and using your personal data. Where we are relying on your consent in order to collect and use your personal data, we will ask you to give your consent. You can change your mind at any time by contacting us.
We will also use your personal information because it is in our legitimate interests in order to run our business, and we do not believe that your interests and fundamental rights override those interests.
We may use your personal information where we need to do so in order to comply with our legal or regulatory obligations. For example, this will apply where we need to keep information for a specific period to comply with our legal obligations.
We will only process any special categories of personal data with your explicit consent unless exceptional circumstances apply or we are required to do this by law (e.g. to comply with legal obligations to ensure health and safety at work). Any such consent will clearly identify what the relevant data is, why it is being processed, and to whom it will be disclosed.
5. WHO WILL YOUR INFORMATION BE SHARED WITH?
Your personal data is an important part of our business. We do not sell your information to third parties. We will only share your information as set out below. All information sharing is only done on the basis of being necessary and to fulfil legitimate business purposes. For example:
- Information may be shared with third parties to enable us to provide our services to our clients. If your consent is required to pass your personal data to third parties, you may be contacted in order to give your positive consent for this purpose.
We may disclose your personal information to third parties in limited circumstances as follows:
- Where we engage the business services of a third party to provide services directly to us. We will carry out the necessary due diligence on any third party that we use to ensure that they fully comply with data protection regulations. Any third party will be engaged for a specific purpose and they will be strictly prohibited from using your personal data for any other purposes.
6. DATA SECURITY AND RETENTION
We keep personal data secure against loss or misuse. We are committed to protecting the confidentiality of your information and will take all reasonable measures to secure your information including, encryption, third party audits, access controls and security testing.
Where other organisations process personal data as a service on our behalf, our Data Protection Officer will establish what, if any, additional specific data security arrangements need to be implemented in contracts with those third-party organisations.
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.
Transferring data internationally
There are restrictions on international transfers of personal data. Whenever we transfer your personal data out of the UK, 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 UK government.
- Where we use certain service providers, we may use specific contractual clauses approved by the UK government.
7. RIGHTS TO YOUR DATA
- You have the right to access information held about you.
- Upon request, you will have the right to receive a copy of your data.
- You can ask us to correct any inaccurate information held about you.
- You may also request that your data is transferred directly to another system.
- You may request that any information held on you is deleted or removed, where there is no good reason for us to continue to process. This includes any third parties who process or use that data. Please 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.
If we can help with any of these, please email us at email@example.com.
These requests will be processed within one month, provided there is no undue burden and it does not compromise the privacy of other individuals.
If you are unhappy with the way we have responded to your request or how we have otherwise used your personal data, please contact us to give us an opportunity to resolve your issues.
You also have the right to make a complaint to the Information Commissioner’s Office, the UK’s independent regulator for data protection issues. More details of how to do so can be found at www.ico.org.uk/make-a-complaint.
8. LINKS TO OTHER WEBSITES
A cookie is a small file, which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added, and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
We use analytics cookies provided by Google and Leadfeeder to identify which pages are being used. This helps us analyse data about web page traffic and improve our website. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies when you first visit our website.