Privacy Policy

Protection Officer: Ricky Bostock

BriefYourMarket is committed to protecting your personal data and respecting your privacy. This privacy notice will inform you as to how we look after your personal data when you visit our website, www.briefyourmarket.com (our site), regardless of where you visit it from, and tell you about your privacy rights and how the law protects you.

1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy notice

This privacy notice aims to give you information on how BriefYourMarket collects and processes your personal data through your use of our site, including any data you may provide through our site when you fill in forms or purchase a product or service.

Our site is 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 the other notices and is not intended to override them.

Controller

BriefYourMarket is the controller and is responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy notice).

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 (as detailed below), please contact the data privacy manager using the following details.

Contact details

Our full details are:

• Full name of legal entity: BriefYourMarket Limited
• Data Protection Officer: Ricky Bostock
• DPA complaints or concerns to be sent to this email: [email protected]
• Postal address: Brindley House, Outrams Wharf, Little Eaton, Derby DE21 5EL
• Telephone number: 0344 800 84 24

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

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

This version was last updated on 17th May 2018 and historic versions can be obtained by contacting us.

We will seek to keep your data and information accurate and up-to-date but can only do so effectively if you provide us with the information that is needed. If there are any changes to your data, please notify us so we can update our records.

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 BriefYourMarket platform

Where your personal data is provided through your use of the BriefYourMarket platform and other services that we provide, we are a data processor for the purposes of the General Data Protection Regulation and the Data Protection Act 2018. Details of how your data has been collected, how it is used and your rights will be found in the Privacy Policy of our client who has communicated with you via email, surveys, SMS, letters or direct mail.

We will not take control of, use or share any of the information you provide by utilising the BriefYourMarket platform and other services that we provide with any third-parties for marketing purposes or store any of your information outside of the European Economic Area. The information you provide through your use of the BriefYourMarket platform and other services that we provide will be held securely by us and /or by our data processors whether the information is in electronic or physical format.

2. 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 (i.e. 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, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone number(s).
• 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 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 but is not considered personal data in law as this data does 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 notice.

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 collect 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 goods or 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.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

How we collect data:

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 via post, phone, email or otherwise. This includes personal data you provide when you:
  • apply for our products or services;
  • create an account on our website;
  • subscribe to our service or publications;
  • request marketing to be sent to you; 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. Please see our cookie policy which is available on our site.
• Third-parties or Publicly Available Sources. We may receive personal data about you from various third-parties and public sources as set out below:
  • Technical Data from analytics providers, advertising networks, and search information providers.
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
  • Identity and Contact Data from data brokers or aggregators.
  • Identity and Contact Data from publicly available sources.

Third-party systems we use

• Client Relationship Management software. We store personal information we collate within Microsoft Dynamics CRM.
• E-newsletter and marketing campaigns. All marketing communications are undertaken within our own BriefYourMarket platform where changes to the information we provide you and your subscription options can be changed at any time by clicking the ‘edit preferences’ link within the footer of any email you receive or by accessing the control panel on the following link: https://news.briefyourmarket.com/SignIn.aspx
• Call recording. All of our calls are recorded for training and quality purposes and recordings are held within the Xelion software system.
• Online support. Any support required by a client using the BriefYourMarket platform will be logged within the Zendesk support ticketing system.
• Accountancy and billing. All of our clients will have their data held within the Sage accountancy software system in order to generate invoices and communications surrounding the payments in relation to services used.
• Contracting with our clients. All new prospect client contracts will be processed using the Echosign platform.
• WordPress. We use a third-party service, WordPress.com, to publish our website and blog.

Contact by social media and email:

• Social media. We use a third-party provider, Hootsuite, to manage our social media interactions. If you send us a private or direct message via social media, the message will be stored by Hootsuite for 3 months. We will not share it with any other organisations.
• Email. We use Transport Layer Security (TLS) via Office 365 to encrypt and protect email traffic. If your email service does not support TLS, you should be aware that any emails we send or receive may not be protected in transit. We will also monitor any emails sent to us, including file attachments, for viruses or malicious software using Windows Smartscreen.

4. 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 or regulatory obligation.

Purposes for which we will use your personal data

Purpose/Activity	Type of data	Lawful basis for processing
To register you as a new customer	(a) Identity (b) Contact	Performance of a contract with you.
To process and deliver your order	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing	(a) Performance of a contract with you. (b) Necessary for legitimate interests.
To manage our relationship with you	(a) Identity (b) Contact (c) Profile (d) Marketing	(a) Performance of a contract. (b) Legal obligation. (c) Legitimate interests.
To administer and protect our business	(a) Identity (b) Contact (c) Technical	(a) Legitimate interests. (b) Legal obligation.

5. 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 in paragraph 4 above.

• Internal Third-parties who are companies in our group of companies based in the UK.
• External Third-parties where we are under a duty to disclose or share your personal data in order to comply with any legal obligation.
• Third-parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.

6. INTERNATIONAL TRANSFERS

Although we do not transfer your personal data outside the European Economic Area (EEA), we may share your personal data with third-parties who provide services to us and who we refer to in this privacy notice. This may involve a transfer of data outside the EEA.

7. 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.

8. 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. By law, we have to keep basic information about our customers for six years after they cease being customers for tax purposes.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data, including the right to request access, correction, erasure, restriction, transfer, or to object to processing and withdraw consent.

10. GLOSSARY

Legitimate Interests means the interests 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.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party.

Comply with a Legal or Regulatory Obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation.

11. PRIVACY NOTICE FOR JOB APPLICANTS

Purpose

We are the data controller for the information you provide during the process of applying to work with us. If you have any queries, please contact us at [email protected].

What information do we ask for and why

As part of your application for work, we will collect and store the personal information about you detailed below:

• information you provide in your curriculum vitae and any covering letter.
• information you provide during an interview.
• information about your health, including any medical condition, health and sickness records.
• information about criminal convictions and offences.

How long is information retained for

If you accept an offer of employment with us, all of the information we have requested and you provided during the application process will be retained by us as part of your personnel file for the duration of your employment and for a further 6 years following the end of your employment.

If your application for work is unsuccessful or you do not accept an offer of employment with us, the information you provided will be retained for 6 months from the date the position you applied for has been filled. Any equal opportunities or diversity information that has been provided will be retained in all cases for a period of 6 months from the date the position you applied for has been filled.