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Please find below our Privacy & Cookie Policy

Cookie Policy

What Information Do We Collect?

Information automatically collected

In Short:  Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Website .

We automatically collect certain information when you visit, use or navigate the Website . This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Website and other technical information. This information is primarily needed to maintain the security and operation of our Website , and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

  • Log and Usage Data. Log and usage data is service-related, diagnostic, usage and performance information our servers automatically collect when you access or use our Website and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity in the Website  (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called ‘crash dumps’) and hardware settings).
  • Device Data. We collect device data such as information about your computer, phone, tablet or other device you use to access the Website . Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model Internet service provider and/or mobile carrier, operating system and system configuration information.
  • Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Website . For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. Note however, if you choose to opt out, you may not be able to use certain aspects of the Services.

 

How Do We Use Your Information?

In Short:  We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Website for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

  • To send you marketing and promotional communications. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. For example, when expressing an interest in obtaining information about us or our Website , subscribing to marketing or otherwise contacting us, we will collect personal information from you. You can opt-out of our marketing emails at any time .
  • Deliver targeted advertising to you. We may use your information to develop and display personalized content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.
  • For other business purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Website , products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.

 

Will Your Information Be Shared With Anyone?

In Short:  We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.

We may process or share your data that we hold based on the following legal basis:

  • Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.
  • Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
  • Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
  • Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
  • Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

 

More specifically, we may need to process your data or share your personal information in the following situations:

  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  • Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.Do We Use Cookies And Other Tracking Technologies?

 

In Short:  We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice .

Is Your Information Transferred Internationally?

In Short:  We may transfer, store, and process your information in countries other than your own.

Our servers are located in the United Kingdom . If you are accessing our Website from outside the United Kingdom , please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information in and other countries.

If you are a resident in the European Economic Area, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. We will however take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.

How Long Do We Keep Your Information?

In Short:  We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than 1 year .

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

How Do We Keep Your Information Safe?

In Short:  We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Website is at your own risk. You should only access the Website within a secure environment.

What Are Your Privacy Rights?

In Short:  You may review, change, or terminate your account at any time.

If you are a resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Website .

Controls For Do-Not-Track Features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

Do California Residents Have Specific Privacy Rights?

In Short:  Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Website , you have the right to request removal of unwanted data that you publicly post on the Website . To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Website , but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).

Do We Make Updates To This Notice?

In Short:  Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

How Can You Contact Us About This Notice?

If you have questions or comments about this notice, you may email us or by post to:

How Can You Review, Update, Or Delete The Data We Collect From You?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request form by clicking here . We will respond to your request within 30 days.

Privacy Policy

bf1group[1] (“we”, “us”, “our”) take your privacy very seriously.

Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR).

Key terms

Our GDPR team & contact e-mail Enza Andrews – Head of HR

Richard Colton – Head of Technology

Paul Dance – Head of SHEQ

[email protected]

Personal data Any information relating to an identified or identifiable individual
Special category personal data Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership

Genetic data

Biometric data (where used for identification purposes)

Data concerning health, sex life or sexual orientation

Data subject The individual who the personal data relates to

 

Personal data we collect about you

The personal data we collect about you depends on the particular products and services we provide to you. We will collect and use the following personal data about you:

  • your name and contact information, including email address and telephone number and company details
  • information to check and verify your identity, e.g. your date of birth
  • your gender, if you choose to give this to us
  • location data, if you choose to give this to us
  • your billing information, transaction and payment card information
  • your personal or professional interests
  • your professional online presence, e.g. LinkedIn profile
  • your contact history, purchase history and saved items
  • information from accounts you link to us, e.g. Facebook
  • information to enable us to undertake credit or other financial checks on you
  • Information about how you use our website, IT, communication and other systems
  • your responses to surveys, competitions and promotions

We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below. If you do not provide personal data we ask for, it may delay or prevent us from providing products and/or services to you.

How your personal data is collected

We collect most of this personal data directly from you—in person, by telephone, text or email and/or via our website and apps. However, we may also collect information:

  • from publicly accessible sources, e.g. Companies House or HM Land Registry;
  • directly from a third party, e.g.:
    • sanctions screening providers;
    • credit reference agencies; and/or
    • customer due diligence providers.
  • from a third party with your consent, e.g. your bank or building society
  • from cookies on our website—for more information on our use of cookies, please see our cookie policy
  • via our IT systems, e.g.:
    • from door entry systems and reception logs;
    • through automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems;

 

How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason, e.g.:

  • where you have given consent;
  • to comply with our legal and regulatory obligations;
  • for the performance of a contract with you or to take steps at your request before entering into a contract; or
  • for our legitimate interests or those of a third party.

A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.

The table below explains what we use your personal data for and why:

What we use your personal data for Our reasons
Providing products and/or services to you To perform our contract with you or to take steps at your request before entering into a contract
Preventing and detecting fraud against you or us For our legitimate interest, i.e. to minimise fraud that could be damaging for you and/or us
Conducting checks to identify our customers and verify their identity

Screening for financial and other sanctions or embargoes

Other activities necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety law or rules issued by our professional regulator

Depending on the circumstances:

·        to comply with our legal and regulatory obligations

·        for our legitimate interests

To enforce legal rights or defend or undertake legal proceedings Depending on the circumstances:

·        to comply with our legal and regulatory obligations;

·        in other cases, for our legitimate interests, i.e. to protect our business, interests and rights

Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g. policies covering security and internet use For our legitimate interests, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training and quality control For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price
Ensuring the confidentiality of commercially sensitive information Depending on the circumstances:

·        for our legitimate interests, i.e. to protect trade secrets and other commercially valuable information;

·        to comply with our legal and regulatory obligations

Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price
Preventing unauthorised access and modifications to systems Depending on the circumstances:

·        for our legitimate interests, i.e. to prevent and detect criminal activity that could be damaging for you and/or us;

·        to comply with our legal and regulatory obligations

Protecting the security of systems and data used to provide the goods and services To comply with our legal and regulatory obligations

We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, i.e. to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us

Updating and enhancing customer records Depending on the circumstances:

·        to perform our contract with you or to take steps at your request before entering into a contract;

·        to comply with our legal and regulatory obligations;

·        for our legitimate interests, e.g. making sure that we can keep in touch with our customers about existing orders and new products

Statutory returns To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments Depending on the circumstances:

·        to comply with our legal and regulatory obligations;

·        for our legitimate interests, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you

Marketing our services to:

—existing and former customers;

—third parties who have previously expressed an interest in our services;

—third parties with whom we have had no previous dealings.

For our legitimate interests, i.e. to promote our business to existing and former customers
Credit reference checks via external credit reference agencies For our legitimate interests, i.e. to ensure our customers are likely to be able to pay for our products and services
To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency. In such cases information will be anonymised where possible and only shared where necessary Depending on the circumstances:

·        to comply with our legal and regulatory obligations;

·        in other cases, for our legitimate interests, i.e. to protect, realise or grow the value in our business and assets

How and why we use your personal data—Special category personal data

Certain personal data we collect is treated as a special category to which additional protections apply under data protection law:

  • personal data revealing racial or ethnic origin, and religious beliefs
  • data concerning health information.

 

Where we process special category personal data, we will also ensure we are permitted to do so under data protection laws, e.g.:

  • we have your explicit consent;
  • the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent; or
  • the processing is necessary to establish, exercise or defend legal claims.

How and why we use your personal data—sharing

See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.

Who we share your personal data with

We routinely share personal data with:

  • companies within the Bf1 Group;
  • third parties we use to help deliver our products and/or services to you, e.g. payment service providers, warehouses and delivery companies;
  • other third parties we use to help us run our business, e.g. marketing agencies or website hosts;
  • third parties approved by you, e.g. social media sites you choose to link your account to or third party payment providers;
  • credit reference agencies;
  • our insurers and brokers;
  • our banks;

We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on them to ensure they can only use your personal data to provide services to us and to you.

We or the third parties mentioned above occasionally also share personal data with:

  • our external auditors, e.g. in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations;
  • our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;
  • law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations;
  • other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.

We will not share your personal data with any other third party

Where your personal data is held

Personal data may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal data with’).

Some of these third parties may be based outside the UK. For more information, including on how we safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the UK’.

How long your personal data will be kept

We will not keep your personal data for longer than we need it for the purpose for which it is used.

Different retention periods apply for different types of personal data. Further details on this are available in our data retention policy, a copy of which is available on request.

Transferring your personal data out of the UK

Countries outside the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.

We do not anticipate that we will transfer your personal data to countries outside the UK but in the event that we do we will comply with applicable UK laws designed to ensure the privacy of your personal data.

Under data protection laws, we can only transfer your personal data to a country outside the UK where:

  • in the case of transfers subject to UK data protection law, the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR. A list of countries the UK currently has adequacy regulations in relation to is available at: https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/international-transfers-after-uk-exit/#adequacy
  • in the case of transfers subject to EEA data protection laws, the European Commission has decided that the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy decision’) further to Article 45 of the EU GDPR. A list of countries the European Commission has currently made adequacy decisions in relation to is available at https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en.
  • there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or
  • a specific exception applies under relevant data protection law.

 

Your rights

You have the following rights, which you can exercise free of charge:

Access The right to be provided with a copy of your personal data
Rectification The right to require us to correct any mistakes in your personal data
Erasure (also known as the right to be forgotten) The right to require us to delete your personal data—in certain situations
Restriction of processing The right to require us to restrict processing of your personal data in certain circumstances, e.g. if you contest the accuracy of the data
Data portability The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object The right to object:

·        at any time to your personal data being processed for direct marketing (including profiling);

·        in certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims

Not to be subject to automated individual decision making The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
The right to withdraw consents If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time. Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn

For more information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below) or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights.

If you would like to exercise any of those rights, please email us—see below: ‘How to contact us’ and provide enough information to identify yourself (e.g. your full name, address and customer or matter reference number) and let us know what right you want to exercise and the information to which your request relates.

Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures 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.

How to complain

Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the Information Commissioner.

The Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.

Changes to this privacy policy

We may change this privacy notice from time to time—when we do we will inform you via e-mail.

How to contact us

You can contact our GDPR team by email if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

[1] bf1group is any holding company of BF1SYSTEMS LIMITED and any subsidiary of BF1SYSTEMS LIMITED or such holding company from time to time. The terms “holding company” and “subsidiary” shall have the meanings given to them in section 1159 of the Companies Act 2006

[email protected]

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Registered Office: Technical Centre, Owen Road, Diss, Norfolk, IP22 4ER, United Kingdom

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