Privacy Notice

FOR CUSTOMERS AND PROSPECTIVE CUSTOMERS

This notice applies to you if you are an individual customer (including a sole trader or partnership) of ours or an employee of our corporate customer [or group company of our corporate customer,] who (i) has contracted with us to purchase our services/products; or (i) we have contacted you about the services/products we offer as a business.

This notice does not form part of any contract for services or products. A copy of our customer terms and conditions can be found here http://www.blinkbrowbar.com/info/terms-and-conditions/

References to we, our or us in this privacy notice are to  Blink Brow Bar Limited of 1 Gledhow Gardens, London, SW5 0BL (Registered number 0655384)

We have not appointed a Data Protection Officer to oversee our compliance with data protection laws [as we not required to do so, but our HR Advisor has overall responsibility for data protection compliance in our organisation.  Contact details are set out in the “Contacting us” section at the end of this privacy notice.

We are committed to respecting your privacy. This notice is to explain how we may use the personal information we collect and use about you during and after your working relationship with us. This notice also explains how we comply with the law on data protection and what your rights are.

1. For the purposes of this privacy notice and for data protection law we are the controller of your personal information.

PERSONAL INFORMATION WE COLLECT

When you interact with us or we interact with you in relation to our products and services, you may provide us with or we may obtain personal information about you, such as the following:

  • Contact details: information that allows us to contact you directly such as your name, email address, telephone number, addresses, allergy, health and patch test information and details of availability.
  • Purchase details and requirements: details of the products or services you have asked us to provide to you, or other instructions and decisions made by you in relation to our products or services;
  • Financial information: bank accounts, credit/debit card details, payment and receipt details, refund or credit details and details of payment transactions with you;
  • Records of your interactions with us: such as any enquiries or complaints you make, telephone conversations, letters and other correspondence (including e-mail) and your usage of our website.
  • Online account information:use of and movements through our online portal, passwords, personal identification numbers, IP addresses, user names and other IT system identifying information;
  • Responses to any feedback forms, surveys or competitions:we keep records of any responses you give us;
  • Your marketing preferences: so that we know whether and how we should contact you.
  • CCTV images:recorded by our CCTV systems

 

2. SPECIAL CATEGORIES OF PERSONAL INFORMATION

We will not collect, store and use the following “special categories” of more sensitive personal information regarding you:

  • information about your race or ethnicity, religious beliefs, sexual orientation and political opinions;
  • information about your trade union memberships;
  • information about your health, including any medical condition, health and sickness records, medical records and health professional information and disability information; and
  • biometric information about you, for example fingerprints, retina scans.

If we do collect any special category personal information, we do not currently rely on consent as a basis for processing special category personal information.

We will also not collect, store and use any criminal records information in relation to you.  If wedo collect any criminal records information, we do not currently rely on consent as a basis for processing criminal records information.

 

3. WHERE WE COLLECT YOUR INFORMATION

We will collect personal information from a number of sources. These include the following:

  • Directly from you:from yourself, when you use our website, make a claim, make a complaint, contact us by phone, email or communicate with us directly in some other way.
  • Third parties authorised by you: a family member or someone else authorised by you.
  • Advisors: either advisors appointed by you, for example legal advisors, or advisors appointed by us.
  • Our website: provides us with information about how you use it and the devices that you use to connect to our website.
  • Providers of information: which may include credit reference agencies, private investigators, Companies House, LinkedIn and other web platforms or social media.
  • Sub-contractors:such as our couriers, import/export agents, shippers, service sub-contractors, payment processors and any other sub-contractors;

We will also collect additional personal information throughout the period of the services and/or products we provide.

If you are providing information regarding other individuals to us, it is your responsibility to ensure that you have the right to provide the information to us.

If you are providing us with details about other individuals they have a right to know and to be aware of what personal information we hold about them, how we collect it and how we use and may share that information.  Please share this privacy notice with those of them whom you feel are sufficiently mature to understand it. They also have the same rights as set out in the “Your rights in relation to personal information” section below.

 

4. WHAT WE USE YOUR PERSONAL INFORMATION FOR

The table below describes the main purposes for which we process your personal information, the categories of your information involved and our lawful basis for being able to do this.

For some of your personal information you will have a legal, contractual or other requirement or obligation for you to provide us with your personal information.  If you do not provide us with the requested personal information we may not be able to properly perform our contract with you or comply with legal obligations.  For other personal information, whilst you may not be under an obligation to provide it to us, if you do not provide it then we may not be able to properly perform our services for you as an asset manager.

You should be aware that it is not a condition of any contract with us that you agree to any request for consent from us and we do not usually rely on consent as a basis for processing your personal information.  However if we have asked you for consent, and you have given us your consent to use your personal information, you have the right to withdraw this consent at any time, which you may do by contacting us as described in the “Contacting us” section below.

Please note however that the withdrawal of your consent will not affect any use of the data made before you withdrew your consent and we may still be entitled to hold and process the relevant personal information to the extent that we are entitled to do so on bases other than your consent.  Withdrawing consent may also have the same effects as not providing the information in the first place, for example we may no longer be able to provide carry out certain activities.

 

5. WHO WE SHARE YOUR PERSONAL INFORMATION WITH

We share personal information with the following parties:

  • Any party approved by you: for example family members.
  • Credit reference agencies.
  • Companies in the same group of companies as us: for the purpose of providing services or products to you.
  • Other service providers to our business and advisors: third party banks, administration and IT services and other service providers. All our third-party service providers are required to take appropriate security measures to protect your personal information.
  • Advisors: either advisors appointed by you, for example legal advisors, or advisors appointed by us.
  • Purchasers of our business: buyers or perspective buyers to whom we may sell or negotiate to sell our business.
  • Sub-contractors:such as our couriers, import/export agents, shippers, service sub-contractors, payment processors and other sub-contractors.
  • The Government, government bodies or our regulators: where we are required to do so by law or to assist with their investigations or initiatives, for example HMRC or the Information Commissioner’s Office.
  • Police, law enforcement and security services: to assist with the investigation and prevention of crime and the protection of national security.

We do not disclose personal information to anyone else except as set out above unless we have your consent or we are legally obliged to do so.  We do not sell, rent or trade your data.

 

6.DIRECT MARKETING

Email, post, telephone and SMS marketing:from time to time, we may contact you by email, post, telephone or SMS with information about products or services we believe you may be interested in.

We will only send marketing messages to you in accordance with the marketing preferences you set when you create your account or that you tell us afterwards you are happy to receive or where you or the organisation you represent have purchased similar services or goods from us previously or you ask us to send you the information.

You can then let us know at any time that you do not wish to receive marketing messages by sending an email to us at enquiries@blinkbrowbar.com  or by using the details set out in the “Contacting us” section below.  You can also unsubscribe from our marketing by clicking on the unsubscribe link in any written marketing messages we send to you or letting us know during any marketing telephone call.

 

7.TRANSFERRING YOUR PERSONAL INFORMATION INTERNATIONALLY

The personal information we collect may be transferred to and stored in countries outside of the UK and the European Union. Some of these jurisdictions require different levels of protection in respect of personal information and, in certain instances, the laws in those countries may be less protective than the jurisdiction you are typically resident in. We will take all reasonable steps to ensure that your personal information is only used in accordance with this privacy notice and applicable data protection laws and is respected and kept secure and where a third part processes your data on our behalf we will put in place appropriate safeguards as required under data protection laws.  For further details please contact us by using the details set out in the “Contacting us” section below.

If you require more details on the arrangements for any of the above then please contact us using the details in the “Contacting us” section below.

 

8. HOW LONG DO WE KEEP PERSONAL INFORMATION FOR

The duration for which we retain your personal information will differ depending on the type of information and the reason why we collected it from you. However, in some cases personal information may be retained on a long term basis: for example, personal information that we need to retain for legal purposes will normally be retained in accordance with usual commercial practice and regulatory requirements.  Generally, where there is no legal requirement, we retain all physical and electronic records for a period of approximately 6years following the end of our customer relationship with you or the organisation you work for because this is the limitation period for claims related to breach of contract. The exceptions to this general rule are:

  • Where you or the organisation you work for have not yet become a customer and we are only engaged in marketing to you, we will retain your details for as long as any consent you have given remains valid and/or a period of 2years since our last interaction, unless you or the organisation you work for later becomes a customer;
  • CCTV images will generally be retained for approximately 90 days and then overwritten, unless required to be retained for any reason; and

It is important to ensure that the personal information we hold about you is accurate and up-to-date, and you should let us know if anything changes, for example if you move home or change your phone number or email address. Alternatively, you can contact us by using the details set out in the “Contacting us” section below.

 

9. YOUR RIGHTS IN RELATION TO PERSONAL INFORMATION

You have the following rights in relation to your personal information:

  • the right to be informed about how your personal information is being used;
  • the right to access the personal information we hold about you;
  • the right to request the correction of inaccurate personal information we hold about you;
  • the right to request the erasure of your personal information in certain limited circumstances;
  • the right to restrict processing of your personal information where certain requirements are met;
  • the right to object to the processing of your personal information;
  • the right to request that we transfer elements of your data either to you or another service provider; and
  • the right to object to certain automated decision making processes using your personal information.

You should note that some of these rights, for example the right to require us to transfer your data to another service provider or the right to object to automated decision making, may not apply as they have specific requirements and exemptions which apply to them and they may not apply to personal information recorded and stored by us.  For example we do not use automated decision making in relation to your personal data. However some have no conditions attached, so your right to withdraw consent or object to processing for direct marketing are absolute rights.

Whilst this privacy notice sets out a general summary of your legal rights in respect of personal information, this is a very complex area of law. More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-public/.

To exercise any of the above rights, or if you have any questions relating to your rights, please contact us by using the details set out in the “Contacting us” section below.

If you are unhappy with the way we are using your personal information you can also complain to the UK Information Commissioner’s Office or your local data protection regulator. We are here to help and encourage you to contact us to resolve your complaint first.

 

10. CHANGES TO THIS NOTICE

We may update this privacy notice from time to time. When we change this notice in a material way, we will update the version date at the bottom of this page. For significant changes to this notice we will try to give you reasonable notice unless we are prevented from doing so. Where required by law we will seek your consent to changes in the way we use your personal information.

 

11. CONTACTING US

In the event of any query or complaint in connection with the information we hold about you, please email enquiries@blinkbrowbar.comor write to us at Blink Brow Bar, 8 Oldbury Place, Marylebone, London, W1U 5PG.

 

REST OF THE WORLD

FOR INDIVIDUALS NOT COVERED BY A SPECIFIC PRIVACY NOTICE 

This notice applies to you if we process your personal information and you are not an employee or worker of ours, a prospective candidate employee or worker, a prospective customer or existing customer or an individual to whom we have provided a specific privacy notice.  You may be, for example, be an individual that works at a supplier or another organisation that we deal with, an attendee at one of our marketing events, a user of our website or someone who is affected by our activities.

References to we, ouror usin this privacy notice are to Blink Brow Bar Limited of 1 Gledhow Gardens, London, SW5 0BL    (Registered number 0655384)We have not appointed a Data Protection Officer to oversee our compliance with data protection laws as we are not required to do so, but our HR Advisor has overall responsibility for data protection compliance in our organisation. Contact details are set out in the “Contacting us” section at the end of this privacy notice.

We are committed to respecting your privacy. This notice is to explain how we may use personal information we collect before, during and after your relationship with us. This notice explains how we comply with the law on data protection and what your rights are.

For the purposes of data protection we will be the controller of any of your personal information.

1. PERSONAL INFORMATION WE COLLECT

We may collect the following types of personal information about you:

  • Contact details: information that allows us to identify and contact you directly such as your name, address email address, telephone number and addresses.
  • Identification information:passport and other official identification details, information from a third party money laundering check provider, Companies House information, national insurance number, membership of relevant schemes.
  • Details of your work history: This includes may include positions, roles, responsibilities, professional qualifications.
  • Personal history and information: This includes hobbies, interests, marital status, family details and dietary requirements.
  • Advisors appointed by you: including mortgage brokers, lawyers, financial advisors, surveyors.
  • Business information: including property owned by you, transactions, amounts paid or owed and tenants.
  • Responses to surveys, competitions and promotions:we keep records of any surveys you respond to or your entry into any competition or promotion we run.
  • Creditworthiness:We may undertake investigations into your creditworthiness in order to establish whether to enter into or continue a business relationship with you or the organisation you work for.
  • Details of your performance: when working with or for us or in relation to any project or work we are engaged in.
  • How you use our website: we collect information about the pages you look at and how you use them, usernames and passwords.
  • Videos, photographs and audio recordings: which you or other people take and provide to us or we take ourselves.
  • CCTV images: if you visit any of our premises which areas covered by our CCTV system.
  • Your usage of the IT systems we make available to visitors to our premises: for example our client internet and Wi-Fi facilities.
  • Details of the correspondence (including e-mail correspondence) you send and receive from us and details of any claims: this includes letters and emails, SMS, MMS and other electronic communication and may in some cases include audio recording of telephone conversations.
  • Subscription information:for example when you subscribe to one of our blogs or other materials.
  • IP address information:your computer’s IP address allows us to track your usage of our website.

 

2.SPECIAL CATEGORIES OF PERSONAL INFORMATION

We do not generally collect, store and use the following “special categories” of more sensitive personal information regarding you:

  • information about your race or ethnicity, religious beliefs, sexual orientation and political opinions;
  • information about your trade union memberships;
  • information about your health, including any medical condition, health and sickness records, medical records and health professional information; and
  • biometric information about you, for example fingerprints, retina scans.

If we do collect any special category personal information, we do not currently rely on consent as a basis for processing special category personal information.

We will also not collect, store and use any criminal records information in relation to you.  If we do collect any criminal records information, we do not currently rely on consent as a basis for processing criminal records information.

 

3.SOURCES WE COLLECT YOUR PERSONAL INFORMATION FROM

We will collect personal information from a number of sources. These may include the following:

  • Directly from you:when you indicate that you may wish to attend an event, complete forms we provide to you, use our website, enter our competitions and promotions, make a claim, make a complaint, provide money laundering information to us contact us by phone, email or communicate with us directly in some other way.
  • From referrals and recommendations: usually given by other people who know you or have a working relationship with you.
  • Our website: provides us with information about how you use it and the devices that you use to connect to our website.
  • Providers of information: which may include professional bodies or trade associations, credit reference agencies, money laundering check provider, Companies House, the Land Registry, LinkedIn and other web platforms and social media.
  • Journalists or other investigators: they may provide us with details or make enquires about you or matters concerning you or ourselves.
  • Your employer or the organisation you work for: they may provide us with your name, position contact details and background information about you.
  • Our professional advisors: such as lawyers, accountants, financial advisors, planning consultants, surveyors, consultants and other advisors.
  • Your professional advisors: such as lawyers, accountants, financial advisors, planning consultants, surveyors, consultants and other advisors.
  • The Government, local authorities or relevant regulators:to assist with investigations, for example the Information Commissioner’s Office or applications to the local authority.

We will also collect additional personal information throughout the period of our relationship with you.

If you are providing information regarding other individuals to us, it is your responsibility to ensure that you have the right to provide the information to us.

If you are providing us with details about other individuals they have a right to know and to be aware of what personal information we hold about them, how we collect it and how we use and may share that information.  Please share this privacy notice with those of them whom you feel are sufficiently mature to understand it. They also have the same rights as set out in the “Your rights in relation to personal information” section below.

 

4. WHAT WE USE YOUR PERSONAL INFORMATION FOR

The table below describes the main purposes for which we process your personal information, the categories of your information involved and our lawful basis for being able to do this. Which will apply will depend upon the nature of your relationship and interactions with us.

For some of your personal information you may have a legal, contractual or other requirement or obligation for you to provide us with your personal information.  If you do not provide us with the requested personal information we may not be able to properly perform our contract with you or the organisation you represent or comply with legal obligations and we may have to terminate our relationship.  For other personal information you may not be under an obligation to provide it to us, but if you do not provide it then we may not be able to properly perform our arrangements with you or the organisation you represent.

Where you have given us your consent to use your personal information in a particular manner, you have the right to withdraw this consent at any time, which you may do by contacting us as described in the “Contacting us” section below.  We will generally only ask for your consent for direct marketing.

Please note however that the withdrawal of your consent will not affect any use of the data made before you withdrew your consent and we may still be entitled to hold and process the relevant personal information to the extent that we are entitled to do so on bases other than your consent.  Withdrawing consent may also have the same effects as not providing the information in the first place, for example we may no longer be able to provide marketing information to you.

We may anonymise and aggregate any of the personal information we hold (so that it does not directly identify you).  We may use anonymised and aggregated information for purposes that include testing our IT systems, research, data analysis, improving our site and developing new products and services.

CCTV images relating to you will be covered by our separate privacy notice regarding our CCTV system which can be found at www.blinkbrowbar.com  or you can request a copy by contacting us as described in the “Contacting us” section below.

 

5. WHO WE SHARE YOUR PERSONAL INFORMATION WITH

We may share personal information with the following parties:

  • Organisations in the same group as us:in relation to joint events or joint work.
  • Other companies in our supply chain: so that they can contact you about any issues in the supply chain or where your personal information is relevant to a subcontractor or party above us in the supply chain.
  • Credit reference and other identification agencies: so that we can assess your creditworthiness and to verify your identity.These agencies may retain a footprint that a search has been undertaken.
  • Third parties who ask for or want referrals: we may provide your details to a third party who is seeking services/products which are the same or similar to those that you provide.
  • Marketing and public relations companies: to help us to develop, carry out and assess marketing and PR campaigns
  • Other service providers and advisors to us:such as companies that support our IT, social media, help us analyse the data we hold, process payments, send communications to our customers, provide us with legal, property or financial advice and generally help us deliver our products and services to you or the organisation that you represent or for us to purchase them from you or the organisation you represent.
  • Information providers: which may include credit reference agencies, money laundering check provider, Companies House, the Land Registry.
  • Purchasers of our business:buyers or perspective buyers to whom we sell or negotiate to sell our business.
  • The Government, local authorities, planning authorities or relevant regulators:where we are required to do so by law or to assist with their investigations, for example the Information Commissioner’s Office.
  • Police, law enforcement agencies and security services:to assist with the investigation and prevention of crime and the protection of national security.

[We also use Google Analytics which sets cookies to collect information about how visitors use our website. We use the information to compile reports and to help us improve the website. The cookies collect information in an anonymous form, including the number of visitors to the website and blog, where visitors have come to the website from and the pages they visited. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.]

We may provide third parties with aggregate statistical information and analytics about users of our products and services but we will make sure no one can be identified from this information before we disclose it.

We do not disclose personal information to anyone else except as set out above unless we have your consent or we are legally obliged to do so.  We do not sell, rent or trade your data.

 

6. DIRECT MARKETING

Email, post and SMS marketing:from time to time, we may contact you by email, post or SMS with information about products or services we believe you may be interested in.

We will only send marketing messages to you in accordance with the marketing preferences you set when you create your account or that you tell us afterwards you are happy to receive or where you or the organisation you represent have purchased similar services or goods from us previously.

You can then let us know at any time that you do not wish to receive marketing messages by sending an email to us at enquiries@blinkbrowbar.com or by using the by using the details set out in the “Contacting us” section below.  You can also unsubscribe from our marketing by clicking on the unsubscribe link in any marketing messages we send to you.

 

7. TRANSFERRING YOUR PERSONAL INFORMATION INTERNATIONALLY

The personal information we collect may be transferred to and stored in countries outside of the UK and the European Union. Some of these jurisdictions require different levels of protection in respect of personal information and, in certain instances, the laws in those countries may be less protective than the jurisdiction you are typically resident in. We will take all reasonable steps to ensure that your personal information is only used in accordance with this privacy notice and applicable data protection laws and is respected and kept secure and where a third part processes your data on our behalf we will put in place appropriate safeguards as required under data protection laws.  For further details please contact us by using the details set out in the “Contacting us” section below.

If you require more details on the arrangements for any of the above then please contact us using the details in the “Contacting us” section below.

 

8. HOW LONG DO WE KEEP PERSONAL INFORMATION FOR

We will keep your personal information for as long as is necessary for the purpose for which it has been obtained and then for as long as there is any risk of a potential claim, which will be dependent upon the limitation period for the particular type of claim.  We have set out below the main retention periods which will apply:

  • For individual contacts at customers and suppliers this will be for as long as we continue to have a relationship with that customer or supplier and then for a period of6  years afterwards.
  • For marketing contacts it will generally be a period of 2 years after we were last in contact with you.
  • For website users it will generally be a period of 6 years after you used our website.
  • For individuals seeking information, making complaints or otherwise corresponding with us it will generally be 6 years.
  • For individuals attending an event it will generally be a period of 3 years after the event.

It is important to ensure that the personal information we hold about you is accurate and up-to-date, and you should let us know if anything changes, for example if you move position or work for a different organisation or change your phone number or email address. you can contact us by using the details set out in the “Contacting us” section below.

 

9. SECURITY

We have numerous security measures in place to protect the loss, misuse and alteration of information under our control, such as passwords and firewalls. We cannot, however, guarantee that these measures are, or will remain, adequate. We do, however, take data security very seriously and will use all reasonable endeavours to protect the integrity and security of the personal information we collect about you.

 

10. YOUR RIGHTS IN RELATION TO YOUR PERSONAL INFORMATION

You have the following rights in relation to your personal information:

  • the right to be informed about how your personal information is being used;
  • the right to access the personal information we hold about you;
  • the right to request the correction of inaccurate personal information we hold about you;
  • the right to request the erasure of your personal information in certain limited circumstances;
  • the right to restrict processing of your personal information where certain requirements are met;
  • the right to object to the processing of your personal information;
  • the right to request that we transfer elements of your data either to you or another service provider; and
  • the right to object to certain automated decision making processes using your personal information.

You should note that some of these rights, for example the right to require us to transfer your data to another service provider or the right to object to automated decision making, may not apply as they have specific requirements and exemptions which apply to them and they may not apply to personal information recorded and stored by us. For example we do not use automated decision making in relation to your personal data. However some have no conditions attached, so your right to withdraw consent or object to processing for direct marketing are absolute rights.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Whilst this privacy notice sets out a general summary of your legal rights in respect of personal information, this is a very complex area of law. More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-public/.

To exercise any of the above rights, or if you have any questions relating to your rights, please contact us by using the details set out in the “Contacting us” section below.

If you are unhappy with the way we are using your personal information you can also complain to the UK Information Commissioner’s Office or your local data protection regulator. We are here to help and encourage you to contact us to resolve your complaint first.

 

11. CHANGES TO THIS NOTICE

We may update this privacy notice from time to time. When we change this notice in a material way, we will update the version date at the bottom of this notice. For significant changes to this notice we will try to give you reasonable notice unless we are prevented from doing so. Where required by law we will seek your consent to changes in the way we use your personal information.

 

12. CONTACTING US

In the event of any query or complaint in connection with the information we hold about you, please email enquiries@blinkbrowbar.com or write to us at Blink Brow Bar, 8 Oldbury Place, Marylebone, London, W1U 5PG.

 

FOR THE RECRUITMENT OF EMPLOYEES, WORKERS, DIRECTORS AND CONSULTANTS

 This notice applies to potential new employees, workers, directors and consultants. This notice does not form part of any contract of employment or other contract to provide services.  If you are offered and accept an engagement with us you will be provided with a new privacy notice which will replace this one and cover you working for us.

References to we, our or usin this privacy notice are to Blink Brow Bar Limited of 1 Gledhow Gardens, London, SW5 0BL (Registered number 0655384).

We have not appointed a Data Protection Officer to oversee our compliance with data protection laws as we are not required to do so, but our HR Advisor has overall responsibility for data protection compliance in our organisation.  Contact details are set out in the “Contacting us” section at the end of this privacy notice.

We are committed to respecting your privacy. This notice is to explain how we may use personal information we collect before and during our recruitment process.  This notice explains how we comply with the law on data protection and what your rights are.  A separate and replacement privacy notice will be provided to you to cover your working relationship with us if we do recruit you to work for us.

For the purposes of this privacy notice and data protection laws we are the controller of your personal information which we are processing to recruit you.

 

1. PERSONAL INFORMATION

When you interact with us in relation to your work with us, you may provide us with or we may obtain personal information about you, such as information regarding your:

  • contact details such as name, title, addresses, telephone numbers, and email addresses;
  • date of birth;
  • gender;
  • marital status and dependants;
  • referee details, next of kin, beneficiaries, details of family members and emergency contacts[G1];
  • national insurance number and other tax or governmental identifiers;
  • bank accounts, payroll and tax status
  • salary, bonus, commission, remuneration, annual leave, pension and benefits;
  • start date and leaving date;
  • location of employment or workplace;
  • driving licence(s) (including copies where we are required to hold such information for identification or insurance purposes where you are to use our vehicles);
  • identification documents such as passport, utility bills, identity cards, etc;
  • recruitment (including copies of right to work documentation, past employment history, references and other information included in a CV or cover letter or as part of the application process);
  • work records (including job titles, work history, working hours, training records and professional memberships) and education and professional records/qualifications;
  • compensation history and charity donation preferences;
  • pension and pension entitlements; and
  • images in video and/or photographic form and voice recordings.

=We will always aim to make it clear which personal information it is necessary for you to provide and which personal information is optional. However, if you are unsure as to whether you are required to provide any particular piece of personal information please ask.

 

2. SPECIAL CATEGORIES OF PERSONAL INFORMATION

We may also collect, store and use the following “special categories” of more sensitive personal information regarding you:

  • information about your race or ethnicity, religious beliefs, sexual orientation and political opinions;
  • information about your trade union memberships;
  • information about your health, including any medical condition, health and sickness records, medical records and health professional information and disability information; and
  • biometric information about you, for example fingerprints, retina scans.

We may not collect all of the above types of special category information about you. In relation to the special category personal data that we do process we do so on the basis that:

  • the processing is necessary for reasons of substantial public interest, on a lawful basis;
  • it is necessary for the establishment, exercise or defence of legal claims;
  • it is necessary for the purposes of carrying out the obligations and exercising our or your rights in the field of employment and social security and social protection law; or
  • based on your explicit consent.

In the table below we refer to these as the “special category reasons for processing of your personal data”.

For criminal records information in relation to you we process it on the basis of legal obligations or based on your explicit consent.  We do not generally collect criminal records information about you.

 

3. WHERE WE COLLECT YOUR INFORMATION

We typically collect personal information about employees, workers, directors and consultants through the application and recruitment process, either directly from candidates or sometimes from an employment agency, online recruitment platforms or work related online platforms such as LinkedIn.

We may sometimes collect additional information from third parties including former employers, organisations you have worked for, credit reference agencies or other background check agencies.

If you are providing us with details of referees, next of kin, beneficiaries, family members and emergency contacts they have a right to know and to be aware of how what personal information we hold about them, how we collect it and how we use and may share that information.  Please share this privacy notice with those of them whom you feel are sufficiently mature to understand it.  They also have the same rights as set out in the “Your rights in relation to personal information” section below.

 

4. USES MADE OF THE INFORMATION

The table below describes the main purposes for which we process your personal information, the categories of your information involved and our lawful basis for being able to do this.

You are not under any obligation to provide us with any of your personal information, but if you do not provide it then we may not be able to engage you.

You should be aware that it is not a condition of any contract with us that you agree to any request for consent from us.  Where you have given us your consent to use your personal information in a particular manner, you have the right to withdraw this consent at any time, which you may do by contacting us as described in the “Contacting us” section below.

Please note however that the withdrawal of your consent will not affect any use of the data made before you withdrew your consent and we may still be entitled to hold and process the relevant personal information to the extent that we are entitled to do so on bases other than your consent.  Withdrawing consent may also have the same effects as not providing the information in the first place, for example we may no longer be able to engage you.

 

5. WHO WE SHARE YOUR PERSONAL INFORMATION WITH

We share personal information with the following parties:

  • Your recruitment agency(s) or consultant(s): For the purpose of managing the recruitment process
  • Our professional advisors: such as lawyers, accountants, consultants and other advisors
  • Other service providers to our business: administration and IT services. All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information.
  • Purchasers of our business: buyers or perspective buyers to whom we sell or negotiate to sell our business.
  • The Government or our regulators: where we are required to do so by law or to assist with their investigations or initiatives, for example HMRC or the Information Commissioner’s Office.
  • Police, law enforcement and security services: to assist with the investigation and prevention of crime and the protection of national security.

We do not disclose personal information to anyone else except as set out above unless we have your consent or we are legally obliged to do so.  We do not sell your data.

 

6. TRANSFERRING YOUR PERSONAL INFORMATION INTERNATIONALLY

The personal information we collect may be transferred to and stored in countries outside of the UK and the European Union. Some of these jurisdictions require different levels of protection in respect of personal information and, in certain instances, the laws in those countries may be less protective than the jurisdiction you are typically resident in. We will take all reasonable steps to ensure that your personal information is only used in accordance with this privacy notice and applicable data protection laws and is respected and kept secure and where a third part processes your data on our behalf we will put in place appropriate safeguards as required under data protection laws. For further details please contact us by using the details set out in the “Contacting us” section below.

If you require more details on the arrangements for any of the above then please contact us using the details in the “Contacting us” section below.

 

7. HOW LONG WE KEEP PERSONAL INFORMATION FOR

The duration for which we retain your personal information will differ depending on the type of information and the reason why we collected it from you. However, in some cases personal information may be retained on a long term basis: for example, personal information that we need to retain for legal purposes will normally be retained in accordance with usual commercial practice and regulatory requirements.  Generally, where there is no legal requirement we retain all physical and electronic records for a period of 12 months if you are unsuccessful in your application to work for us.   Exceptions to this rule are:

  • CCTV records which are held for no more than 90 days unless we need to preserve the records for the purpose of prevention and detection of crime;
  • Information that may be relevant to personal injury claims, employment claims, discrimination claims may be retained until the limitation period for those types of claims has expired. For personal injury or discrimination claims this can be an extended period as the limitation period might not start to run until a long time after you have worked for us.

 

8. YOUR RIGHTS IN RELATION TO PERSONAL INFORMATION

You have the following rights in relation to your personal information:

  • the right to be informed about how your personal information is being used;
  • the right to access the personal information we hold about you;
  • the right to request the correction of inaccurate personal information we hold about you;
  • the right to request the erasure of your personal information in certain limited circumstances;
  • the right to restrict processing of your personal information where certain requirements are met;
  • the right to object to the processing of your personal information;
  • the right to request that we transfer elements of your data either to you or another service provider; and
  • the right to object to certain automated decision making processes using your personal information.

You should note that some of these rights, for example the right to require us to transfer your data to another service provider or the right to object to automated decision making, may not apply as they have specific requirements and exemptions which apply to them and they may not apply to personal information recorded and stored by us. For example we do not use automated decision making in relation to your personal data.  However some have no conditions attached, so your right to withdraw consent or object to processing for direct marketing are absolute rights.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Whilst this privacy notice sets out a general summary of your legal rights in respect of personal information, this is a very complex area of law. More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-public/.

To exercise any of the above rights, or if you have any questions relating to your rights, please contact us by using the details set out in the “Contacting us” section below.

If you are unhappy with the way we are using your personal information you can also complain to the UK Information Commissioner’s Office or your local data protection regulator. We are here to help and encourage you to contact us to resolve your complaint first.

 

9. CHANGES TO THIS NOTICE

We may update this privacy notice from time to time. When we change this notice in a material way, we will update the version date at the bottom of this page. For significant changes to this notice we will try to give you reasonable notice unless we are prevented from doing so. Where required by law we will seek your consent to changes in the way we use your personal information.

 

11. CONTACTING US

In the event of any query or complaint in connection with the information we hold about you, please email [enquiries@blinkbrowbar.comor write to us at Blink Brow Bar, 8 Oldbury Place, Marylebone, London, W1U 5PG.

 

CCTV USAGE

 

The controller of the images and personal information captured using the CCTV covered by this notice is Blink Brow Bar Limited of 1 Gledhow Gardens, London, SW5 0BL (Registered number 0655384).

 

The images and personal information are captured using our CCTV system for the purpose of security, crime detection, public safety and other legitimate reasons set out in our privacy notice.  This privacy notice can be found online at www.http://www.blinkbrowbar.com/info/privacy-policy/ or copies are available upon request.  

 

Please contact our HR Advisor by email at enquiries@blinkbrowbar.com or by post at Blink Brow Bar, 8 Oldbury Place, Marylebone, London, W1U 5PG or Telephone 0207 486 2835 if you have any queries or wish to exercise any of your rights in relation to your personal data.  Please see the privacy notice for further details.

 

 Privacy Notice For CCTV

This notice sets out how Blink Brow Bar Limitedof 1 Gledhow Gardens, London, SW5 0BL (Registered number 0655384) (we, us our) uses your personal information which may be recorded on our CCTV system. This notice explains how we comply with the law on data protection and what your rights are and for the purposes of data protection we will be the controller of any of your personal information recorded on our CCTV system.

We have not appointed a Data Protection Officer to oversee our compliance with data protection laws as we are not required to do so, but our HR Advisor has overall responsibility for data protection compliance in our organisation.  Contact details are set out in the “Contacting us” section at the end of this privacy notice.

  1. What information may we hold / process that will relate to you?

We may collect from you video recordings and still pictures which feature you if you are in the field of vision of any of our CCTV system. This personal information may include your activities, your face, car registration details and other visual information about you which is recorded on our CCTV system.

We may also collect personal information about you if you, your representative or a person authorised by you contacts us regarding an enquiry, complaint or other communication.

 

2. What do we do with your personal information?

As the data controller we will collect personal information on our CCTV system and use it for the following purposes:

  • For the prevention and detection of crime
  • For evidence in any civil or criminal legal proceedings
  • To assist in investigations
  • For safety and security
  • Dealing with any queries, complaints or enquiries
  • Retaining records

As well as being the purposes for which we use your personal information, all of the above are also legitimate reasons for us to use and store personal information relating to you which is captured on our CCTV system and legitimate interests is our legal basis for processing your personal information.

We may anonymise any of the personal information we hold on our CCTV system (so that it does not directly identify you, for example by obscuring your face) and it therefore ceases to be your personal information. We may use this anonymised information for any other purposes.

 

3. Who we share your personal information with

We share your personal information with the following parties:

  • Suppliersand service providers: to manage and operate the CCTV system as our data processor.
  • Joint data controllers: who may jointly operate and maintain the CCTV system with us.
  • The police and other law enforcement agencies: to carry out policing, assist investigations, trace missing people and investigate alleged criminal activities.
  • The security services:where relevant for matters of national security.
  • People who have been injured, attacked or had property damaged or stolen and their insurance providers:to assist them with any criminal or civil investigations or legal proceedings.
  • People who have been involved in accidents and their insurance providers:to assist with insurance claims, legal claims and investigations.
  • Private and other investigators:to aid their investigations.
  • Any relevant regulators:where we are required to do so by law or to assist with their investigations or initiatives, and this includes but is not limited to the Information Commissioner’s Office.

We do not disclose personal information to anyone else except as set out above unless we have your consent or we are legally obliged to do so.  We do not sell your data.

 

4. Transferring your personal information internationally

The personal information we collect about you is not transferred to or stored in countries outside of the UK or European Union except as set out in this section.

Our directors and other individuals working for us may in limited circumstances access personal information outside of the UK and European Union if they are on holiday abroad outside of the UK or European Union. If they do so they will be using our security measures and will be subject to their arrangements with us which are subject to English Law and the same legal protections that would apply to accessing personal data within the UK.

In limited circumstances the people to whom we may disclose personal information from our CCTV system as mentioned in section 3 above may be located outside of the UK and European Union. In these cases we will impose any legally required protections to the personal information as required by law before it is disclosed.

If you require more details on the arrangements for any of the above then please contact us using the details in the “Contacting us” section below.

 

5. How long do we keep your personal information for

We will keep your personal information for up to approximately [35] days after the recording was made. After this time the recording stored on the hard drive of our CCTV system will usually be overwritten. However if we receive an enquiry about a particular recording on our CCTV we will generally then retain that part of the recording until it is no longer required. This period can vary as it will depend upon the circumstances of the particular case, but for criminal or civil legal proceedings this could mean that the personal information is retained until after the legal case and any appeals have been concluded, which may be many years. As soon as it is no longer required we will then delete the personal information.

 

6. Your rights in relation to your personal information

You have the following rights in relation to your personal information:

  • the right to be informed about how your personal information is being used;
  • the right to access the personal information we hold about you;
  • the right to request the correction of inaccurate personal information we hold about you;
  • the right to request the erasure of your personal information in certain limited circumstances;
  • the right to restrict processing of your personal information where certain requirements are met;
  • the right to object to the processing of your personal information;
  • the right to request that we transfer elements of your data either to you or another service provider; and
  • the right to object to certain automated decision making processes using your personal information.

You should note that some of these rights may not always apply as they have specific requirements and exemptions which apply to them and they may not apply to personal information recorded and stored in our CCTV system and also other of these rights will not be relevant to personal information stored in a CCTV system.

There is no legal, contractual or other requirement or obligation for you to provide our CCTV system with your personal information.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-public/.

To exercise any of the above rights, or if you have any questions relating to your rights, please contact us by using the details set out in the “Contacting us” section below.

If you are unhappy with the way we are using your personal information you can also complain to the UK Information Commissioner’s Office or your local data protection regulator in the European Union if you are based outside the UK or bring a claim in the courts. However we are here to help and would encourage you to contact us to resolve your complaint first.

 

7. Changes to this notice

We may update this privacy notice from time to time. You are encouraged to regularly check for any updated version of this privacy notice.

 

8. Contacting us

In the event of any query or complaint in connection with the personal information we hold about you or if you would like more information about or to exercise your rights, you can contact our HR Advisor. Please email enquiries@blinkbrowbar.com or write to us at Blink Brow Bar, 8 Oldbury Place, Marylebone, London, W1U 5PG.

 

PRIVACY POLICY AND COOKIES POLICY

 

We at the Blink Brow Bar Limited of 1 Gledhow Gardens, London, SW5 0BL (Registered number 0655384)  (“we” or “our” or “us”) want to make sure all the personal information we have collected about you is safe and secure whether we collect it through our website at www.blinkbrowbar.com(“Site”) or from other sources.  This Policy set outs our commitments to you, in compliance with and beyond the General Data Protection Regulation (commonly known as the GDPR) and explains how we collect, store and use your personal information.

We have not appointed a Data Protection Officer to oversee our compliance with data protection laws as we are not required to do so, but our HR Advisor has overall responsibility for data protection compliance in our organisation.  If you have any questions about this Policy or what we do with your personal information, their contact details are set out in the “Contact” section below.

 

PRIVACY NOTICES

Collecting specific, relevant personal information is a necessary part of us being able to provide you with any services or products you may request from us or in providing services or products to our customers and members, providing you with information you have requested or just managing our relationship with you, whoever you are.

When we hold or use your personal information as a data controller or controller(see below for a description of what this is)we will provide you with a privacy notice which sets out in detail what information we hold about you (such as your contact details, address, etc.), how your personal information may be used and the reasons for these uses, together with details of your rights.

Where we collect personal information from you directly, we will provide this privacy notice at the time we collect the personal information from you.  Where we receive your personal information indirectly, we will provide this privacy notice when we first contact you, first pass the data to someone else or within a month, whichever is the earlier.

We will only provide this privacy notice to you once, generally at the start of our relationship with you. However if the applicable privacy notice is updated substantially, then we may provide you with details of the updated version.  You are encouraged to check back regularly for updates.

Copies of our current privacy notices can be found below:

Please note that it is possible for you to be covered by more than one privacy notice, for example you may be a customer who comes onto our premises and is recorded on CCTV.  In this example both our customer privacy notice and our CCTV privacy notice would apply to you, but for different categories of your personal information.

THE DIFFERENCE BETWEEN DATA CONTROLLERS/PROCESSORS

A data controllerorcontroller is a person who controls how personal information is processed and used. Data controller or controller are two terms that mean the same thing.  A data processoris a person who processes and uses personal information in accordance with the instructions of a third party, i.e. the data controller or controller.

This distinction is important. You have certain rights in relation to your personal information, for example the right to be provided with the personal information held about you and details of its use and the right to have certain of your personal information either erased or anonymised, commonly referred to as the right to be forgotten (see below to see what rights you have).  These rights can generally only be exercised against a controller of your information.

In most cases we will  be a controller of your personal information. In any case where we are not a controller this means that you cannot exercise these rights against us directly (i.e. where we only act as a data processor), but you can do so against the controller (i.e. the person who controls how we process the personal information).  In these cases we will endeavour to inform you who is the controller of your personal information so that you can direct any such requests to them.

Also it is only a controller that will provide you with a privacy notice about your personal information, so where we process your personal information as a controller we will provide you with a privacy notice.  Where we process your personal information as a data processor for a third party, that third party should provide you with a privacy notice which will set out details regarding the processing of your personal information, which should also include the processing to be carried out by us on their behalf.

 

HOW DO WE USE YOUR PERSONAL INFORMATION?

Where we are a controller we will use your personal information as described in the privacy notice provided to you, but, for example, we may use your personal information to administer any account(s) you have with us or to send you information we think you might find useful, provided you have indicated that you are happy to be contacted for these purposes.  To see how we use your personal information as a controller, please see our current privacy notices, which can be accessed below:

  • Customer privacy notice – http://www.blinkbrowbar.com/info/privacy-policy/
  • Recruitment privacy notice – http://www.blinkbrowbar.com/info/privacy-policy/
  • CCTV privacy notice – http://www.blinkbrowbar.com/info/privacy-policy/
  • Privacy notice for everyone else external to our organisation, “rest of the world” – http://www.blinkbrowbar.com/info/privacy-policy/

WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?

Details of how we disclose your personal information are set out in the relevant privacy notice provided to you, but generally it is where we need to do so in order to run our organisation (e.g. where other people process information for us). In such circumstances, we will put in place arrangements to protect your personal information.  Outside of that we do not disclose your personal information unless we are required to do so by law.

If we as a controller transfer personal information about you outside the European Economic Area (EEA), we will let you know and ensure that all reasonable security measures are taken and that any third party processers will be required to process the information in accordance with information protection laws and we will notify you in your privacy notice if we are the information controller.

We do not sell, trade or rent your personal information to others.

 

HOW LONG DO WE HOLD ON TO YOUR PERSONAL INFORMATION?

Further details of how long we hold onto your personal information for are set out in the relevant privacy notice provided to you, but we will only hold your information for as long as is necessary or where you ask us to delete records we may delete it earlier.

The duration for which we retain your personal information will differ depending on the type of information and the reason why it was collected. However, in some cases personal information may be retained on a long term basis: for example, personal information that we need to retain for legal purposes will normally be retained for at least six years in accordance with usual commercial practice and regulatory requirements.

 

WHAT ARE YOUR RIGHTS?

Full details of your rights set out in the relevant privacy notice provided to you, but you are entitled by law to ask for a copy of your personal information at any time. You are also entitled to ask us to correct, delete or update your personal information, to send your personal information to you or another organisation and to object to automated decision making. Where you have given us your consent to use your personal information in a particular manner, you also have the right to withdraw this consent at any time.

To exercise any of your rights, or if you have any questions relating to your rights, please contact us by using the details set out in the “Contact” section below. You can also unsubscribe from any direct marketing by clicking on the unsubscribe link in the marketing messages we send to you.

You should note that some of your rights may not apply as they have specific requirements and exemptions which apply to them and they may not also apply to personal information recorded and stored by us.  However your right to withdraw consent or object to processing for direct marketing are absolute rights.

If you are unhappy with the way we are using your personal information you can complain to the UK Information Commissioner’s Office or your local data protection regulator. More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-public/.  However, we are here to help and would encourage you to contact us to resolve your complaint first.

 

LINKING WITH THIRD PARTY SITES

Our Site may, from time to time, contain links to and from the websites of our commercial partners and advertisers.  If you follow a link to any of these websites, please note that these websites have their own privacy policies and they will be a data controller of your personal information. We do not accept any responsibility or liability for these policies and you should check these policies before you submit any personal information to these websites.

In addition, if you linked to this Site from a third-party site, we cannot be responsible for the privacy policies and practices of the owners or operators of that third-party site and recommend that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.

 

SECURITY

We employ a variety of technical and organisational measures to keep your personal information safe and to prevent unauthorised access to, or use, or disclosure of it. Unfortunately, no information transmission over the Internet is guaranteed 100% secure nor is any storage of information always 100% secure, but we do take all appropriate steps to protect the security of your personal information.

 

COOKIES

Certain parts of our Site use “cookies” to keep track of your visit and to help you navigate between sections. A cookie is a small data file that certain websites store on your computer’s hard-drive when you visit such websites. Cookies can contain information such as your user ID and the pages you have visited. The only personal information a cookie contains is information that you have personally supplied.

We use cookies on our Site to enable us to deliver content that is specific to your interests and gives us an idea of which parts of the Site you are visiting and to recognise you when you return to the Site. Reading cookies does not give us access to other information on your computer’s hard-drive and our Site will not read cookies created by other websites that you have visited.

You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. If, however, you select this setting you may be unable to access certain parts of the Site. Unless you have adjusted your browser settings so that it will refuse cookies, our system will issue cookies when you access the Site.

Please note providers of third party content may also use cookies over which we have no control. For detailed information on the cookies we use and the purposes for which we use them see the table at the end of the policy.

 

LOG FILES

In common with most websites, our Site logs various information about visitors, including internet protocol (IP) addresses, browser type, internet service provider (ISP) information, referring / exit pages and date / time stamp.

We may use this information to analyse trends, administer the Site, track your movement around the Site and gather broad demographic information.

 

CHANGES TO THIS POLICY

Any changes we may make to this Policy in the future will be posted on our Site and, where appropriate, notified to you by e-mail. When we change this Policy in a material way, we will update the version date at the bottom of this page. Please check back frequently to see any updates or changes to this Policy and should you object to any alteration, please contact us as set out in the “Contact” section below.

 

CONTACT

In the event of any query or complaint in connection with the information we hold about you, please contact our HR Advisor at email enquiries@blinkbrowbar.com or write to them at 8 Oldbury Place, Marylebone, London, W1U 5PG.

Whilst this privacy policy sets out a general summary of your legal rights in respect of personal information, this is a very complex area of law. More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-public/.