Definitions and Interpretation – In this Policy the following terms shall have the following meanings: “Account” means an account required to access and/or use certain areas and features of Our Site; “Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 12, below; “Our Site” means these websites and all its subdomains, www.BusinessMobiles.com www.BusinessMobiles.com “UK and EU Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015; and “We/Us/Our” Means BusinessMobiles.com, a limited company registered in England under 03772025, whose registered address is BusinessMobiles.com Ltd, Regent House. Western Avenue Business Centre, Kendal Avenue. London, W3 0XA.
2 Information About us – 2.1 Our Site is owned and operated by BusinessMobiles.com, a limited company registered in England under 03772025 who’s registered address is BusinessMobiles.com Ltd, Regent House. Western Avenue Business Centre, Kendal Avenue. London, W3 0XA..Our VAT number is GB 735678984. 2.2 Our Data Protection Officer is Aik Gabrielsen who can be contacted on email@example.com. 2.3 Our registration number with the Information Commissioners Office is: Z2556909.
5 How Do We Use Your Data? 5.1 All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on security see section 6, below. 5.2 We use your data to provide the best possible products and services to you. This includes 5.2.1 Providing and managing your Account / 5.2.2 Providing and managing your access to Our Site / 5.2.3 Personalising and tailoring your experience on Our Site / 5.2.4 Supplying Our products and services to you / 5.2.5 Personalising and tailoring Our products and services for you / 5.2.6 Responding to communications from you / 5.2.7 Supplying you with email newsletters, alerts etc. that you have subscribed to (you may unsubscribe or opt-out at any time by clicking the ‘update your preferences link in the email or by contacting us at firstname.lastname@example.org / 5.2.8 Market research / 5.2.9 Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience / 5.3 In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the products and services We can provide you without your consent for Us to be able to use such data. 5.4 Once you have submitted your data to us, we use your data for marketing purposes which may include contacting you by email, telephone, text message with information, news and offers on Our products and services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015. 5.5 Advertisers whose content appears on Our Site may engage in what is known as “behavioural advertising” – advertising which is tailored to your preferences, based on your activity. Your activity is monitored using Cookies, as detailed below in section 12. You can control and limit your data used in this way by adjusting your web browser’s privacy settings. Please note that We do not control the activities of such advertisers, nor the information they collect and use. Limiting the use of your data in this way will not remove the advertising, but it will make it less relevant to your interests and activities on Our Site. 5.6 Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies: a) you have given consent to the processing of your personal data for one or more specific purposes; b) processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract; c) processing is necessary for compliance with a legal obligation to which we are subject; d) processing is necessary to protect the vital interests of you or of another natural person; e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or f) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
6 How and Where Do We Store Your Data? 6.1 We only keep your data for as long as We need to in order to use it as described above in section 5, and/or for as long as We have your permission to keep it. In any event, your data will be deleted if you notify us via email, telephone or post. 6.2 Some orall ofyour data may be stored or transferred outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store or transfer data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between Us and any third parties We engage with. 6.3 Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site. 6.4 The Company shall ensure that the following measures are taken with respect to the collection, holding, and processing of personal data: • All employees, agents, contractors, or other parties working on behalf of the Company shall be made fully aware of both their individual responsibilities and the Company’s responsibilities under the Regulation and under this Policy, and shall be provided with a copy of this Policy; • Only employees, agents, sub-contractors, or other parties working on behalf of the Company that need access to, and use of, personal data in order to carry out their assigned duties correctly shall have access to personal data held by the Company; • All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately trained to do so; • The performance of those employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be regularly evaluated and reviewed; • All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be bound to do so in accordance with the principles of the Regulation and this Policy by contract; • All agents, contractors, or other parties working on behalf of the Company handling personal data must ensure that any and all of their employees who are involved in the processing of personal data are held to the same conditions as those relevant employees of the Company arising out of this Policy and the Regulation. 6.5 Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.
7 Do We Share Your Data? 7.1 We may only share your data with wholly-owned subsidiaries of BusinessMobiles.com. 7.2 We may contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law. We currently contract with: Third-party Name Type of data subject Google First name, last name, email address, Adroll Email address. Facebook First name, last name, email address, Xero First name, last name, email address, company information, purchase invoices, Infusionsoft First Name, Last Name, Email Address, Telephone number, Address, Website, Company Information, Device IP Address, Credit/Debit Card Details, Dropbox First name, last name, email address. Typeform, Royal Mail and Couriers First name, last name, email address, First name, last name, Company Name, Address. 7.3 We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law. 7.4 In certain circumstances We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.
9 How Can You Control Your Data? 9.1 When you submit information via Our Site, you may be given options to restrict Our use of your data. We aim to give you strong controls on Our use of your data (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails or by emailing us to let us know your preferences). 9.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you from receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receive.
11 How Can You Access Your Data? You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details email@example.com, or using the contact details below in section 15.