- IMPORTANT INFORMATION AND WHO WE ARE
- THE DATA WE COLLECT ABOUT YOU
- HOW IS YOUR PERSONAL DATA COLLECTED?
- HOW WE USE YOUR PERSONAL DATA
- DISCLOSURES OF YOUR PERSONAL DATA
- INTERNATIONAL TRANSFERS
- DATA SECURITY
- DATA RETENTIONY
- YOUR LEGAL RIGHTS
1. IMPORTANT INFORMATION AND WHO WE ARE
Our Site and App are not intended for children and we do not knowingly collect data relating to children.
We are the controller and responsible for your personal data we collect through your use of our Site and App.
Full name of legal entity: BuyABeam Limited
Name of DPO: Thomas Baker
Email address: firstname.lastname@example.org
Postal address: Unit 3a Lucas Green, West End, Woking, Surrey, United Kingdom, GU24 9YB
Telephone number: 0330 320 0650
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes name, username or similar identifier;
- Contact Data includes postal address, email address and telephone number;
- Financial Data includes bank account and payment card details;
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased via our Site or App;
- Technical Data includes internet protocol (IP) address, your login data, device type, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Site and App;
- Profile Data includes your username and password, purchases or orders received or made by you, feedback and survey responses;
- Usage Data includes information about how you use our Site and App;
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences; and
- Location Data includes your current location disclosed by GPS technology.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact, Financial and Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email, via our Site and App or otherwise. This includes personal data you provide when you:
- create an account on and use our Site or App;
- purchase or sell products via our App or Site;
- request marketing to be sent to you;
- enter a promotion or survey; or
- give us feedback, leave a review or contact us.
- Third parties or publicly available sources. We may receive personal data about you from the following third parties and public sources:
- Technical Data from analytics providers, such as Google;
- Financial and Transaction Data from providers of payment services, such as GoCardless.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to do so. Most commonly, we will use your personal data in the following circumstances:
- Where you have consented before the processing;
- Where we need to perform a contract we are about to enter or have entered with you;
- Where it is necessary for our Legitimate Interests (or those of a third party) and your interests and fundamental rights do not override those interests; and
- Where we need to Comply with a Legal Obligation.
Click here to find out more about the types of Lawful Basis that we will rely on to process your personal data.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our Legitimate Interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer or supplier|
(b) Performance of a Contract
|To enable you to use our Site or App, to manage our charges and collect money owed to us|
(e) Marketing and Communications
(b) Performance of a Contract
(c) Necessary for our Legitimate Interests (to study how customers use our Site or App, to develop them, to grow our business and to recover debts due to us)
To manage our relationship with you which will include:
(b) Asking you to give us feedback, leave a review or take a survey
(d) Marketing and Communications
(b) Performance of a Contract
(c) Necessary to Comply with a Legal Obligation
(d) Necessary for our Legitimate Interests (to keep our records updated and to study how customers use our Site or App)
|To enable you to partake in a promotion or complete a survey|
(e) Marketing and Communications
(b) Performance of a Contract
(c) Necessary for our Legitimate Interests (to study how customers use our Site or App, to develop them and to grow our business)
To administer and protect our business and our Site and App (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our Legitimate Interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to Comply with a Legal Obligation
|To use data analytics to improve our Site and App, marketing, customer relationships and experiences|
(b) Necessary for our Legitimate Interests (to define types of customers or suppliers for our Site or App, to keep our Site and App updated and relevant, to develop our business and to inform our marketing strategy)
|To make suggestions and recommendations to you about goods or services that may be of interest to you|
(f) Marketing and Communications
(b) Necessary for our Legitimate Interests (to develop our Site or App and to grow our business)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased or sold goods via our Site or App and you have consented to receiving that marketing.
We will get your Consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by logging into the Site or App and checking or unchecking relevant boxes to adjust your marketing preferences, by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product or service purchase, sale, experience or other transaction.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below for the purposes set out in the table above:
- External Third Parties as set out in the Glossary; and
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
- Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
Where we have given you (or where you have chosen) a user identification code, password or any other piece of information that enables you to access certain parts of our Site or App, you are responsible for keeping such information confidential. You must not disclose it to any third party.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We will not normally retain your personal data for longer than twelve months from deletion of your account, save that we may retain your personal data for a longer period:
- Where for legal, accounting and tax purposes we have to keep certain information about you, including Contact, Identity, Financial or Transaction Data, which we may have to retain for up to seven years after deletion of your account; and
- In the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data: please see Your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
In the event that you do not use our Site or App for a period of twelve months then we may treat the account as expired and your personal data may be deleted.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:
- Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a Legitimate Interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- if you want us to establish the data's accuracy;
- where our use of the data is unlawful but you do not want us to erase it;
- where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine- readable format. Note that this right only applies to automated information which you initially provided Consent for us to use or where we used the information to perform a contract with you.
- Withdraw Consent at any time where we are relying on Consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your Consent. If you withdraw your Consent, we may not be able to provide certain services or products to you. We will advise you if this is the case at the time you withdraw your Consent.
If you wish to exercise any of the rights set out above, please contact our DPO.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service or product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your Consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of a Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a Legal Obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
EXTERNAL THIRD PARTIES
- Persons or entities acting as joint controllers or processors from whom you have received or with whom you have placed orders for products via our Site or App; and
- Service providers acting as processors who provide IT services (such as website hosting and data storage) as well as payment and system administration services.