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BRG Enterprise Solutions Limited ("BRG") is a data controller in respect of personal data of our customers, newsletter subscribers [visitors to our group websites, (www.brggroup.com, www.ialconsultants.com, www.informationresearch.co.uk/, www.brgbuildingsolutions.com (the "Site")] and suppliers or other third parties. This means that we are responsible for deciding how we process personal data about you.
This privacy notice describes how we are or will be processing personal data about you during your relationship with us. "Processing" covers such actions as collecting, using, storing, disclosing, erasing or destroying your personal data.
References to your "personal data" will, as the context requires, include "special categories of personal data", which involves more sensitive information about you.
Our main office address and contact number are: CP House, 97-107 Uxbridge Road, Ealing, London, W5 5TL. Tel - 0208 832 7750.
We have appointed a data protection manager responsible for data protection within the business ("DPM") whose contact details are as follows:
Joanna Lander, firstname.lastname@example.org
The DPM is responsible for overseeing compliance with this privacy notice and for handling any data protection queries or issues involving BRG. You should contact the DPM in the first instance about any issue involving data protection, whether it involves your data or anyone else's.
1. What information we collect
We collect the following personal information from subscribers to our newsletters:
- Email address
- Telephone number
- If you purchase something from us, your payment details and delivery address.
Our websites use Google Analytics to help analyse how users use the website. Google Analytics uses "cookies", which are text files placed on your computer to collect standard Internet log information and visitor behaviour in an anonymous form. The information generated by the cookie about your use of the website (including IP address) is transmitted to Google. This information is then used to evaluate visitor's use of the website and compiles statistical reports on website activity for BRG.
All information gathered is used only to improve how the website works and functions. We never (and will not allow any third party to) use the analytics tool to track or to collect any Personally Identifiable Information (PII) or visitors of our website. All information the cookies collect is aggregated and therefore anonymous. Google will not associate your IP address with any other held by Google, nor link or seek to link an IP address with identity of a user.
2. How do we collect your personal data?
We collect data in relation to our customers from our customers themselves, who input their details through our Site [or provide data over the telephone].
We collect the data in relation to subscribers to our newsletters from the subscribers themselves, who input their data into a page on our Site.
We take supplier and third party contact details from suppliers/third parties themselves.
By continuing to use this website without adjusting your browser's cookie settings, you agree that we can place these cookies on your device. You can also opt out of Google's advertising tracking cookie or use a browser plugin to opt out of all Google.
3. Why do we collect your information
We collect data from our customers in order to honour the contract they have entered into with us to supply services, and to retain for future marketing purposes.
We collect data from our newsletter subscribers in order to be able to email them newsletters they have subscribed to. We do not email any marketing materials to newsletter subscribers.
We collect data from suppliers and third parties so that we have contact details for our suppliers to facilitate the contracts or business arrangements we have entered into with the supplier/third party.
4. What are the legal bases and the purposes for which we process your personal data?
We will only use your personal data as permitted by law. We will usually only use your personal data in one of the following circumstances:
- 1. Where we have your consent to do so.
- 2. Where we need to perform the contract we have entered into with you.
- 3. 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. We are required to specify what the legitimate interests are (see below for further details).
You are asked to consent to the use of your personal data when you subscribe to our newsletter(s). You may withdraw your consent for the use of your data for receiving the newsletter for these purposes at any time by following a clearly displayed link in the email and on our website, here in which case all reasonable efforts will be made to erase your data from our systems.
Necessary for the performance of a contract we have entered into with you
We process your name, address and payment details if you have purchased something from our Site in order to perform the terms of the contract we have entered into with you, and in order to deliver your purchase.
Necessary for our legitimate interests or those of a third party
It is in our legitimate interest to use the personal information of contracts from suppliers and/or third parties in order to continue our business arrangements with those suppliers/third parties.
It is in our legitimate interests to use your personal information in such a way to ensure that we can continue providing the best content to you, through our newsletters.
"Special categories" of personal data
"Special categories" of personal data require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal data. We do not process any special category data for you.
You are also reminded of your right to withdraw your consent at any time, in any cases where your consent has been sought. We would then erase your data, unless we had another lawful basis for processing it.
6. 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 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, before we start using it for that unrelated purpose. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is permitted by law.
7. Sharing Data
We may share your data with third parties, including third-party service providers and any sub-contractors of those service providers where required by law, or where we have a legitimate interest in doing so.
We require third parties to respect the security of your data and to treat it in accordance with the law.
How secure is your information with third party service providers?
All our third party service providers are required to take appropriate security measures to protect your personal data in line with our policies. We do not allow our third party service providers to use your personal data for their own purposes unless they are data controllers in their own right in relation to your personal data. Where they operate as our "data processors" (ie they process your personal data on our behalf and acting only on our instructions), we only permit them to process your personal data for specified purposes and in accordance with our instructions.
What about disclosure to other third parties?
We may share your personal data with other third parties, for example to external legal or other professional advisers, or to otherwise comply with the law. For example, we may share your personal data with external legal or other professional advisers, or to otherwise comply with the law. We use the services of Doyle Clayton solicitors who, in common with other legal or other professional advisers, act as data controllers of your personal data. For more information about how they process your personal data, visit www.doyleclayton.co.uk.
What safeguards are in place in relation to the transfer of your personal data outside of the EU?
Neither we nor any of our third party suppliers envisage transferring your personal data outside the EU. If the position changes, we will let you know and also let you know of the safeguards we will be putting in place to keep your personal data secure.
8. How long will we retain your personal data?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods for different aspects of your personal data are available in our Records Management Policy which is available from the DPM. 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 requirements.
9. What are your rights and obligations as a data subject?
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please let us know of any changes. We will update your records promptly upon being notified of such changes.
Your rights in connection with personal data
Under certain circumstances, by law you have the right to:
- 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 information we hold about you corrected.
- 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 exercised your right to object to processing (see below).
- 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.
- Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal data to another party.
If you want to review, verify, correct or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, please contact the DPM in writing.
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 for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances, as permitted by the GDPR.
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 the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
What are your rights to withdraw consent to processing?
Where you may have provided your consent to the processing of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, use our unsubscribe buttons, or contact the DPM. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
10. Using our Site
Offensive or inappropriate content on the Site
If you post or send offensive, inappropriate or objectionable content anywhere on or to the Site, or otherwise engage in any disruptive behaviour on the Site, we may use your personal information to stop such behaviour. Where we reasonably believe that you are or may be in breach of any of applicable laws (for example, but without limitation, content you have posted may be defamatory), we may use your personal information to inform law enforcement agencies about the content and your behaviour. We reserve the right to prevent you from accessing some of the Site services if you display such behaviour.
The Site may contain links to other websites where information practices may be different to ours. For example, if you click on a link, this may take you off the Site. Visitors should consult the privacy policies of the websites they are taken to for further details, as we are not responsible for and have no control over information that is submitted to, or collected by, these third parties.
We have put in place measures to protect the security of your information. Details of these measures are available upon request but in brief, we secure the storage of your data on our servers, and restrict access to only those employees, agents, contractors and other third parties who have a business need to know. 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.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
12. Changes to this privacy notice
If you have any questions about this privacy notice, please contact the DPM.
13. What are your rights to lodge a complaint about the way in which your personal data are being processed?
Firstly, we would urge you to contact the DPM in writing so that we can try to resolve your complaint to your satisfaction. If you are not satisfied with the DPM's response, you may contact the Information Commissioner's Office ("ICO") on 0303 123 1113.
You are free to contact the ICO at any time. However, emailing email@example.com may answer your concerns or questions more quickly.