ABOUT THIS POLICY
It also explains your privacy rights and how the law protects you including how we comply with the General Data Protection Regulation (“GDPR”) and other related legislation which relates to the use of personal data.
rb&m Limited is the data controller and is responsible for the use of your personal data. Our full details are set out below.
Jacqueline Robinson: firstname.lastname@example.org
You have the right to make a complaint to the Information Commissioner’s Office (ICO) which is the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, like the opportunity to assist you with any concerns before you approach the ICO so please contact us in the first instance using the details above.
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.
This website may include links to third-party websites, such as our Twitter and LinkedIn social media pages. Clicking on those links may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies. You should read any policies and other statements on such websites carefully.
DATA WE COLLECT ABOUT YOU AND HOW WE WILL USE IT
Personal data means any information about an individual from which that person can be identified. It does not include data which has been anonymised such that a person’s identity is removed.
The following table explains the types of personal data which we may collect, use, store and transfer. We will only use your personal data as the law allows us to. The categories of personal data which we use include:
Identity and Contact Data such as names, titles and other identifiers together with address, email address and telephone numbers.
Technical Data including internet protocol (IP) address, your login data, browser type and version, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. This may also include information about how you use our website and our products and services.
The table below also explains the purposes for which we use different categories of personal data and the legal basis or bases which we believe applies to those uses. We may process your personal data for more than one lawful basis depending on the purpose for which we are using your data.
|Purpose||Types of personal data used||Lawful basis for processing|
|To manage the relationship which we have with you, such as dealing with any enquiries or complaints.||Identity and Contact Data||This will be necessary for our legitimate interests in ensuring that the services we provide are managed, so that we can contact you to deal with those issues or enquires, as appropriate.|
|To administer this website, including troubleshooting, data analysis, testing, system maintenance and support||Identity and Contact Data
|This will be necessary for our legitimate interests in providing and improving our website and customer service to you, to improving the services we offer and in ensuring our website operates properly and for network security.|
|To provide you with marketing communications such as a newsletter, for example.||Identity and Contact Data
Marketing and Communications Data
|This will be necessary for our legitimate interests in developing, marketing and promoting our services.|
|To ensure our third-party providers can perform their obligations to us.||Identity and Contact Data
|This will be necessary for our legitimate interests in ensuring that our third-party providers perform their services for us. For example, from time to time we may also use IT providers and marketing consultants for the proper function of the website and to help us promote our services.|
|To consider you for employment with us where you submit your details to us to apply for a role with us.||Identity and Contact
|This will be necessary for our legitimate interests in responding to your application, and in considering you as a potential candidate for employment with us.|
|To gather your feedback on our services, for example, if we run a survey about the services we provide.||Identity and Contact Data||This will be necessary for our legitimate interests in seeking to improve the quality of our services.|
In addition, we may disclose information about you to the extent that we are required to do so by law, regarding any legal proceedings or prospective legal proceedings, in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk) and / or where we may otherwise do so in accordance with applicable data protection legislation.
HOW IS YOUR PERSONAL DATA COLLECTED?
Most of the personal data which we hold is collected directly through the website or by email and will be directly from you. For example, you might provide certain identity information by completing our contact form on the rb&m website.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, under the terms of a contract we have with you or for another lawful reason and you fail to provide that data, we may not be able to fully perform our obligations in accordance with our contract, provide you with the information you require or otherwise properly deal with your request.
MARKETING AND PROMOTIONS
From time to time we may use your data including identity and contact data, technical data and profile data and marketing and communications data, to contact you with information about our services. You may receive marketing communications from us if you have contacted us about our services, or have purchased services from us.
Email marketing messages may contain tracking beacons / tracked clickable links or similar server technologies in order to track subscriber activity within email marketing messages. Where used, such marketing messages may record a range of subscriber data relating to engagement, geographic, demographics and already stored subscriber data.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
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. Please also 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.
If you would like further information about how we use personal data and the purposes for which we might use it, please contact us.
DISCLOSURES OF YOUR PERSONAL DATA
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.
We do not transfer your personal data outside the European Union.
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 it. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
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.
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.
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.
In some circumstances, we may anonymise 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 policy to you.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Those rights are listed below. Please contact us if you would like to exercise any of them. You have the right to:
- Request access to your personal data (a “data subject access request”). This means you can receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of your personal data: 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. You can ask us to remove personal data where there is no good reason for us continuing to process it. You also have this right where you have successfully exercised your right to object to processing, where we may have processed your data unlawfully or where we are required to erase your personal data to comply with law. We may not always be able to comply with your request where there are particular legal reasons.
- Object to processing of your personal data where we rely on a legitimate interest basis and if the processing impacts on your fundamental rights and freedoms. You can also object to direct marketing. In some cases, we may demonstrate that we have grounds to process your data which override your rights and freedoms.
- Request restriction of processing. You can ask us to suspend the processing of your personal data: if you want us to establish the data’s accuracy; where our data use is unlawful but you do not want us to erase it; where you need us to hold the data even if we no longer need it, to establish, exercise or defend legal claims; or you have objected to use of data but we need to verify whether we have overriding legitimate grounds to use it.
- Request a data transfer. We will provide to you, or your chosen third party, your personal data in a structured, commonly used, machine-readable format. This only applies to automated information which you provided consent for us to use or necessary to perform a contract with you.
- Withdraw consent at any time where we rely on consent to process your personal data. This will not affect the lawfulness of processing carried out before you withdraw your consent.
EXERCISING YOUR RIGHTS
You will not have to pay a fee to access your personal data (or to exercise any other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
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 personal data is not disclosed to a person who has no right to receive it. We may also contact you to ask you to clarify your request to speed up our response.
We try to respond to all legitimate requests within one week. Occasionally it may take us longer than a week if your request is particularly complex or you have made several requests in which case we will keep you updated.