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Privacy Policy

We at BrightMinds respect your privacy. We only use the information we collect about you carefully, lawfully and in accordance with The General Data Protection Regulation ((EU 2016/679) and the Data Protection Act 2018.

INTRODUCTION

This privacy notice provides you with details of how we collect and process your personal data through your use of our sites www.brightminds.co.uk and blog.brightminds.co.uk including any data you may provide through these websites when you sign up to our newsletter or purchase a product or service. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy

 

By providing us with your data, you warrant to us that you are over 13 years of age.

BrightMinds Ltd is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

 

We have appointed a data protection officer who is responsible for overseeing questions in relation to this privacy policy. If you have any questions regarding this privacy policy, including any requests to exercise your legal rights, please contact the Data Protection Officer using the details set out below.

 

Contact Details

Our full details are:

Full name of legal entity: BrightMinds Ltd

Data Protection Officer: Data Protection Guru

Email address: info@brightminds.co.uk

Postal address: Suite 8 Westfield Court, Third Avenue, Westfield Industrial Estate, Radstock, Bath, BA34XD

 

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 opportunity to deal with your concerns before you approach the ICO so please contact us in the first instance.

 

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

 

We keep our privacy policy under regular review.

 

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at info@brightminds.co.uk during your relationship with us.

 

THIRD-PARTY LINKS

 

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections 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 statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

 

WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND WE PROCESS IT

 

Personal data means any information about an individual from which that person can be identified. It does not include anonymised data.

 

We may collect, use, store and transfer process the following categories of personal data about you:

  • Identity Data that includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data that includes billing address, delivery address, email address and telephone numbers.
  • 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 from us.
  • Technical Data includes IP address, your login data, 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 this website.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Marketing and communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

 

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

 

Sensitive Data

We do not collect any Sensitive Data about you. Sensitive data refers to data that 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. We do not collect any information about criminal convictions and offences.

 

Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

 

 

HOW WE COLLECT YOUR PERSONAL DATA

 

We may collect data from and about you through a variety of different methods including:

  • Direct interactions: You may provide data by filling in forms on our site and / or by communicating with us by post, phone, email or otherwise, including when you:
    • order our products or services;
    • create an account on our site;
    • subscribe to our newsletter;
    • request catalogues or marketing be sent to you;
    • enter a competition, prize draw, promotion or survey;
    • give us feedback on service and products.
  • Automated technologies or interactions: As you use our site, we may automatically collect Technical Data about your equipment, browsing actions and usage patterns. We collect this data by using cookies, tracking pixels, server logs and similar technologies. We may also receive Technical Data about you if you visit other websites that use our cookies. Please see our cookie policy at https://www.brightminds.co.uk/pages/cookies-policyfor further details.
  • Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below:
    • Marketing data providers such as Experian
  • Technical Data from the following parties:
    • analytics providers such as Google based outside the UK;
    • advertising networks such as Google and Facebook based outside the UK;
    • search information providers such as Google and Microsoft Bing based outside the UK.
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services which may be based outside the UK.
  • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.

 

HOW DO WE USE YOUR PERSONAL DATA

 

We will only use your personal data when legally permitted. The most common uses of your personal data are:

  • Where we need to perform the contract we are about to enter into or have entered into 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.
  • Where we need to comply with a legal or regulatory obligation.

 

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

 

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

 

We have set out below, in 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.

 

Please 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

(a)         Identity

(b)        Contact

Performance of a contract with you

To process and deliver your order including:

(c)         Manage payments, fees and charges

(d)        Collect and recover money owed to us

 

(a)         Identity

(b)        Contact

(c)         Financial

(d)        Transaction

(e)         Marketing and communications

(a)         Performance of a contract with you

(b)        Necessary for our Legitimate Interests (to recover debts due to us)

To manage our relationship with you which will include:

(a)         Notifying you about changes to our terms of privacy policy

(b)        Asking you to leave a review of take a survey

(a)         Identity

(b)        Contact

(c)         Profile

(d)        Marketing and communications

(a)         Performance of a contract with you

(b)        Necessary to comply with legal obligation

(c)         Necessary for our Legitimate Interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a prize draw, competition or complete a survey

(a)         Identity

(b)        Contact

(c)         Profile

(d)        Usage

(e)         Marketing and communications

(a)         Performance of a contract with you

(b)        Necessary for our Legitimate Interests (to study how customers use our products/services to develop them and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a)         Identity

(b)        Contact

(c)         Technical

(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 deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a)         Identity

(b)        Contact

(c)         Profile

(d)        Usage

(e)         Marketing and communications

(f)          Technical

Necessary for our Legitimate Interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a)         Technical

(b)        Usage

Necessary for our Legitimate Interests (to define types of customers for our products and services, to keep our website 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

(a)         Identity

(b)        Contact

(c)         Technical

(d)        Usage

(e)         Profile

(f)          Marketing and communications

Necessary for our Legitimate Interests (to develop our products/services and grow our business)

 

 

Marketing Communications

 

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

 

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 to you.

You will receive marketing communications from us if you have:

  • requested information directly from us or
  • purchased goods or services from us

And in each case, you have not opted out of receiving that marketing.

 

 

OPTING OUT

 

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.

 

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/service purchase, product/service experience or other transactions.

 

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.

 

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:

  • Service providers who provide IT, system administration, payment processor providers, live chat operators, enhanced web functionality, fulfilment and courier services.
  • Suppliers who operate direct ship services on our behalf.
  • Marketing services who produce and execute marketing campaigns and organisations such as Mailing Preference Service (MPS) who clean the mailing data we hold.
  • Professional advisers including lawyers, bankers, auditors and insurers
  • HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use; or to protect the rights, property, or safety of BrightMinds Ltd, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
  • Third parties to whom we sell, transfer, or merge parts of our business or our assets in which case personal data held by BrightMinds Ltd about its customers will be one of the transferred assets.

 

We may share your postal information (never telephone or email addresses) with third parties under the Legitimate Interest clause of the UK GDPR - For example we work with Epsilon Abacus (registered as Epsilon International UK Ltd), a company that manages the Abacus Alliance on behalf of UK retailers. We may share or sell postal information with third parties such as clothing, collectables, food & wine, gardening, financial services, gadgets & entertainment, health & beauty, household goods, and home interior companies for marketing or profiling purposes. We may also share postal information with other third parties such as charities directly. Please note that your data could also be sent outside the EEA (e.g. to the USA) for marketing and customer profiling purposes. If any data is transferred outside of the EEA, the relevant companies have provided assurances of appropriate safeguards being in place for the transfer (e.g. relevant companies in the USA are signed up to the Privacy Shield). If you do not want us to share your details with third parties for marketing purposes, you can opt out at any time by emailing info@brightminds.co.uk and request to be removed with ‘removal from third party’ in the subject line.

 

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing us at info@brightminds.co.uk.

 

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions. 

 

INTERNATIONAL TRANSFERS

 

 

Some of our third parties service providers are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

 

Whenever we transfer your personal data out of the UK, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:

 

  • We will only transfer your personal data to countries that have been approved as providing an adequate level of protection for personal data; or
  • 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 UK;

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time. 

 

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

 

DATA SECURITY

 

We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.

 

Sensitive and private data exchange between the Site and its Users happens over a EV SSL secured communication channel and is encrypted and protected with digital signatures. Our Site is also in compliance with PCI vulnerability standards in order to create as secure of an environment as possible for Users.

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.

 

DATA RETENTION

 

We will retain your personal data indefinitely to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of 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.

For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.

 

In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

 

YOUR LEGAL RIGHTS

 

Under data protection laws you have rights in relation to your personal data. These include the right to:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data. If you request your data to be deleted (that not required by our legal obligations) this may invalidate any product guarantees and mean that we can not comply with any wishes not to be communicated with in the future. This is because we occasionally purchase third party data which is usually de-duped against our suppression list ie those people who have withdrawn consent. If we do not hold your data on this list we can not remove you from the mailing.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Where the lawful ground of processing is consent, to withdraw consent. 

 

You can see more about these rights at:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

 

If you wish to exercise any of the rights set out above, please email us at info@brightminds.co.uk

 

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 or 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 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.

 

We try to respond to all legitimate requests within one month. Occasionally it may 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.

 

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

 

THIRD-PARTY LINKS

 

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections 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 statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

 

COOKIES

 

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see Cookie Policy

 

GLOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/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.

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.

THIRD PARTIES

Third Party Links

  • Service providers who provide IT and system administration services.
  • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities based in the UK who require reporting of processing activities in certain circumstances.
  • Service providers who may advertise on our website, including, for example, advertising networks and providers of external services like web traffic analysis services

YOUR LEGAL RIGHTS

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 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.
  • 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.

UPDATED 27th January 2021

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