We at BrightMinds respect your privacy. We only use the information we collect about you carefully, lawfully and in accordance with the Data Protection Act 1998, the EU General Data Protection Regulation (GDPR) and Privacy and Electronic Communications Regulations (PECR).
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
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).
Our full details are:
Full name of legal entity: BrightMinds Ltd
Data Protection Officer: Data Protection Guru
Email address: email@example.com
Postal address: Suite 8 Westfield Court, Third Avenue, Westfield Industrial Estate, Radstock, Bath, BA34XD
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 firstname.lastname@example.org
WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND WE PROCESS IT
Personal data means any information capable of identifying an individual. It does not include anonymised data.
We may process the following categories of personal data about you:
Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting, telephone calls or any other communication that you have with us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address, email address, phone number, contact details, purchase details. We do not retain or hold credit/debit card details and only process card payments through encrypted methods. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back-ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.
Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.
Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free give-aways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.
We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).
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.
We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at email@example.com In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
We do not carry out automated decision making.
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.
HOW WE COLLECT YOUR PERSONAL DATA
We may collect data 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.
Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below.
Technical Data from the following parties:
analytics providers such as Google based outside the EU;
advertising networks such as Google and Facebook based outside the EU;
Contact, Financial and Transaction Data from providers of technical, payment and delivery services which may be based outside the EU.
Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
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 between us.
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.
Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).
You will receive marketing communications from us if you have:
requested information directly from us or
purchased goods or services from us; or
been identified by our third party data suppliers as potentially being interested in our goods or services by post.
in each case, you have not opted out of receiving that marketing.
Under the Privacy and Electronic Communications Regulations (PECR),we may send you marketing communications from us if:
(i) you made a purchase or asked for information from us about our goods or services or
(ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since.
Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However you can still opt out of receiving marketing emails from us at any time.
If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, guarantee, safety recalls etc.
For purposes of quality control and training, calls and emails may be monitored and stored.
Our communications are designed to tell you about the benefits we can offer, so that you have exclusive access to our best deals. We use the information we have about you to tailor the content and try to ensure that our offers and those of third parties are as relevant to you as possible.
DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below:
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.
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 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 firstname.lastname@example.org 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 email@example.com.
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.
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
Some of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, 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:
If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place; or
We will only transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or
Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe;
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.
Epsilon Abacus may transfer data outside the EEA. The transfer will take place in the presence of appropriate safeguards, including standard data protection clauses adopted by the EU Commission.
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.
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.
Customers often return to us many years after buying for the first time and our suppression list ensures we do not contact you when you have opted out.
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 groundof processing is consent, to withdraw consent.
If you wish to exercise any of the rights set out above, please email us at firstname.lastname@example.org
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.
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.
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