This privacy notice is used inform you of how we collect and process any information that we collect from you, or that you provide to us. “Personal data” is defined by the ICO as “information that relates to an identified or identifiable individual” and information that could not. “Processing” is defined by the ICO as “collecting, recording, storing, using, analysing, combining, disclosing or deleting”.
This notice tells you about your privacy rights and how the law protects you.
This policy is effective from July 25, 2024.
Scope
We are committed to protecting your privacy and the confidentiality of your personal information. Our policy is not just an exercise in complying with the law, but a continuation of our respect for you and your personal information. We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
Our policy complies with the Data Protection Act 2018 accordingly incorporating the EU General Data Protection Regulation (GDPR) and The Personal Information Protection and Electronic Documents Act (PIPEDA). The law requires us to tell you about your rights and our obligations to you regarding the processing and control of your personal data. We do this now, by requesting that you read the information provided at http://www.knowyourprivacyrights.org
Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.
Data we process
We may collect, use, store and transfer different kinds of personal data about you. We have collated these into groups as follows:
- Personal Data
- Your identity includes information such as first name, last name, title, date of birth, and other identifiers that you may have provided at some time.
- Your contact information includes information such as billing address, delivery address, email address, telephone numbers and any other information you have given to us for the purpose of communication or meeting.
- Technical data includes your internet protocol (IP) address, 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.
- Special Category Data
- Special personal information is data 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 special personal information about you.
- Anonymised Data
- We may aggregate anonymous data such as statistical or demographic data for any purpose. Anonymous data is data that does not identify you as an individual. Aggregated data may be derived from your personal data but is not considered personal information in law because it does not reveal your identity.
Legal basis for processing
The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category. The legal bases for processing personal data are:
- The individual’s consent,
- Vital interests,
- Compliance that has a legal obligation,
- A contract with the individual,
- Legitimate interests, and
- A public task.
If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.
If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.
- Data processing with consent
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including job opportunities and our products and services, you provide your consent to us to process information that may be personal information.
Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to our use of cookies. We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by instructing us enquiries@bttcgroup.com. However, if you do so, you may not be able to use our website or our services further.
- Contractual obligations requiring data processing
When you contract us to provide a service, or otherwise agree to our terms and conditions, a contract is formed between you and us. In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.
We may use it in order to:
- Provide you with our services, and
- Improve the services we offer.
We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract. We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
- Data processing for legitimate interests
We may process information on the basis there is a legitimate interest, either to you or to us, of doing so. Where we process your information on this basis, we do so after having given careful consideration to:
- whether the same objective could be achieved through other means,
- whether processing (or not processing) might cause you harm,
- whether you would expect us to process your data, and
- whether you would, in the round, consider it reasonable to do so.
For example, we may process your data on this basis for the purposes of:
- record-keeping for the proper and necessary administration of our business,
- responding to unsolicited communication from you to which we believe you would expect a response,
- protecting and asserting the legal rights of any party,
- insuring against or obtaining professional advice that is required to manage business risk, or
- protecting your interests where we believe we have a duty to do so.
- Legal obligations for processing
Sometimes, we must process your information in order to comply with a statutory obligation.
For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.
This may include your personal information.
How we use your personal data
- Job applications and employment
If you send us information in connection with a job application, we may keep it for up to three years in case we decide to contact you at a later date.
If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for six years before destroying or deleting it.
- Complaints regarding content on our website
If you complain about any of the content on our website, we shall investigate your complaint.
If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate.
Free speech is a fundamental right, so we have to make a judgment as to whose right will be obstructed: yours, or that of the person who posted the content that offends you.
If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.
- Communicating with us
When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need.
We record your request and our reply in order to increase the efficiency of our business.
We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high-quality service.
- Complaints
When we receive a complaint, we record all the information you have given to us. We use that information to resolve your complaint.
We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.
- Automated processing
- Cookies
Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit websites. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.
Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.
Your web browser allows you to delete any you choose. It also should allow you to prevent or limit their use.
Our website uses cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use. We use cookies in the following ways:
- to track how you use our website, and
- to record whether you have seen specific messages we display on our website.
- Personal identifiers from your browsing activity
Requests by your web browser to our servers for web pages and other content on our website are recorded.
We record information such as your geographical location, your Internet Service Provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed into our website.
Disclosure and sharing of your information
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- Data processing outside the European Union
Our websites are hosted in the European Union.
Our cloud storage solution for holding personal data is based in the European Union.
Control over your own information
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- Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes.
- Access to your Personal Information
At any time you may review or update personally identifiable information that we hold about you, by requesting this by email to enquiries@bttcgroup.com.
All requests will be responded to within 30 days of receiving the access request, unless the request is complex, or if you have made a high number of requests. We will communicate any delay caused by these reasons without delay.
All access requests will be responded to at no cost to you, unless a request is ‘manifestly unfounded or excessive’. In this case, we can charge a reasonable fee to deal with the request or refuse to provide information at all. In these cases, we will communicate this decision to you and agree fees before commencing the access request.
- Removal of your information
If you wish us to remove personally identifiable information from our website, you should contact us at enquiries@bttcgroup.com to make your request. This may limit the service we can provide to you.
- Verification of your identity
When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
How you can complain
If you are not happy with our privacy policy or if you have any complaint then you should tell us at enquiries@bttcgroup.com.
If a dispute is not settled, we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office (ICO) or with The Office of the Privacy Commissioner of Canada (OPC). This can be done at https://ico.org.uk/make-a-complaint or https://www.priv.gc.ca/en/report-a-concern/file-a-formal-privacy-complaint/. We would, however, appreciate the opportunity to talk to you about your concern before you approach the ICO or OPC.
Compliance with the law
Our privacy policy has been compiled so as to comply with the law of every country or legal jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, we should like to hear from you at enquiries@bttcgroup.com.
Review of this privacy policy
We may update this privacy notice from time-to-time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.
If we make a change to this policy which may impact your privacy, we will inform you that it has been updated.
If you have previously given us consent to process your data, we will ask you to provide new consent if our new policy impacts on the way we process your data.