Introduction
Bridgeeleven Limited (the Company) respects your privacy and is committed to protecting your personal data. This privacy policy will inform you how the Company uses the personal data we collect from you when you use our website and services.
(1) Definition of personal data
Personal data is given the definition of any information that relates to an identified or identifiable living individual. Different pieces of information, which collected together can lead to the identification of a particular person, also constitute personal data.
(2) Control and processing of your personal data
The Company determines why and how your personal data will be processed and controlled.
(3) What data may be collected
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
(a) Identity Data – includes first name, maiden name, last name, username or similar identifier, title, date of birth and gender;
(b) Contact Data – includes billing address, email address and telephone numbers;
(c) Transaction Data – includes details about payments to and from you and other details of services you have purchased from the Company;
(d) Technical Data – includes 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;
(e) Usage Data – includes information about how you use our website and services;
(f) Marketing and Communications Data – includes your preferences in receiving marketing from us and your communication preferences.
We do not collect any special categories of personal data about you (this 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). Nor do we collect any information about criminal convictions and offences.
(4) How do we collect your data
We use different methods to collect data from and about you including through:
(a) Direct Interactions – you may give us your Identity, Contact and Financial Data by filing in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
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- request or apply for our services;
- voluntarily complete a customer survey;
- give us feedback or contact us.
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(b) Automated Technologies or Interactions – as you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
(5) How we will use your data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances (the Permitted Purposes):
(a) to verify your identity and register you as a client;
(b) to respond to any queries or feedback you may have;
(c) to process and deliver your order, including, (i) managing payments, fees and charges, and (ii) collecting and recovering money owed to us;
(d) to manage our relationship with you which includes notifying you about changes to our terms or privacy policy and asking you to leave a review or take a survey;
(e) to deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you;
(f) to use data analytics to improve our website, services, marketing customer relationship and experiences;
(g) to make suggestions and recommendations to you about services that may be of interest to you;
(h) where it is required for the purpose of providing our services, as well as for administrative, billing and other business purposes;
(i) where we need to perform the contract we are about to enter into or have entered into with you;
(j) when our Company processes your order, it may send your data to, and also use the resulting information from, credit reference agencies to prevent fraudulent purchases;
(k) 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;
(l) where we need to comply with a legal obligation;
(m) we may also utilise aggregated personal data and statistics to track website usage in order to improve our website and services.
(6) Refusal to provide your personal data
Generally, we obtain your personal data when you voluntarily provide it, and there are usually no negative implications if you refuse to provide it or allow it to be processed. However, there are some situations in which we will be unable to provide our services without obtaining such information.
If we are unable to provide you with what you request without the required personal data, we will notify you.
(7) Legal basis for processing your personal data
We may process your personal data on one or more of the following legal grounds, depending on which of the above Permitted Purposes we use it for:
Consent
Where we ask for your consent to process your personal data.
Contractual obligation
Where the data is required for the fulfilment of the contract we have with you, or to take the necessary actions at your request prior to entering into a contract.
Legitimate interest
When processing is required to pursue the Company’s or a third party’s legitimate interest.
Legal obligation
The Company is required to carry out the processing to comply with legal or regulatory requirements
(8) How we store and protect your personal data
We take suitable technical and organisational steps to keep your personal data confidential and secure.
We may store your personal information in electronic systems, third-party systems, and paper files
(9) Marketing
Our Company may send you information about services of ours that we believe they may be of interest to you. If you have agreed to receive marketing, you may always opt-out at a later date.
You have the right at any time to stop our Company from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, please contact us to let us know.
(10) Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to 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.
(11) Your rights to your personal data
Our Company would like to make sure you are fully aware of all your data protection rights. Every used is entitled to the following:
Right to Access
You have the right to request access to your personal data. This enables you to receive a comply of the personal data we hold about you and to check that we are lawfully processing it. We may charge you a small fee for this.
Right to Rectification
You have the right to 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.
Right to Erasure
You have the right to 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.
Right to Object Processing
You have the right to 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 you 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.
Right of Restriction of Processing
You have the right to request restriction of processing of your 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 accuracy of the data.
- 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.
Right to Data Portability
You have the right to 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.
Right to Withdraw Consent
You have the right to 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.
Complaint Submission
You have the right to file a complaint if you have concerns with how we are managing your data.
Please contact us at [email protected] if you wish to exercise any of the rights set out above.
We may require you to verify your identity in order to process your request. This is to safeguard the personal data we hold and that the data is adequately protected from unauthorised access requests and that we meet our security requirements.
We will respond to your request, or request for additional information from you within one month. In the event of a particularly complex or multiple requests, it may take us longer than one month. In this case, we will notify you within one month of the receipt of your request about the extension and keep you updated.
The Company may charge you a reasonable fee when a request is manifestly unfounded, excessive or repetitive, or we receive a request to provide further copies of the same data. In this case we will send you a fee request which you will have to accept prior to us processing your request. Alternatively, we may refuse to comply with your request in these circumstances.
(12) Disclosure of your personal data
We will not disclose your personal data, except:
(a) in the context of providing its services to you or your organisation with other third parties, including, prospective employers, recruitment agencies, other specialist service providers, our own legal and/or other advisors, other service providers (e.g. customer relationship management systems, online storage centres, cloud service providers and statistics monitoring;
(b) where we are required to do so by law or where it is necessary for the purpose of, or in connection with legal proceedings or in order to exercise or defend legal rights;
(c) upon your instructions or your express consent.
We may also share your personal data with any third party to whom we assign or novate any of our rights or obligations.
(13) Personal data about other persons that we collect from you
In the event you provide us with the personal data of others, such as your employees or employer, company directors or other people with whom you do business, you must ensure that you have the authority to disclose that data to us and that we can collect, use , and disclose that data in the ways described in this privacy policy without taking any additional steps. More specifically, you must ensure that the individual whose personal data you are sharing with us is aware of the information provided in this privacy policy, as it pertains to that individual, such as our identity, how to contact us, the purposes for which we collect data, or disclosure practices, and the individual’s rights in relation to our data holding.
(14) Personal data of children
Our website and services are not intended for individuals under the age of 16 and we do not knowingly collect data relating to individuals under the age of 16. If we become aware that an individual under the age of 16 has provided us with personal data, we will take steps to delete such data.
(15) Personal data transfer abroad
To provide our services, we may need to transfer your personal data abroad if required to do so for the Permitted Purposes. In some situations, this may include transferring data to jurisdictions that may not provide the same level of protection as your home country’s regulations (for example, the EU/EAA data protection legislation).
When making such transfers, we will ensure that they are subject to appropriate safeguards in accordance with the General Data Protection Regulation (Regulation 2016/679) or other relevant data protection legislation. This may include entering into the EU Commission’s Standard Contractual Clauses.
(16) What are cookies
Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. When you visit our website, we may collect information from you automatically through cookies or similar technology.
For further information, please visit www.allaboutcookies.org
(17) How do we use cookies
Our Company uses cookies for functionality and advertising purposes to understand how you use our website and to improve your experience on our website.
(18) What types of cookies do we use
There are a number of different types of cookies, however, our website uses:
(a) Functionality – our Company uses these cookies so that we recognize you on our website and remember your previously selected preferences. This could include what language you prefer and location you are in.
(b) Advertising – our Company uses these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, devise, and your IP address. Our Company may share some limited aspects of this data with third parties for advertising purposes. We may also share online data collected through cookies with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our website.
(c) Always Active – our Company uses these cookies to enable the basic features of this site, such as providing secure log-in or adjusting your consent preferences. These cookies do not store any personally identifiable data.
(d) Analytics – our Company uses these cookies to understand how visitors interact with the website. These cookies help provide information on metrics such as the number of visitors, bounce rate, traffic source, etc.
(e) Performance – our Company uses these cookies to understand and analyse the key performance indexes of the website which helps in delivering a better user experience for the visitors.
(19) How to manage cookies
You can set your browser not to accept cookies, and the above website provides information as to how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.
(20) 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 we are not responsible for their privacy statements. Our privacy policy applies only to our website, so if you click on a link to another website, you should read their privacy policy.
(21) Changes to our privacy policy
The last time this privacy policy was updated was 14 November 2022. We reserve the right to amend the contents of this privacy policy at any time to reflect changes in the way we process your personal data or to reflect changes in the relevant legal framework. If there are any changes, we will update our privacy policy on our website. The changes will become effective as soon as the amended version is published on our website.
(22) Complaints
We encourage you to contact us first if you have any concerns or complaints about the Company’s processing of your data, as we seek to satisfactorily resolve any concerns or complaints you may have concerning the Company’s processing of your personal data.
Email: [email protected]
You can, however, report any concerns directly to the Office of the Commissioner for Personal Data Protection, where you can also learn more about your rights under applicable data protection law and file a formal complaint.
Email: [email protected]
Tel: +357 22 818 456
