This privacy notice provides you with details of how we collect and process your personal data through your use of our site www.brightethics.com including any information you may provide through our site or sign up forms.
Bright Ethics is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
Identity and contact details of the controller and where applicable, the controller’s representative) and the data protection officer:
Data Protection Officer: Bethan Vincent
1. WHAT DATA DO WE COLLECT ABOUT YOU
We may process certain types of personal data about you:
* Identity Data - your first name, last name, business name, business description
* Contact Data - your contact number, email address and business social media profiles
* Transaction Data - details about payments between us and other details of purchases made by you.
* Technical Data- login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.
* Usage Data - information about how you use our website, products and services.
* Marketing and Communications Data - your preferences in receiving marketing communications from us and our third parties and your communication preferences.
We may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your Usage Data to work out the percentage of website users using a specific feature of our site. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.
2. HOW WE COLLECT YOUR PERSONAL DATA
We collect data about you through a variety of different methods including:
Direct interactions: You may provide data by filling in forms on our site (or otherwise) or by communicating with us by post, phone, email or otherwise, including when you:
* make an equiry
* subscribe to our service or publications;
* request resources or marketing be sent to you;
* give us feedback.
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, server logs and similar technologies. We may also receive Technical Data about you if you visit other websites that use our cookies.
Technical Data from the following parties:
* Analytics providers such as Google based outside the EU;
3. HOW 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 our business function - this data may be shared with selected third-parties in order to perform our business relationship 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 ground for processing your personal data, other than in relation to sending marketing communications to you via email.
You have the right to withdraw consent to marketing at any time by emailing us at firstname.lastname@example.org or by clicking the Unsubscribe button at the bottom of every Newsletter.
Purposes for processing your personal data
Please email us at email@example.com if you need details about the specific legal ground we are relying on to process your personal data.
You will receive marketing communications from us if you have:
* signed up to our mailing lists and have given explicit permission for us to contact you (double opt-in)
Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a service purchase, service experience or other transactions.
Your data will be processed by us and our representatives when it is necessary to perform a contract we have with you.
Our main representative in the UK is:
The Centre for Assessment, Lee House, 90, Great Bridgewater St, Manchester M1 5JW
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 find out more about how the processing for the new purpose is compatible with the original purpose, please email us at firstname.lastname@example.org
If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
4. DISCLOSURES OF YOUR PERSONAL DATA
* Service providers who provide IT and system administration services.
* External organisations or individuals we use to perform accreditation services (part of our business contract with you).
* 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 United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
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.
5. INTERNATIONAL TRANSFERS
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.
Many 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 implemented:
Please email us at email@example.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
6. DATA SECURITY
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 such data. 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.
7. DATA RETENTION
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.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances, you can ask us to delete your data: see below for further information.
In some circumstances, we may anonymise your 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 notice to you.
8. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws 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.
* Object to processing of your personal data.
* Request restriction of processing your personal data.
* Request transfer of your personal data.
* Right to withdraw consent.
You can see more about these rights at:
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. Alternatively, we may refuse to comply with your request in these circumstances.
9. 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.
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