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BACKGROUND:

 

Bressenden Associates Ltd understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our clients and contacts and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

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Information About Us

Bressenden Associates Ltd.

Limited company registered in England under company number 12616070.

Registered address: 12 Brierley Road, Balham, England, SW12 9NA.

VAT number: 351936586.

 

Email address: info@bressendenassociates.com

Telephone number: +1 (0) 917 675 3240

Postal address: Bressenden Associates, 12 Brierley Road, Balham, England, SW12 9NA

 

1. What Does This Notice Cover?

This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

 

2. What Is Personal Data?

Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The personal data that we use is set out in Part 5, below.

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3. What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

1. The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.

2. The right to access the personal data we hold about you. Part 10 will tell you how to do this.

3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.

4. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 11 to find out more.

5. The right to restrict (i.e. prevent) the processing of your personal data.

6. The right to object to us using your personal data for a particular purpose or purposes.

7. The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.

8. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

9. Rights relating to automated decision-making and profiling. Part 6 explains more about how we use your personal data, including automated decision-making  and profiling.

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For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 11.

 

4. What Personal Data Do You Collect and How?

We may collect and hold some or all of the personal data set out in the table below, using the methods also set out in the table. We do not collect any ‘special category’ or ‘sensitive’ personal data, or personal data relating to children or data relating to criminal convictions and/or offences.

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5. How Do You Use My Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:

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What we use your personal information for

What personal information we collect

Our legal grounds for processing

Our legitimate interests

(if applicable)

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To register you as a new client

Identity data, Contact data, Financial data, Marketing and communications data

Performance of a contract with you, Our legitimate interests, Your consent

Keeping our records up to date, working out which of our services may interest you and telling you about them

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To manage our relationship with you or your business

Identity data, Contact data, Marketing and communications data

Performance of a contract with you, Our legitimate interests

Being efficient about how we fulfil our legal and contractual duties

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To study how our clients use our services including submitting surveys

Identity data, Contact data, Marketing and communications data

Our legitimate interests, Our legal duty, Your consent

Developing services, and what we charge for them, Defining types of clients for new services, To study how clients use our services, to develop them, to promote and grow our business and to inform our marketing strategy

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To communicate with you about our services

Identity data, Contact data, Marketing and communications data

Your consent, Our legitimate interests

Keeping our records up to date, working out which of our services may interest you and telling you about them, Developing services, and what we charge for them, To assess the health of our relationships with business contacts

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To manage relationships with our business contacts

Identity data, Contact data, Marketing and communications data

Your consent, Our legitimate interests

Keeping our records up to date, working out which of our services may interest you and telling you about them, Developing services, and what we charge for them, To assess the health of our relationships with business contacts

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To administer and protect our business and our website

Usage data, Technical data

Fulfilling contracts, Our legitimate interests

Being efficient about how we fulfil our legal and contractual duties

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To use data analytics to improve our website, services, marketing, client relationships and experiences

Usage data

Performance of a contract with you, Our legitimate interests

Being efficient about how we fulfil our legal and contractual duties

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To exercise our rights set out in agreements or contracts

Identity data, Contact data, Financial data

Performance of a contract with you, Our legitimate interests

Being efficient about how we fulfil our legal and contractual duties

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To run our business in an efficient and proper way. This includes managing our financial position, business capability, planning, adding and testing systems and processes, managing communications, corporate governance, and audit

Identity data, Contact data, Financial data

Our legitimate interests, Our legal duty

Complying with rules and guidance from regulators, Being efficient about how we fulfil our legal and contractual duties

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To manage payments and collect and recover money that is owed to us

Identity data, Contact data, Financial data

Performance of a contract with you, Our legitimate interests

Being efficient about how we fulfil our legal and contractual duties, Complying with rules and guidance from regulators

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To develop new ways to meet our clients’ needs and to grow our business

Identity data, Contact data, Financial data, Marketing and communications data

Performance of a contract with you, Our legitimate interests, Our legal duty

Developing products and services, and what we charge for them, Defining types of clients for new services, Being efficient about how we fulfil our legal and contractual duties

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With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone, text message and post with information, news, and offers on our products and services. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

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We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 11.

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If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

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In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

 

6. How Long Will You Keep My Personal Data?

We will retain your personal information for as long as required to perform the purposes for which the data was collected, depending on the legal basis for which that data was obtained and/or whether additional legal/regulatory obligations require us to retain it.

 

In general terms, this will mean that your personal information will be kept for the duration of our relationship with you and:

 

the period required by tax and company laws and regulations; and

 

as long as it is necessary for you to be able to bring a claim against us and for us to be able to defend ourselves against any legal claims. This will generally be the length of the relationship plus the length of any applicable statutory limitation period under local laws.

 

 

7. How and Where Do You Store or Transfer My Personal Data?

We will only store your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the EU GDPR and/or to equivalent standards by law. Transfers of personal data to the EEA from the UK are permitted without additional safeguards.

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

• limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;

• procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are  legally required to do so.

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7. Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.

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If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.

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In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

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We may sometimes contract with the following third parties to supply services.

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Recipient

Activity Carried Out

Sector

Location

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Customers with whom we are contracted to provide marketing services and with whom we have appropriate data sharing agreements in place

Outsourced marketing services

Consulting & Services

The United Kingdom

The United States of America

Countries in the EU or EEA

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If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.

If any personal data is transferred outside of the UK, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 8.

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If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.

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In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

 

8. How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

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All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11.

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There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

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We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

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9. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:

Email address: info@bressendenassociates.com

Telephone number: +1 (0) 917 675 3240

Postal Address: Bressenden Associates, Brierley Road, SW12 9NA

10. Changes to this Privacy Notice

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be made available  on our website

This Privacy Notice was last updated on November 2021.