1.1 Purpose of this privacy notice

This privacy notice aims to give you information on how BGL Partners collects and processes your personal data through your use of this website, including any data you may provide through this website.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

1.2 Controller

BGL Partners is the controller and responsible for your personal data (referred to below as “we”, “us” or “our” in this privacy notice).

1.3  Changes to your personal data

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

1.4  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.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• Identity Data includes your name.
• Contact Data includes your address, email address and telephone numbers.
• 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.
• Usage Data includes information about how you use our website, products and services.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

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.

2.1. If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you request that we contact you.
• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
• Technical Data from the following parties:

• (a) analytics providers such as Google based outside the EU;
• (b) advertising networks; and
• (c) search information providers.

• Identity and Contact Data from data brokers or aggregators.
• Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in circumstances noted below.  We have used asterisks on the list to identify the lawful basis on which we rely when processing your personal information.

Where the information is needed to allow us to perform our contract with you, this is indicated by *.

Where we need the information to enable us to comply with legal obligations, this is shown by **.

In certain circumstances we may use your personal information to pursue legitimate interests of our own, provided your interests and fundamental rights do not override those interests. This is indicated by ***

• Where we need to perform or process any contract that we have entered into in respect of our services. This will typically require your name and address, the full details of the matter about which you have sought our advice or help, setting out how we work and agreeing fees with you.*
• Fulfilling your instructions.*
• The administration of our website and data management systems by our third party IT support company.**
• Carrying out routine “Know Your Client” checks. This may include a credit reference check and/or an identity check for money laundering compliance purposes.**
• Contacting you to inform you of other services you might be interested in. ***

Some of the above grounds for processing may overlap. Generally, we do not rely on consent as a legal basis for processing your personal data. If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you, or we may be prevented from complying with our legal obligations.

You may receive occasional industry-related updates from us.

You can ask us to stop sending you marketing information at any time by contacting us.

Cookies
Our website utilises cookies. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly.

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 we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We may have to share your personal data with third parties, including third-party service providers, in the following instances:

• If required to do so by law
• In order for us to administer our contract with you
• where we have another legitimate interest in doing so.

Primarily we will share your personal information with others who are involved in fulfilling your instructions. We may also need to share your personal information with another party, or their solicitors who may be involved.

Finally, we use a select group of third party service providers to enable us to provide services to you. In particular:

• Our IT services are provided by ITbuilder (www.itbuilder.co.uk). They have helped us develop a secure and robust IT infrastructure, so as to protect client data. They do have access to that data for the purposes of ensuring that our systems are properly maintained and backed up.

We require third parties to respect the security of your data and to treat it in accordance with the law.

We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

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. 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.

We do not transfer your personal data outside the European Economic Area (EEA).

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. Once this no longer applies we will securely destroy any personal information and data we hold

Under certain circumstances, you have rights under data protection laws in relation to your personal data.  These rights are as follows:

9.1. Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

9.2. Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected.

9.3. Request erasure of your personal data. This enables you to ask us to delete or remove personal information 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)

9.4. Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground.  You also have the right to object where we are processing your 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.

9.5. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data about you, for example if you want us to establish its accuracy or the reason for processing it.

9.6. Request the transfer of your personal information

9.7. 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.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

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.

What we may need from you

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.

 Time limit to respond

We will 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 several requests. In this case, we will notify you and keep you updated.

10.1. LAWFUL BASIS

• Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us
• Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
• Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

10.2. EXTERNAL THIRD PARTIES

• Service providers acting as processors who provide IT and system administration services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who may require reporting of processing activities in certain circumstances.

Any changes we may make to our privacy policy in the future will be posted on this page.

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to James Knott at jk@bglpartners.co.uk or in writing to BGL Partners, 120 Marylebone Lane, London, W1U 2QG.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.