Privacy Policy

  • July 27, 2018

Introduction

We may have to collect and use information about people with whom we work.  This personal information must be handled and dealt with properly, however it is collected, recorded and used, and whether it be on paper, in computer records or recorded by any other means.

We regard the lawful and correct treatment of personal information as very important to our successful operation and to maintaining confidence between us and those with whom we carry out business.  We will ensure that we treat personal information lawfully and correctly.

To this end we fully endorse and adhere to the principles of the General Data Protection Regulation (GDPR).

This policy applies to the processing of personal data in manual and electronic records kept by us in connection with our human resources function as described below. It also covers our response to any data breach and other rights under the GDPR.

This policy applies to the personal data of job applicants, existing and former employees, apprentices, volunteers, placement students, workers and self-employed contractors. These are referred to in this policy as relevant individuals.

Definitions

Personal Information is information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Data processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

We collect personal information from you when you use our Services.

Data protection principles

Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we will ensure that:

  1. processing will be fair, lawful and transparent
  2. data be collected for specific, explicit, and legitimate purposes
  3. data collected will be adequate, relevant and limited to what is necessary for the purposes of processing
  4. data will be kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay
  5. data is not kept for longer than is necessary for its given purpose
  6. data will be processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures
  7. we will comply with the relevant GDPR procedures for international transferring of personal data

Types of data held

We keep several categories of personal from you and any devices (including mobile devices) you use when you: use our Services, register for an account with us, provide us information on a web form, update or add information to your account, participate in a community board discussion chat, or when you otherwise correspond with us.

We may also collect personal information from other sources, as described below.

  1. Personal information we collect automatically when you use our Services or register for an account with us
    • We collect information about your interaction with our Services and your communications with us. This is information we receive from devices (including mobile devices) you use when you access our Services. This information could include the following: Device ID or unique identifier, device type, ID for advertising and a unique device token.
    • Location information, including location information from your mobile device. Keep in mind that most mobile devices allow you to control or disable the use of location services by any application on your mobile device in the device’s settings menu.
    • Computer and connection information such as statistics on your page views, traffic to and from the sites, referral URL, ad data, your IP address, your browsing history and your web log information.
  2. Personal information we collect using cookies and similar technologies
    • We use cookies, unique identifiers and similar technologies to collect information about the pages you view, the links you click and other actions you take when using our Services, within our advertising or email content.
    • For more information about our use of these technologies, and how to control them, see Cookies Policy.

Data disclosures

The Company may be required to disclose certain data/information to any person. The circumstances leading to such disclosures include:

  1. the right to be informed about the data we hold on you and what we do with it;
  2. the right of access to the data we hold on you. More information on this can be found in the section headed “Access to Data” below and in our separate policy on Subject Access Requests”;
  3. the right for any inaccuracies in the data we hold on you, however they come to light, to be corrected. This is also known as ‘rectification’;
  4. the right to have data deleted in certain circumstances. This is also known as ‘erasure’;
  5. the right to restrict the processing of the data;
  6. the right to transfer the data we hold on you to another party. This is also known as ‘portability’;
  7. the right to object to the inclusion of any information;
  8. the right to regulate any automated decision-making and profiling of personal data.

More information can be found on each of these rights in our separate policy on employee rights under GDPR.

Responsibilities

In order to protect the personal data of relevant individuals, those within our business who must process data as part of their role have been made aware of our policies on data protection.

We have also appointed employees with responsibility for reviewing and auditing our data protection systems.

Lawful bases of processing

We acknowledge that processing may be only be carried out where a lawful basis for that processing exists and we have assigned a lawful basis against each processing activity.

Where no other lawful basis applies, we may seek to rely on the employee’s consent in order to process data.

However, we recognise the high standard attached to its use. We understand that consent must be freely given, specific, informed and unambiguous. Where consent is to be sought, we will do so on a specific and individual basis where appropriate. Employees will be given clear instructions on the desired processing activity, informed of the consequences of their consent and of their clear right to withdraw consent at any time.

Access to data

As stated above, employees have a right to access the personal data that we hold on them. To exercise this right, employees should make a Subject Access Request. We will comply with the request without delay, and within one month unless, in accordance with legislation, we decide that an extension is required. Those who make a request will be kept fully informed of any decision to extend the time limit.

No charge will be made for complying with a request unless the request is manifestly unfounded, excessive or repetitive, or unless a request is made for duplicate copies to be provided to parties other than the employee making the request. In these circumstances, a reasonable charge will be applied.

Further information on making a subject access request is contained in our Subject Access Request policy.

Data disclosures

The Company may be required to disclose certain data/information to any person. The circumstances leading to such disclosures include:

  1. Third party service providers who help us to provide our Services, assist us in providing customized advertising, to assist us with the prevention, detection, mitigation, and investigation of potentially illegal acts, violations of our User Agreement, fraud and/or security breaches, bill collection, transportation, co-branded credit cards and other business operations.
  2. Law enforcement, legal proceedings and as authorized by law
    • To comply with our legal requirements, enforce our User Agreement, respond to claims that a listing or other content violates the rights of others, or protect anyone’s rights, property or safety.
    • To third parties involved in a legal proceeding, if they provide us with a subpoena, court order or substantially similar legal basis, or we otherwise believe in good faith that the disclosure of information is necessary to prevent imminent physical harm or financial loss or to report suspected illegal activity.

These kinds of disclosures will only be made when strictly necessary for the purpose.

Ways you can access, control, and correct your personal information

We respect your right to access, correct, request deletion or request restriction of our usage of your personal information as required by applicable law. We also take steps to ensure that the personal information we collect is accurate and up to date.

You have the following rights in relation to the personal data we hold on you:

  • the right to be informed about the data we hold on you and what we do with it;
  • the right of access to the data we hold on you;
  • the right for any inaccuracies in the data we hold on you, however they come to light, to be corrected. This is also known as ‘rectification’;
  • the right to have data deleted in certain circumstances. This is also known as ‘erasure’;
  • the right to restrict the processing of the data;
  • the right to transfer the data we hold on you to another party. This is also known as ‘portability’;
  • the right to object to the inclusion of any information;
  • the right to regulate any automated decision-making and profiling of personal data.

Data security 

We protect your personal information using technical and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration.

Where data is computerised, it should be coded, encrypted or password protected both on a local hard drive and on a network drive that is regularly backed up. If a copy is kept on removable storage media, that media must itself be kept in a locked filing cabinet, drawer, or safe.

Third party processing

Where we engage third parties to process data on our behalf, we will ensure, via a data processing agreement with the third party, that the third party takes such measures in order to maintain the Company’s commitment to protecting data.

International data transfers

Our business may require us to transfer your Personal Data to countries outside of the European Economic Area (“EEA”), including to countries that may not provide the same level of data protection as your home country such as China. We take appropriate steps to ensure that recipients of your Personal Data are bound to duties of confidentiality and we implement appropriate measures to ensure your Personal Data will remain protected in accordance with this Privacy Policy.

Use of cookies

Cookies are small text files that are sent to your PC, mobile phone or tablet when you visit a website. They stay on your device and are sent back to the website they came from when you visit it again.

Cookies are used by our website to make your experience more efficient by:

  • Recognising when you log in and any preferred settings.
  • Giving you a browsing experience that is unique to you which we believe improves your site experience.
  • Analyzing how you use our website and our services, so we can improve them.

How do we use cookies?

We and third parties may use cookies and tracking technologies to collect information from websites, Applications, and other online services for a variety of reasons, such as to enable us to improve your experience of the services, to understand how users interact with our online services and advertisements, and to deliver advertising. For example, we use these technologies to allow us to know when and for how long you use our services, and to remember your preferences and settings and other functionality you have requested. We and third parties may use the technologies to link your activities across the devices you may use. This helps us learn about how you use the services and enables us to provide you with a seamless experience across your devices. We may also use cookies and tracking technologies to deliver advertising and marketing messages that we think may be relevant to you based on your online activities over time, across the various devices you may use, and across third-party services– a common practice across the internet and known as interest-based advertising or behavioral advertising.

  1. Strictly Necessary Cookies

These cookies enable services you have specifically asked for. For those types of cookies that are strictly necessary, no consent is required. These cookies are essential in order to enable you to move around the Website and use it features, such as accessing secure areas of the Website. Without these cookies services you have asked for, like shopping baskets or e-billing, cannot be provided.

  1. Performance Cookies

These cookies collect information about how you use our websites — for instance, which pages you go to most. This data may be used to help optimize our websites and make them easier for you to navigate. These cookies are also used to let affiliates know if you came to one of our websites from an affiliate and if your visit resulted in the use or purchase of a product or service from us, including details of the product or service purchased. These cookies don’t collect information that identifies you. All information these cookies collect is aggregated and therefore anonymous.

  1. Functionality Cookies

These cookies allow our websites to remember choices you make while browsing. For instance, we may store your geographic location in a cookie to ensure that we show you our website localized for your area. We may also remember preferences such as text size, fonts, and other customizable site elements. They may also be used to keep track of what featured products or videos have been viewed to avoid repetition. The information these cookies collect will not personally identify you, and they cannot track your browsing activity on non-BCEGI websites.

  1. Third Party Cookies

This website uses a number of supplies who also set cookies on our website on our behalf in order to deliver the services that they are providing.

How do you change cookie preferences or block cookies?

You can at any time change or withdraw your consent from the Cookie Declaration on our website. Different browsers make different controls available to you. For further information to manage cookies on popular browsers please refer to: https://www.aboutcookies.org/how-to-delete-cookies/