PRIVACY POLICY

Blue Lights Digital Ltd. Privacy Notice

Date: 16 March 2020 (revised)

Background:

Blue Lights Digital 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 our customers 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.

Please read this Privacy Policy and our related Cookie Policy carefully and ensure that you understand it. If you have any question about it, please use the contact details below to let us know.

1) Information About Us

Blue Lights Digital is a limited company registered in England under company number 09430671.

Registered address: The Officers’ Mess, Royston Road, Duxford, Cambridge, CB22 4QH

VAT number: GB 213 9417 20

Data Protection Officer: Matt Service

Data Protection Help email address: ISMS@bluelightsdigital.com

We are registered with and regulated by the Information Commissioner’s Office.

2) Privacy for Children – 13 and Older Minimum Age

You must be at least 13 years old to use our Services. The minimum age to use our Services without parental approval may be higher in your home country. If you are under 13, please ask a parent or guardian to contact us so that we can ask for their permission to communicate with you.

What information about me do you ask for and why do you need it?

This is just a quick note to let you know how we handle the information you give us. We want to let you know that your information is safe with us.

Besides using cookies, which you were asked to accept or reject when you found our website, this website can collect personal information you choose to share through the use of the Intercomm chat button. We provide this communication tool for your convenience, as a way to engage with our customers, but we are careful to not collection personal or sensitive data this way. We suggest you keep information about yourself as private as possible. We don’t really need it so don’t give it to us.

How do you use my information?

At this time, any information you give us will only be used to communicate with you.

How do you look after information about me?

We keep it safe. We are GDPR compliant. This is the European law that is meant to keep personal information about you protected.

How long do you keep information about me for?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected.

You can ask us to delete it at any time.

Who do you share information about me with?

We sometimes uses other companies to help us. If we do that, we make sure they have the right agreements in place. Sometimes, we have to share information in special cases, like when the law requires us to.

3) Privacy for Adults

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. We have put a simpler version above for children just in case they did not scroll down this far.

For information regarding how this website uses Cookies, please see our Cookies Policy.

This Privacy Policy applies only to our use of your data. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

4) What is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) 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 6, below.

5) What Are My Rights?

Under the GDPR, you have the following rights, which we will always work to uphold:

  1. 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.
  2. The right to access the personal data we hold about you.
  3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete.
  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 have. Please contact us using the details in Part 13 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 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.

For more information about our use of your personal data or exercising your rights as outlined above, please see Parts 8 and 12 respectively.

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.

6) What Personal Data Do You Collect?

As outlined above the section for minors, besides using cookies, which you were asked to accept or reject when you found our website, this website can collect personal information about you if you choose to share it with us.

In the course of other business activities, not on this website, we may collect some or all of the following personal data.

  • Name;
  • Force/agency/business/company name;
  • Rank, title, position;
  • Contact information such as email addresses and telephone numbers;
  • Demographic information such as post code, preferences, and interests;
  • Financial information such as credit / debit card numbers (although we do not store these once the worldpay transaction is completed);

This may vary according to your relationship with us. If you are applying for training, we will ask you directly for the information we require and ask for your consent. However, your employment organisation or organisation framework provider may provide us with personal data when applying for training on your behalf. In this situation, we ask that they gain your consent or use a lawful collection basis.

Through our GDPR compliant website Cookie Pop-up, we also save your consent data. Consents are automatically collected through a secured SSL-connection and all consents are stored as strongly encrypted keys. The consent state is stored on a user’s browser as a persistent cookie with a JSON-formatted value that can also be read server side to evaluate the user’s consent before setting cookies. A user’s choice is retained for 12 months after which the banner will automatically pop up to renew a user’s consent.

An Intercom chat widget is available on our website for you to communicate with us. Intercom’s Privacy Policy https://www.intercom.com/terms-and-policies#privacy states that any information you submit this way is collected under the privacy policy of the owner of such Third-Party Property. We provide this communication tool for your convenience, as a way to engage with our customers, but we are careful to not collection personal or sensitive data this way.

7) How do partner organisations use data when you use our website (Cookies)

Google Analytics

As outlined in our Cookie Policy, our website uses google analytics. If you have not disabled cookies, and would like to understand how Google Analytics collects and processes data, please refer to their Privacy Policy: www.google.com/policies/privacy/partners

8) How Do You Use My Personal Data?

Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:

  • Providing, personalising and managing your access to our site;
  • Providing and managing your account;
  • Supplying our products and services to you. (We require your personal details in order to enter into a contract with you);
  • Personalising and tailoring our products and services for you;
  • Communicating with you. This may include responding to emails or calls from you;
  • Supplying you with information by email and/or post that you have opted-in to (you may unsubscribe or opt-out at any time by unsubscribing on links supplied);
  • Inviting you to events that have been arranged by your companies or organisations;
  • Processing necessary information for the performance of tasks carried out in the public interest or in the exercise of official authority vested in us by the authorised data controller.

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/or post with information, news, and offers on our products and/or services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

9) How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected.

Where credit/debit card payment is taken via our website, we use Stripe as our payment service. Secure single use payment tokens are issued by Stripe for each transaction. If you would like a receipt for the transaction, then the email address provided is stored securely in Stripe with the record of the payment transaction.

10) How and Where Do You Store or Transfer My Personal Data?

We currently only store or transfer your personal data in the UK or 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 GDPR or to equivalent standards by law.

If, in the future, we decide to store or transfer some or all of your personal data to countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein), we will take appropriate action as defined by law and best practice at the time of change.

Countries outside the UK and EEA are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we would take additional 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 GDPR.

Current Additional measures:

The security of your personal data is essential to us and we take important measures to protect it, including the following: Our data is held on cloud services which are architected to the NCSC Cloud security principles.

11) Do You Share My Personal Data?

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. We are careful to not share any of your personal data with any third parties for any other purposes without your consent or the consent of your organisation as long as they have the authority to provide it.

12) How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us or 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”. You can also request changes to incorrect data or ask us to delete data.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 13. We require two forms of government accepted forms of identification such as passport, driving licence or utility bill. At least one must be photographic. To make your request as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.

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.

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.

13) How Do I Contact You?

To contact us about anything to do with your personal data and data protection, please use the following details. To help us to attend to your query swiftly, it would be helpful to reference “data protection” in the subject header.

Email address: ISMS@bluelightsdigital.com

Postal Address: Blue Lights Digital Ltd – Data Protection Department, The Officers’ Mess, Royston Road, Duxford, Cambridge, CB22 4QH.

14) 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 in accordance with the law and best practice at the time of change.