Website Privacy Policy

BACKGROUND:

Bespoke Information, Advice and Solutions Limited 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 everyone who visits this website, https://biasltd.co.uk (“Our Site”) 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 carefully and ensure that you understand it. If you do not accept and agree with this Privacy Policy, you must stop using our Site immediately.

1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

“Account”

means an account required to access or use certain areas and features of our Site; and

“Cookie”

means a small text file placed on your computer or device by our Site when you visit certain parts of our Site or when you use certain features of our Site. Details of the Cookies used by our Site are set out in Part 14, below.

“Cookie Law”

“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003.

2. Information About Us

Our Site is owned and operated by Bespoke Information, Advice and Solutions Limited, a Limited Company registered in England and Wales under company number 12437909.

Registered address:

5 Barkby Road, Sheffield S9 1JX

VAT number:

GB342966673

3. What This Privacy Policy Covers

This Privacy Policy applies only to your use of our Site. 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. Personal Data Definition

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.

5. Your Rights

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

a)

The right to be informed about our collection and use of your personal data. This Privacy Policy 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 15.

b)

The right to access the personal data we hold about you. Part 13 will tell you how to do this.

c)

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 15 to find out more.

d)

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 15 to find out more.

e)

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

f)

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

g)

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.

h)

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.

i)

Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

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 15.

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 15.

6. Data We Collect and How We Collect It

Depending upon your use of our Site, 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. Please also see Part 14 and our Cookie Policy at https://biasltd.co.uk/cookie-policy for more information about our use of Cookies and similar technologies . We do not collect any ‘special category’ or ‘sensitive’ personal data or personal data relating to children or data relating to criminal convictions or offences.

Data Collected	How We Collect the Data
Identity Information including Name and/or Title.	Collected directly from yourself through various relevant contact forms on our site
Contact information including Address and/or Email Address and/or Telephone Number.	Collected directly from yourself through various relevant contact forms on our site
Business information including Business Name and/or Job Title and/or Profession.	Collected directly from yourself through various relevant contact forms on our site
Payment information including Card Details and/or Bank Account Details.	Depending on the transaction type, we may collect this data directly from yourself through relevant payment forms. However most transactions are carried out using our Payment Processors in which case Card or Account details are collected and processed by them and are not passed on to us.
Profile information including Preferences, Interests and Purchase History.	Preferences and Interests may be collected directly from yourself using relevant forms, surveys or quizzes, or may be inferred from analytics information. Purchase History data comes from the recording of business transactions between you and us.
Technical information including IP Address; Browser Type and Version; and Operating System.	This information is automatically sent by your browser to any website server that it connects to

7. How We Use Your 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:

What We Do	What Data We Use	Our Lawful Basis
Registering you on our Site.	Identity Information Contact information	Consent
Providing and managing your Account.	Identity Information Contact information Business information	Contract
Providing and managing your access to our Site.	Identity Information Technical information	Legitimate Interests – We need to ensure that all bona fide users, visitors and account holders can access the site with all relevant devices; and we have to manage and restrict access to anyone abusing our terms and conditions or the law.
Personalising and tailoring your experience on our Site.	Profile information Technical information	Consent
Administering Our Site.	Technical information	Legitimate Interests – We need to ensure that our site remains accessible to a full range of devices and browsers.
Administering Our Business.	Identity Information Contact information Business information Payment information	Legal Obligation and Legitimate Interests – Sound business practice mandates the collection, processing and organisation of all information relating to business transactions. The law requires certain information to be kept for a minimum of 6 years.
Supplying our products and services to you.	Identity Information Contact information Payment information	Contract
Managing payments for our products and services.	Identity Information Payment information	Contract
Personalising and tailoring our products and services for you.	Profile information Technical information	Consent
Communicating with you.	Contact information	Legitimate Interests – This item relates to communications of a transactional nature where you have purchased products or services from us; or where a contractual relationship exists between us
Supplying you with information by email that you have opted-in to. You may opt-out at any time by clicking the “Unsubscribe” link in all non-transactional emails sent by us.	Contact information	Consent – This item relates to communications that you have opted into, such as newsletters or marketing alerts.

With your permission and where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email with information, news, and offers on our products and 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 Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

Third Parties whose content appears on our Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.

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 15.

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.

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.

8. How Long We Keep Your 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. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

Type of Data	How Long We Keep It
Identity Information including Name and/or Title.	Until consent is withdrawn or until any contractual or legitimate interest basis expires
Contact information including Address and/or Email Address and/or Telephone Number.	Until consent is withdrawn or until any contractual or legitimate interest basis expires
Business information including Business Name and/or Job Title and/or Profession.	Until consent is withdrawn or until any contractual or legitimate interest basis expires
Payment information including Card Details and/or Bank Account Details.	Card and account details, where collected by us, will be kept until any relevant contract between us (for example recurring payments for ongoing services) expires. Where data is collected by 3rd party payment processors the data will be subject to their own Privacy and Data Protection policies. Payment information such as sums due and sums paid will be retained for as long as business accounting and taxation record keeping legislation requires
Profile information including Preferences, Interests and Purchase History.	Until consent is withdrawn or until any contractual or legitimate interest basis expires. Purchase History information may be anonymised and kept indefinitely for business planning purposes
Technical information including IP Address; Browser Type and Version; and Operating System.	Until consent is withdrawn or until any contractual or legitimate interest basis expires. Browser and OS information may be anonymised and kept indefinitely for business planning purposes

9. Storage or Transfer of Your Personal Data

We will only store your personal data within the UK. This means that it will be fully protected under the Data Protection Legislation.

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 the Information Commissioner’s Office where we are legally required to do so;

10. Sharing of Your Personal Data

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

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.

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.

11. Your Control of Personal Data

11.1

In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails.

11.2

You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

12. Withholding Information

You may access certain areas of our Site without providing any personal data at all. However, to use all features and functions available on our Site you may be required to submit or allow for the collection of certain data.

You may restrict our use of Cookies. For more information, see Part 14 and our Cookie Policy at https://biasltd.co.uk/cookie-policy.

13. Accessing Your 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”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15.

There is not normally any charge for a subject access request. However, 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.

14. How We Use Cookies

Our Site may place and access certain first-party Cookies on your computer or device.

First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of our Site and to provide and improve our products and services.

By using our Site you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, or parties other than us.

In addition, our Site uses analytics services provided by Google Analytics, which also use Cookies. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling us to better understand how people use our Site.

For more details, please refer to our Cookie Policy at https://biasltd.co.uk/cookie-policy.

15. How To Contact Us

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

dpo@biasltd.co.uk

Telephone

+44 (0) 114 438 0052

Postal Address

DPO, Bespoke Information, Advice & Solutions Ltd, 5 Barkby Road, Sheffield S9 1JX

or you can use an appropriate Form or Link as listed on our Contact Page at https://biasltd.co.uk/contact.

16. Changes to this Privacy Policy

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 immediately posted on our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of our Site following the alterations. We recommend that you check this page regularly to keep up-to-date. This Privacy Policy was last updated on 5 March 2021.