1. Introduction

1.1       We are committed to safeguarding the privacy of our clients, website visitors and sales community.

1.2       This policy applies where we are acting as a data controller with respect to the personal data of our clients, website visitors and sales community; in other words, where we determine the purposes and means of the processing of that personal data.

1.3       We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.

1.4       Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information. You can change your privacy controls by emailing info@sbrconsulting.com.

1.5       In this policy, “we”, “us” and “our” refer to SBR Consulting. [For more information about us, see Section 13.]

  1. How we use your personal data

2.1       In this section we have set out:

(a)        The general categories of personal data that we may process;

(c)        The purposes for which we may process personal data; and

(d)       The legal bases of the processing.

2.2       We may process data about your use of our website and services (“usage data“). The usage data may include referral source. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is consent OR our legitimate interests, namely monitoring and improving our website and services.

2.3       We may process your account data (“account data“). The account data may include your name and email address. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.4       We may process your information included in your personal profile on our website (“profile data“). The profile data may include your name, telephone number, email address and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at you request, to enter into such a contract.

2.5       We may process your personal data that are provided in the course of the use of our services (“service data“). The service data may include your employment details. The source of the service data is you or your employer. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.6       We may process information that you post for publication on our website or through our services (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.7       We may process information contained in any enquiry you submit to us regarding services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing relevant services to you. The legal basis for this processing is consent.

2.8       We may process information relating to our customer relationships, including customer contact information (“customer relationship data“). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our services to clients. The legal basis for this processing is consent OR our legitimate interests, namely the proper management of our customer relationships.

2.9       We may process information relating to transactions, including purchases of services, that you enter into with us and/or through our website (“transaction data“). The transaction data may include your contact details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.

2.10    We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.11    We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

2.13    Please do not supply any other person’s personal data to us, unless we prompt you to do so.

  1. Providing your personal data to others

3.1       We will never disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insurers and/or professional advisers, suppliers or subcontractors or any third party insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy. Information about our group of companies can be found at http://southwestern.com.

3.2       Financial transactions relating to our website and services are handled by our financial controller. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.

3.3       In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

  1. International transfers of your personal data

4.1       In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

4.2       We and our other group companies have offices and facilities in the United States of America and Singapore. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.

4.3       The hosting facilities for our website are situated in Bulgaria. The European Commission has made an “adequacy decision” with respect to having the same data protection laws. Transfers to this country will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.

4.5       You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

  1. Retaining and deleting personal data

5.1       This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

5.2       Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

5.3       In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:

(a)        The period of retention of your personal data will be determined based on inactivity.

5.4       Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

  1. Amendments

6.1       We may update this policy from time to time by publishing a new version on our website.

6.2       You should check this page occasionally to ensure you are happy with any changes to this policy.

6.3       We will notify you of significant changes to this policy by email.

  1. Your rights

7.1       In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

7.2       Your principal rights under data protection law are:

(a)        The right to access;

(b)       The right to rectification;

(c)        The right to erasure;

(d)       The right to restrict processing;

(e)        The right to object to processing;

(f)        The right to data portability;

(g)       The right to complain to a supervisory authority; and

(h)       The right to withdraw consent.

7.3       You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

7.4       You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

7.5       You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

7.6       To the extent that the legal basis for our processing of your personal data is:

(a)        Consent; or

(b)       That the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

And such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

7.7       If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

7.8       To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

7.9       You may exercise any of your rights in relation to your personal data by written notice to us.

  1. About cookies

8.1       A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

8.2       Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

8.3       Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

  1. Cookies that we use

9.1       We use cookies for the following purposes:

(a)        Status – we use cookies to help us to determine if you are logged into our website;

(d)       Security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;

  1. Cookies used by our service providers

10.1    Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

10.2    We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/

  1. Managing cookies

11.1    Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a)        https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b)       https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c)        http://www.opera.com/help/tutorials/security/cookies/ (Opera);

(d)       https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e)        https://support.apple.com/kb/PH21411 (Safari); and

(f)        https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

11.2    Blocking all cookies will have a negative impact upon the usability of many websites.

11.3    If you block cookies, you will still be able to use all the features on our website.

  1. Our details

12.1    This website is owned and operated by SBR Consulting.

12.2    We are registered in England and Wales under registration number 292 0340, and our registered office is at Houghton Stone, The Conifers, Filton Rd, Hambrook, Bristol, BS16 1QG.

12.3    Our principal place of business is at 16, Black Friars Lane, London, EC4V 6EB.

12.4    You can contact us:

(a)        By post, to the postal address given above;

(b)       Using our website contact form;

(c)        By telephone, on the contact number published on our website; or

(d)       By email, using the email address published on our website.

  1. Data protection officer

13.1    Our data protection officer’s contact details are:

Oliver Booker, info@sbrconsulting.com. Tel: 0207 653 3740

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SBR CONSULTING © All Rights Reserved | 2018

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SBR CONSULTING © All Rights Reserved | 2018