At BlueHorn Technologies Ltd, we take your privacy seriously, and we are committed to protecting your personal data. We aim to be clear about how we use personal data, and this privacy notice will inform you how we look after your data, what personal data we process, and why. It includes the relevant requirements of the General Data Protection Regulation. It applies both when you visit our website (regardless of where you visit it) and when you use our services.
This privacy notice is provided in a layered format. Please understand the meaning of some of the terms used in this privacy notice. It will give you information about:
- Who we are and who is responsible for your personal data
- Where you can contact us if you have any questions about how we process your personal data
- What types of personal data do we process, and where do we get that personal data from.
- How we use your data and what our legal basis for doing so is
- Whom we disclose your data to and why
- Whether we transfer any of your data internationally
- How we store your data securely
- How long we hold your data for
- Your rights to complain and how you go about making a complaint
Changes to This Data Protection Notice
Like any business, our business will change over time, and so will the way we use and protect your personal data. As a result, we may need to change this General Data Protection Notice. These changes will not reduce your rights or the level of protection we apply to your personal information. The most up-to-date General Data Protection Notice will continuously be published on our website, and we will identify the changes we have made in any updates.
Important information and who we are
This privacy notice aims to give you information on how BlueHorn Technologies Ltd collects and processes your data through your dealings with us, including your use of this website or when you use any service we offer.
This website is not intended for children, and we do not knowingly collect data relating to children.
It is essential that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when 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.
BlueHorn Technologies is the controller and responsible for your data (collectively referred to as “BlueHorn Technologies,” “we,” “us,” or “our” in this privacy notice). When we refer to BlueHorn Technologies Ltd, we mean:
Address: 71-75 Shelton Street, Covent Garden, London, England, WC2H 9JQ
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.
You can contact us if you have any questions about how we process your personal data. We have appointed a Data Protection Officer responsible for overseeing questions concerning this privacy notice if you have any questions about this privacy notice, including any requests to exercise your legal rights.
What types of personal data do we process, where we get that personal data from
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 need to collect, use, store and transfer various kinds of personal data about you, which we have grouped as follows:
- Identity Data includes first name, last name, username or similar identifier, title, date of birth, and gender.
- Contact Data includes address, email address, and telephone numbers.
- Technical Data includes internet protocol (IP) address and other technology on your devices to access this website.
- Marketing and Communications Data includes your preferences in receiving marketing from us.
We also collect, use, and share Aggregated Data such as statistical data for any purpose. Aggregated Data may be derived from your data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. However, suppose we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you. In that case, we treat the combined data as personal data, which will be used following 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) unless we have your explicit consent to do so. Nor do we collect any information about criminal convictions and offenses.
If you fail to provide personal data, we may not perform the contract we have or are trying to enter with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact, and Financial Data by filling in forms or corresponding with us by post, phone, email, or otherwise. It includes personal data you provide when you:
- Use our services;
- Participate in our events;
- Please give us some feedback.
We automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your browsing actions. We collect this personal data by using cookies.
How we use your personal data
- We will only use your data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- We need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party), your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your data.
We have set out below a description of all the ways we plan to use your personal data and the legal bases we rely on. We have also identified what our legitimate interests are where appropriate.
- To manage our relationship with you, which will include
- To notify you about relevant information to our services
- Necessary for our legitimate interests (to keep records updated)
- Necessary to comply with a legal obligation
To administer or protect our business and this website.
including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud, and in the context of a business reorganization or group restructuring exercise. To make suggestions and recommendations to you about services that may interest you.
Necessary for our legitimate interests (to develop our products/services and grow our business)
We strive to provide you with specific personal data uses, mainly marketing and advertising. We have established the following personal data control mechanisms:
We may use your Identity, Contact, Technical, Usage, and Profile Data to form a view on what we think you may want or need or what may be of interest to you. This is how we decide which products, services, and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us, and, in each case, you have not opted out of receiving that marketing.
We will never sell your data or share it with third parties who might use it for their own purposes.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us due to a product/service purchase, warranty registration, product/service experience, or other transactions.
Change of purpose
We will only use your data for the purposes 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 you wish to explain how the processing for the new purpose is compatible with the original purpose, please get in touch with us.
If we need to use your data for an unrelated purpose, we will notify you and explain the legal basis that allows us to do so.
Please note that we may process your data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Whom we disclose your data to and why
We may share your data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- Internal Third Parties as set out in the Glossary.
- External Third Parties as set out in the Glossary.
Third parties may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, the new owners may use your data the same way as set out in this privacy notice.
We require all third parties to respect the security of your data and to treat it under the law. We do not allow our third-party service providers to use your personal data for their purposes and only permit them to process your data for specified purposes and follow our instructions.
Whenever we transfer your data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring the following safeguard is implemented:
We use certain service providers; we may use specific contracts approved by the European Commission, which give personal data the same protection it has in Europe.
How we store your data securely
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized 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 notify you and any applicable regulator of a breach where we are legally required to do so.
Data retention How long will you use my data?
We will only retain your data for as long as necessary to fulfill the purposes we collected it for, including to satisfy 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 unauthorized use or disclosure of your data, the purposes for which we process your data, and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your data are available in our retention policy which you can request from us by contacting us.
In some circumstances, you can ask us to delete your data.
What rights do you have concerning your data, and how can you exercise these rights?
We want to ensure you remain in control of your data. Part of this is making sure you understand your legal rights, which (for individuals) are as follows:
- The right to confirmation as to whether or not we have your data and, if we do, to obtain a copy of it (this is known as a subject access request);
- The right to have inaccurate data rectified; and
- The right to object to your data being used for marketing or profiling.
You will not have to pay a fee to access your data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
It is a security measure to ensure that personal data is not disclosed to anyone who has no right to receive it. We may need to request specific information from you to help us confirm your identity and ensure your right to access your data (or exercise any of your other rights). We may also contact you to further information concerning your request to speed up our response.
Time limit to respond.
We 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.
Please keep in mind that there are exceptions to the rights above and, though we will always try to respond to your satisfaction, there may be situations where we are unable to do so. If you are not happy with our response, or you believe that your data protection or privacy rights have been infringed, you should contact the UK Information Commissioner’s Office, which oversees data protection compliance in the UK.
We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please get in touch with us in the first instance.