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BSA BRANDS PRIVACY POLICY

INTRODUCTION

Welcome to the BSA Brands (UK) Limited’s (hereafter ‘BSA Brands’) privacy policy.

BSA Brands respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. You may be accessing this privacy policy from the Bisley Workwear website https://www.bisleyworkwear.co.uk/ This site is operated by Bisley Sales Pty Ltd on behalf of BSA Brands. Data  is hosted on servers owned by Stealth Global Holdings Ltd, as described in this Privacy Policy.

Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

1.  IMPORTANT INFORMATION AND WHO WE ARE 

PURPOSE OF THIS PRIVACY POLICY

This privacy policy aims to give you information on how BSA Brands Bisley Sales Pty Ltd, and Stealth Global Holdings Ltd collects and processes your personal data through your use of this website, including any data you may provide through this website when you make an enquiry or take part in a competition.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

CONTROLLER

BSA Brands (UK) Limited is the controller and responsible for your personal data (collectively referred to as “BSA Brands”, “we”, “us” or “our” in this privacy policy). The information collected with your enquiry on the Bisley Sales Pty Ltd website will be passed directly on to BSA Brands who are located in the UK (on whose behalf Bisley Sales Pty Ltd run the website) and BSA Brands will respond directly to your enquiry or in relation to any online competition.

We have appointed a Data Protection Officer who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the Data Protection Officer using the details set out below.

PROCESSORS

Bisley Sales Pty Ltd is a processor of the personal data referred to in this Privacy Policy. Bisley Sales Pty Ltd, through the website shall automatically transfer your data to BSA Brands.

The website is hosted on servers owned by Stealth Global Holdings Ltd (hereafter Stealth Global Holdings) who are processor of the personal data referred to in this Privacy Policy. Your data will therefore be transferred to these servers.

ShortStack are a third party application provider whom we use to collect and store the data which we collect from the website, including your personal data. ShortStack’s servers are based in the United States, so your data will be transferred there. Shortstack are owned by Pancake Laboratories, Inc, who are self-certified on the US Privacy Shield and have an agreement with their customers which includes the EU standard contractual clauses see section 6 below.

Please see section 6 ‘International Transfers’ for further information on these processing arrangements.

CONTACT DETAILS

If you have any questions about this privacy policy or our privacy practices, please contact our Data Protection Officer in the following ways:

Full name of legal entity:  BSA Brands (UK) Limited
Email address: it@bsabrands.co.uk
Postal address: Fleming Court, Leigh Road, Eastleigh, Southampton, Hampshire, United Kingdom, SO50 9PD
Telephone number: 0800 9550 550 

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy policy under regular review.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications (such as ShortStack). 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 policy of every website you visit.

ShortStack are a third party application provider whom we use to collect and store the data which we collect from the website, including your personal data. ShortStack’s servers are based in the United States, so your data will be transferred there. Shortstack are owned by Pancake Laboratories, Inc, who are self-certified on the US Privacy Shield and have an agreement with their customers which includes the EU standard contractual clauses see section 6 below.

2.  THE DATA WE COLLECT ABOUT YOU

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 collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, and gender.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.

When you complete the ‘Contact Us’ form on our website, we will ask for different information depending on whether you are based in the UK or internationally. For transparency, the information we request is listed below.

  • ‘Contact Us’ form data for UK enquiries:
  • First name
  • Last name
  • Company
  • Post code
  • Phone number
  • Email address
  • Message
  • ‘Contact Us’ form data for international enquiries:
  • Title *
  • First name *
  • Last name *
  • Company *
  • Address *
  • Address (line 2)
  • Country *
  • Postal code *
  • Phone *
  • Email *
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  • Profile Data includes, where relevant, your username and password, purchases or orders made by you, your lifestyle, activities and other interests, preferences, feedback, testimonials, opinions and survey responses

If you complete the ‘Contact Us’ form for International queries, we will also ask the following:

  • Business Type * Importer/ Wholesaler/ Retailer /Agency /Other (Please Specify)
  • Business Type (If Other)
  • Does your business own/operate a warehouse facility? * No Yes (0-50m2) Yes (50-500m2) Yes (500-1500m2) Yes (1500m2+)
  • How long have you been in business? * 0-12 Months 1-3 Years    3-5 Years    5+ Years
  • Do you want to represent Bisley as a distributor in your country? * Yes No
  • Do you intend to hold stock or order as required? * Hold Stock Order As Required
  • Do you currently supply/stock other international brands? * Yes No
  • Do you have a current website? * Yes (Comment box for website address) No
  • Message
  • Usage Data includes information about how you use our website, products and services
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy. 

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). Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3.  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 by corresponding with us by post, phone, email or otherwise. This includes personal data you provide, where relevant, when you:
  • apply for our products or services;
  • create an account on our website;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us feedback or contact us, including where you complete an online ‘Contact Us’ form.
  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy available on the website for further details.

4.  HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where 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) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.

Please see ‘LAWFUL BASIS’ in the GLOSSARY section below to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

 

Purpose/Activity

 

Lawful basis for processing including basis of legitimate interest

 

To respond to your website enquiry

Performance of a contract with you

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

 

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

 

To enable you to partake in a prize draw, competition or complete a survey

 

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

 

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data, and carrying out internal functions)

 

(a) 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 reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

 

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you, and undertake marketing research and analysis

 

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

 

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences, including staff training

 

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

 

To manage and resolve any legal or commercial complaints and issues

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us, or to resolve issues which could expose the business to risk)

(c) Necessary to comply with a legal obligation

 


MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

PROMOTIONAL OFFERS FROM US  

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 goods from us and you have provided your consent to receive those marketing materials.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you, or in relation to our marketing materials, 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 as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy on the website.

5.  DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes set out in the table ‘Purposes for which we will use your personal data’, above.

  • Third Parties:
  • Service providers acting as processors based in Australia who provide IT and system administration services, including providing the BSA Brands servers, namely: Stealth Global Holdings, and Bisley Sales Pty Ltd (who are owned by DJG Corporation Pty Ltd). Please see section 6 ‘International Transfers’ for further details.
  • HM Revenue & Customs, regulators and other authorities based in the United Kingdom or Australia who may require reporting of processing activities in certain circumstances.
  • Any other third party we are required to share your personal data with by law or legal obligation.
  • Third parties to whom we 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, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6.  INTERNATIONAL TRANSFERS

Bisley Sales Pty Ltd will share your personal data with BSA Brands who will respond directly to your enquiry. Bisley Sales Pty Ltd will also share your personal data with Stealth Global Holdings, who are providing IT services to us . This will involve transferring your data outside the European Economic Area (EEA) for the following reasons:

  • The website shall be run by Bisely Sales Pty Ltd (who are located in Australia) on behalf of BSA Brands, and as such information collected through the site will be transferred between Bisley Sales Pty Ltd and BSA Brands. BSA Brands shall at all times remain the controller of the personal data, and Bisley Sales Pty Ltd shall be the processor.
  • Your information collected through the website will be stored on the BSA Brands system, which is located on servers in Australia, which are owned by Stealth Global Holdings. BSA Brands shall at all times remain the controller of the personal data, and Stealth Global Holdings shall be the processor.
  • Your information collected through the website may be collected and stored by ShortStack, who are located in the United States, and owned by Pancake Laboratories, Inc. BSA Brands shall at all times remain the controller of the personal data and ShortStack shall be the processor.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented

  • Where we use certain service providers, we may use specific contracts approved by the European Commission and UK data protection supervisory authority as appropriate, which give personal data the same protection it has in Europe.
  • Where we use providers based in the United States, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7.  DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised 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 will notify you and any applicable regulator of a breach where we are legally required to do so.

8.  DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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 unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see ‘Your Legal Rights’ below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9.  YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You have the right to:

  • Request access to your personal data (commonly known as a “data subject access request”).
  • Request correction of the personal data that we hold about you.
  • Request erasure of your personal data.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
    • If you want us to establish the data’s accuracy.
    • Where our use of the data is unlawful but you do not want us to erase it.
    • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
    • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party.
  • Withdraw consent at any time where we are relying on consent to process your personal data.

If you wish to exercise any of the rights set out above, please contact us.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10.  GLOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.