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PRIVACY POLICY


(UPDATED 23 MAY 2018)


PURPOSE OF OUR PRIVACY POLICY

This privacy policy aims to give you information on how BlueBridge One Business
Solutions Limited and any of our group companies collect and process your
personal data.


WHAT OUR POLICY COVERS

We are committed to protecting your personal data and also being transparent
about how we collect, use, and share information about you while providing you
with the opportunity to receive products and services which enhance your
business activities.

This Privacy Policy covers the information we collect about you when you use our
products or services, or otherwise interact with us. This policy also explains
your choices about how we use information about you. Your choices include how
you can object to certain uses of information about you and how you can access
and update certain information about yourself.


DATA WE COLLECT ABOUT YOU

We collect data, as detailed below, when you provide it to us, when you use our
services, or when other sources provide it to us:

 * Identity data – We collect identity data including your first name, last
   name, position, email address and phone numbers.
 * Profile data – We collect information about you when you register for an
   account, create or modify your profile, set preferences, sign-up for or make
   purchases from us.
 * Website data – We collect content that you submit to our websites. This
   includes social media or social networking websites operated by us. For
   example, you provide content to us when you provide feedback or when you
   participate in surveys, activities or events. For some of the services
   supplied on our website you may be asked to provide further details. The
   information required, and the reason why we need it, will be explained at the
   time this information is requested. Additionally, we may collect anonymous
   information about your visit. We will only collect such anonymous information
   to combine with other anonymous information which is then used and analysed
   at an aggregate level to help us understand how our customers use our
   website.
 * Cookies and tracking technologies: We and our third-party partners, such as
   our advertising and analytics partners, use cookies and other tracking
   technologies to recognise you across different services and devices. We may
   collect anonymous information through the use of various technologies,
   including cookies. We use cookies to store and tailor our site to meet your
   personal preferences. You have the option to disallow cookies. Some of these
   cookies are known as “session cookies”, which will last only so long as you
   stay on our website. If your browser permits it, you may set your computer to
   reject our cookies although this may affect the quality of your visit to our
   site.
 * Payment and Transaction data: We collect certain payment and billing
   information when you register for certain services including bank account and
   payment card details, billing address, email address and telephone numbers.
 * Data obtained from third parties: Occasionally, we may receive information
   relating to you from third parties. It is our policy to receive information
   only from such parties which we believe have obtained the information from
   you fairly. However, we do not control the manner in which third parties
   collect data. If you believe that a third party has passed to us your
   personal data against your wishes then you should send us an email at
   support@bluebridgeone.com. We will always treat any data that we receive from
   third parties in the same manner that we treat the personal data we collect.
 * Data obtained from companies we partner with to provide you with a service:
   We co-operate with our partners to help market their products and services to
   you and to assist them in servicing products they supply to your
   organisation. In doing so the partner may provide us with information
   including your name, email address, phone number and company, as well as
   billing and technical information, what products you have purchased or are
   interested in and other information that may be necessary in order for us to
   service your needs.
 * Data you provide through our service and support channels: When you open a
   support case, speak to one of our consultants directly or otherwise engage
   with our services or support teams, you will be asked to provide information.
   For example in the case of a support request you may be asked to provide
   contact information, details of a problem you are experiencing, and any other
   documentation, screenshots or information that would be helpful in resolving
   the problem.


HOW WE COLLECT DATA

We use various methods to collect data from and about you including through:

 * Direct communication: You may give us your identity, contact, financial,
   profile and marketing data by filling in forms or by corresponding with us by
   post, phone, email or otherwise. This includes personal data you provide when
   you purchase our or our Partner products or services, create an account on
   our website, subscribe to our service or publications, request marketing to
   be sent to you, enter a survey, register for an event or give us some
   feedback
 * Automated interactions: When you interact with our website, we may
   automatically collect data about your browsing actions. We collect this
   personal data by using cookies. Please see our cookie policy for further
   details.
 * Third parties or publicly available sources: We may receive personal data
   about you from various third parties and public sources in and outside the
   EEA including data from:
   * analytics providers such as Google and Linked-in
   * advertising networks
   * search information providers
   * contact, financial and transaction data from providers of payment and other
     services


HOW WE USE PERSONAL DATA

We will use your personal data for the following purposes:

 * To provide services or support to you: We will use your personal data to
   provide and improve our general service to you, including to process
   transactions with you, authenticate you when you log in and to provide our
   services including support to you. We may use your information to resolve
   technical issues you encounter, to respond to your requests for assistance,
   to analyse and to repair application issues you experience.
 * To send you information about services and products we are providing you : We
   use your contact information to send transactional communications via email,
   including confirming your purchases, reminding you of subscription
   expirations, responding to your comments, questions and requests and sending
   you technical notices, updates, security alerts, and administrative messages.

 * To market, promote and drive engagement with you : We use your contact
   information to send promotional communications that may be of specific
   interest to you, including by email and by displaying ads on other companies’
   websites and applications, as well as on platforms like Linked-in and Google.
   These communications are aimed at driving engagement and maximising what you
   get out of our services, including information about white papers, survey
   requests, newsletters, product information and events we think may be of
   interest to you. You can control whether you receive these communications as
   described below by opting out.
 * To advise partner companies that we are engaged with you:We use your contact
   information to advise our partner companies that we are currently engaged in
   marketing and services activities with you where the products and services
   relate primarily to the provision of products and services supplied by the
   partner.
 * To protect our legitimate business interests and legal rights: Where required
   by law or where we believe it is necessary to protect our legal rights,
   interests and the interests of others, we use information about you in
   connection with legal claims, compliance, regulatory, and audit functions,
   and disclosures in connection with the acquisition, merger or sale of a
   business.

We may use information about you where you have given us specific consent to do
so for a purpose not listed above. For example, we may publish customer case
studies or featured customer stories to promote our services, with your
permission.


APPLYING THE LAW

We will only use your personal data in accordance with applicable laws. There
are a number of legal bases for processing certain personal data. Most commonly,
we will use your personal data in the following circumstances:

 * Where we need to perform a contract, we enter into with you.
 * Where it is necessary for our legitimate interests (or those of a third
   party) in conducting and managing our business in such a manner to give you
   the best service/product and the best and most secure experience and where
   your interests and fundamental rights do not override those interests.
 * Where we need to comply with a legal or regulatory obligation.
 * We do not rely on consent as a legal basis for processing your personal data
   other than in relation to 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, and unsubscribe links are included on
   every marketing communication.
 * We rely on a legal basis for using your data to:
 * Register you as a new customer
 * Process and deliver our services including to manage collections.
 * Manage our relationship with you including notifying you about changes to our
   privacy policy or terms of service and to gather your feedback regarding our
   services.
 * Register you for an event, complete a survey or provide feedback and
   information about your use of our services.
 * Administer and protect our business and our website.
 * To deliver relevant website content and advertisements to you and measure or
   understand the effectiveness of the advertising we serve to you.
 * To provide data analytics to allow us to improve our website, products and
   services, marketing, customer relationships and experiences.
 * To make suggestions and recommendations to you about products or services
   that may be of interest to you.

If we need to use your personal data for an unrelated purpose, we will notify
you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or
consent where this is required by law.


MARKETING COMMUNICATIONS

We strive to provide you with choices regarding certain personal data uses,
particularly around marketing and advertising. For marketing purposes we may use
your personal data to form a view on what we think you may want or need, or what
may be of interest to you. You will receive marketing communications from us if
you have:

 * requested information from us;
 * purchased products or services from us;
 * provided us with your details when you attended an event, conference,trade
   show;
 * provided us with your details when you registered for an event,competition,
   or promotion; provided us with your details for any other reason;
 * and, in each case, you have not opted out of receiving that marketing.

We will get your express opt-in consent before we share your personal data with
any company outside the group of companies for marketing purposes.


YOU CAN OPT-OUT AT ANY TIME

At any time you can ask us or third parties to stop sending you marketing
communications by following the opt-out links on the marketing communication
sent to you. Alternatively you can request to Opt-out by contacting us at any
time at: support@bluebridgeone.com.


USE OF YOUR PERSONAL DATA BY THIRD-PARTY MARKETING COMPANIES

We will get your express opt-in consent before we share your personal data with
any company outside our group of companies for marketing purposes.


USE OF COOKIES

Our website provides you with the option to disallow cookies any time you visit
our website. You can also set your browser to refuse all or some browser
cookies, or to alert you when websites are set or access cookies. If you disable
or refuse cookies, some parts of this website may become inaccessible or may not
function correctly.


DISCLOSURE OF PERSONAL DATA

We may share your personal data with other parties:

 * Where it is in our legitimate interest to do so and where your interests and
   fundamental rights do not override our interests
 * in order to fulfil a contract we are in or about to enter into with you
 * We are required to comply with a legal or regulatory obligation
 * In such events we may disclose your personal data to the parties set out
   below:
 * Service providers, acting as processors, who may be based within or outside
   the EEA, who provide IT, software-as-a-service (SaaS), system administration
   and other services which support the functions of our business.
 * Professional advisers, acting as processors or joint controllers, including
   lawyers, bankers, auditors and insurers based in who may be based within or
   outside the EEA, who provide consultancy, banking, legal, insurance,
   accounting and similar professional services.
 * 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 notice.
 * Tax authorities, regulators, public bodies or other parties, acting as joint
   controllers or processors, based in countries where BlueBridge One carries on
   business operations and where disclosure is required in accordance with
   applicable law.


INTERNATIONAL DATA TRANSFER

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.

We share your personal data within the BlueBridge One Group. This will involve
transferring your data outside the European Economic Area (EEA). Some of our
external third parties are based outside the EEA so their processing of your
personal data will involve a transfer of data outside the EEA. 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:

 * We will only transfer your personal data to countries that have been deemed
   to provide an adequate level of protection for personal data by the European
   Commission. For further details, see European Commission: Adequacy of the
   protection of personal data in non-EU countries.
 * Where 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. For further details, see European Commission:
   Model contracts for the transfer of personal data to third countries.
 * Where we use providers based in the US, 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. For further
   details, see European Commission: EU-US Privacy Shield.


DATA SECURITY

We have put in place appropriate security measures to prevent your personal
unauthorised way. 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.

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.


DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the
purposes we collected it for, including for the purposes of satisfying 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 unauthorised use or disclosure of your personal data, the purposes for
which we process your personal data, whether we can achieve those purposes
through other means, and the applicable legal requirements.

In some circumstances, you can ask us to delete your data.

In some circumstances, we may 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.


YOUR RIGHTS WHERE WE ARE THE DATA CONTROLLER

Where we are the data controller, and under certain circumstances, you have the
following rights in relation to your personal data:

 * The right to request access to your personal data. This enables you to
   receive a copy of the personal data we hold about you and to check that we
   are lawfully processing it.
 * The right to request correction of the personal data that we hold about you
   that is incomplete or inaccurate. We may need to verify the accuracy of the
   new data you provide to us.
 * The right to request erasure of your personal data. This enables you to ask
   us to delete or remove personal data where there is no good reason for us
   continuing to process it.
 * The right to object to the 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
   us processing your personal data on the ground that you feel it impacts your
   fundamental rights and freedoms.
 * The right to request us to suspend the processing of your personal data in
   the following scenarios: (a) where you want us to establish the data’s
   accuracy; (b) where our use of the data is unlawful but you do not want us to
   erase it; (c) 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; or (d) you
   have objected to our use of your data but we need to verify whether we have
   overriding legitimate grounds to use it.
 * The right to request the transfer of your personal data to you or to a third
   party.
 * The right to withdraw consent at any time where we are relying on consent to
   process your personal data. However, this will not affect the lawfulness of
   any processing carried out before you withdraw your consent. If you withdraw
   your consent, we may not be able to provide certain products or services to
   you.


ADDITIONAL DATA CONSIDERATIONS

From time to time we may aggregate personal data about our users, to understand
usage trends and patterns. Once aggregated, this information cannot be used to
identify individual users.

We keep our Privacy Policy under regular review. Any updates will be published
at this URL. Please review the policy regularly.

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

Our 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 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 may refuse to
comply with your request in these circumstances.

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.

We try to respond to all legitimate requests (where we are the data controller)
within one month. Occasionally it may 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.

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.


FURTHER QUESTIONS

If you have any questions about our Privacy Policy, please contact us at:
BlueBridge One, Dixcart House, Addlestone Road, Bourne Business Park,
Addlestone, Surrey, KT15 2LE or by e-mail at: support@bluebridgeone.com



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BlueBridge One would like to use the information you provide on this form to
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