This document was last updated on [28th September, 2016]
PURPOSE OF OUR POLICY
- Blackbullion Limited (Company Number 7629923) of 10-14 Accommodation Road, London, NW11 8ED (we, us or our) provides the products and services offered on the Blackbullion website www.blackbullion.com (Blackbullion).
- For the purposes of the Data Protection Act 1998 (Act), we are the data controller.
A) Providing you with the products and services that Blackbullion offers; and
B) The normal day-to-day operations of our business.
- For the purposes of the Data Protection Act 1998 (Act), we are the data controller.
WHO AND WHAT THIS POLICY APPLIES TO
- We handle data for the purposes of carrying out our business and also for and on behalf of our customers (such as educational institutions) and users (such as individual consumers).
- Blackbullion is not available to children (persons under the age of 18 years), unless with the permission of a parent or guardian and otherwise under appropriate supervision.
THE INFORMATION WE COLLECT
- It is necessary for us to collect and process data in order to provide you with the products and services offered on Blackbullion. Without limitation, the type of information we may collect is:
A) Identifying Information. We may collect personal details such as your name, location, date of birth, personal correspondence you send us and other information that allows us to identify who you are;
B) Contact Information. We may collect information such as your email number, third-party usernames (where you log in to Blackbullion using your Facebook or Twitter account), address and other information that allows us to contact you;
C) Financial Information. We may collect financial information related to you such as any bank or credit card details and other information that allows us to transact with you, as well as budgetary and other financial information necessary for the use of our products and services;
D) Statistical Information. We may collect information about your online and offline preferences, habits, movements, trends, decisions, associations, memberships, finances, purchases and other information for statistical purposes; and
E) Activity information. We may collect information that is sent or otherwise made available to us by others about your activities, including activities with our partners.
HOW INFORMATION IS COLLECTED
- Most information will be collected in association with your use of Blackbullion, our products and services, or generally when you are dealing with us. However, we may also receive data from other sources such as advertising, promotions, public records, mailing lists, our contractors and staff, recruitment agencies and our business partners (such as educational institutions). In particular, information is likely to be collected as follows:
A) Registrations/Subscriptions/Purchases. When you register, subscribe and or purchase a product, service, list, account, connection or other process whereby you enter details or grant us access to information;
B) Accounts/Memberships. When you submit your details to open an account and/or become a member with us;
C) Partners/Suppliers. When you grant us access to your accounts with our business partners (including educational institutions);
D) Contact/Access. When you contact us in any way or access Blackbullion, we may require you to provide us with certain details for us to permit such access;
E) Meta Data/Pixel Tags. Meta data and pixel tags enable us to track users and email messages.
- As there are many circumstances in which we may collect information both electronically and physically, we will endeavour to ensure that you are always aware of when your data is being collected.
- We may also collect anonymous data such as traffic, IP addresses and transaction statistics, which may be used and shared on an aggregated and anonymous basis.
WHERE DATA IS STORED
- The data that we collect from you is stored in the UK but may be transferred to, and stored at, a destination outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services.
- By submitting your personal data, you agree to this transfer, storing or processing.
HOW DATA IS USED & WHO IT IS DISCLOSED TO
- It may be necessary for us to disclose your data to third parties in a manner compliant with the Act and in the course of our business.
- In all other cases, you agree that we have the right to disclose your data to any member of our group (which means our subsidiaries, our ultimate holding company and its subsidiaries) for the purposes set out below, as well as our business partners, service providers and sub-contractors for the performance of any contract we enter into with them or you.
- Information is used to enable us to operate our business, especially as it relates to you. This may include:
A) for the provision of goods and services between you and us;
B) to verify your identity;
C) to communicate with you about:
1. your relationship with us;
2. our goods and services;
3. our own marketing and promotions;
4. competitions, surveys and questionnaires.
D) investigating any complaints made by you or about you (such as by any governmental or law enforcement agency), or if we have reason to suspect that you are in breach of any of our terms and conditions;
E) for statistical and analytical purposes; and/or
F) as required or permitted by any law (including the Act).
- We may use your data for other purposes, but only where such purposes are clearly communicated to you at the time we collect your data or we later obtain your permission to do so.
- There are also some circumstances in which we will disclose your information to third parties:
A) as required by any law (including the Act), including exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction; and/or
B) in the event we sell our business or part thereof, we may transfer data to a new owner.
- We will not disclose your data to any entity outside of the EEA, unless it is in a jurisdiction that ensures adequate levels of protection in relation to the processing of personal data, or where alternative, appropriate safeguards are in place.
THIRD PARTY ACCOUNTS
- We may link your account with a third party (such as Facebook or Twitter) to enable certain functionality of our services. This allows us to obtain information from those accounts (including your profile picture, friends or contacts).
- The information we may obtain from such third parties often depends on your settings or their privacy policies.
- A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of Blackbullion.
YOUR RIGHTS IN RELATION TO MARKETING
- You have the right to ask us not to process your personal data for marketing purposes. We will inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise this right at any time by notifying us at email@example.com.
- If you believe that you have received information from us that you did not consent to receiving, you should contact us on the details below
THE SAFETY & SECURITY OF DATA
- You are responsible for keeping your password secure. We will take all reasonable precautions to protect your data from unauthorised access. This includes appropriately securing our physical facilities and electronic networks.
- The security of online transactions and the security of communications sent by electronic means or by post cannot be guaranteed. You provide information to us via the internet or by post at your own risk.
- If you suspect any misuse or loss of, or unauthorised access to, your data, you should let us know immediately.
HOW TO ACCESS AND/OR UPDATE INFORMATION
- The Act gives you the right to request from us the data that we have about you. All such requests should be sent to firstname.lastname@example.org and may be subject to an administration fee.
- If you cannot update your own information, we will correct any errors in the data we hold about you within 7 days of receiving written notice from you about those errors.
- It is your responsibility to provide us with accurate and truthful data. We cannot be liable for any information that is provided to us that is incorrect.
COMPLAINTS AND DISPUTES
- If you have a complaint about our handling of your data, you should address your complaint in writing to the details below.
- If a dispute arises regarding your data, you and we must first attempt to resolve the issue directly between us.
- If we become aware of any unauthorised access to your data we will inform you at the earliest practical opportunity once we have established what was accessed and how it was accessed.
ADDITIONS TO THIS POLICY
- All correspondence with regards to privacy should be addressed to:
The Data Protection Officer
You may contact us by email in the first instance.