1. Information About Us
Big Business Agency Ltd
Limited company registered in Northern Ireland under company NI684281
Registered address: 38 Bann Road, Kilrea, County Londonderry, Northern Ireland BT515RY.
Data Protection Officer: Peter Russell-Smith.
Email address: email@example.com
Telephone number: +44 (0) 7389 868706
Postal address: 38 Bann Road, Kilrea, UK, BT515RY
2. What Does This Notice Cover?
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
3. What Is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 5, below.
4. What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
- The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
- The right to access the personal data we hold about you. Part 10 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 11 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling. Part 6 explains more about how we use your personal data, including automated decision-making and profiling.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 11.
5. What Personal Data Do You Collect and How?
Depending upon your use of Our Site, we may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. We do not intentionally collect any ‘special category’ or ‘sensitive’ personal data or personal data relating to children or data relating to criminal convictions and/or offences.
|Data Collected||How We Collect the Data|
|Identity Information including: Prefix, Name, Title||Through a variety of methods including Opt-in, purchased contact databases and lists resulting from sales and marketing outreach|
|Contact information including: Email address, Telephone numbers, office address||Through a variety of methods including Opt-in, purchased contact databases and lists resulting from sales and marketing outreach|
|Business information including Business address, various attributes such as turnover, staff numbers and compliance information like geographies||Through a variety of methods including Opt-in, purchased contact databases and lists desktop research of publicly available information|
|Payment information including: Bank details, Sort, SWIFT and IBAN numbers, Account numbers, Credit Card details, PayPal account details||Requested from you as Opt-in|
|Profile information including employment history, Interests, purchase history, preferences||Through a variety of methods including Opt-in, purchased contact databases and lists resulting from sales and marketing outreach|
|Data from third parties including profile information.||Through a variety of methods including Opt-in, purchased databases and research|
6. How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how wemay use your personal data, and our lawful bases for doing so:
|What We Do||
|Our Lawful Basis|
|Administering our business including payments||Company emails||Legitimate commercial practice|
|Supplying our services to you.||Contact details including name, title, email, phone||Legitimate commercial practice|
|Personalising and tailoring our services for your company||Contact and business details and preferences.||Legitimate commercial practice.|
|Communicating with you.||Email address, Telephone numbers, Street Address||Where we believe you would be legitimately interested in our information, services or offerings|
|Supplying you with information by email or post that you have opted-in-to (you may opt-out at any time by using unsubscribe email functionality)||Email address, Telephone numbers, Street Address, Title,||Where we believe you would be legitimately interested in our information, services or offerings|
With your permission, and where believe you may be interested, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone, text message and post with information, news, and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.
We may use the following automated systems for carrying out certain kinds of decision-making and profiling. If at any point you wish to query any action that wetake on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the Data Protection Legislation gives you the right to do so. Please contact usto find out more using the details in Part 11.
- The following automated decision-making method(s) may be used:
- Google Analytics
- Intent based tools like Bombora
- The following automated profiling may take place:
- Cookies, Analytics running on our Website to track interest.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 11.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
7. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
|Type of Data||How Long We Keep It|
|Identity Information including: Prefix, Name, Title||For a period not exceeding five years from collection will an option for further five years|
|Contact information including: Email address, Telephone numbers, office address||For a period not exceeding five years from collection will an option for further five years|
|[Business information including Business address, various attributes such as turnover, staff numbers and compliance information like geographies||For a period not exceeding five years from collection will an option for further five years|
|Payment information including: Bank details, Sort, SWIFT and IBAN numbers, Account numbers, Credit Card details, PayPal account details||For a period not exceeding five years from collection will an option for further five years|
|Profile information including employment history, Interests, purchase history, preferences||For a period not exceeding five years from collection will an option for further five years|
8. How and Where Do You Store or Transfer My Personal Data?
Where we transfer your data to a third party based in the US, the data may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar levels of data protection to those in Europe. More information is available from the European Commission.
Please contact us using the details below in Part 11 for further information about the particular data protection mechanism used by us when transferring your personal data to a third country.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
- limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
- procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so;
9. Do You Share My Personal Data?
We may share your personal data with other companies in our group for Delivery and marketing purposes. We may sometimes contract with the following third parties to supply services.
|Recipient||Activity Carried Out||Sector||Location|
|Data research and analytic firms||Data acquisition and analysis||All that apply to the business||UK, USA, EU, Australia, New Zealand|
|Marketing Agencies||Brand Awareness and Demand Generation marketing||All that apply to the business||UK, USA, EU, Australia, New Zealand|
If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 8.
10. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 30 days of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
11. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Peter Russell-Smith):
Email address: firstname.lastname@example.org.
Telephone number: +44 (0) 7389 868 706.
Postal Address: 38 Bann Road, Kilrea, UK, BT515RY.
12. Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be made available on our website at www.bigbusinessagency.com. This Privacy Notice was last updated on 3 January 2022.