YOUR DUTY TO INFORM US OF CHANGES
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.
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:
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).
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 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.
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 when you:
Automated technologies/interactions and third party sources. We may automatically collect your personal information as you interact with our Interface (such as browsing actions, patterns, hardware model, device ID, operating system version, web-browser software and your Internet Protocol address/MAC address/device identifier). We may also receive your personal data from various third parties and public sources as required or permitted by applicable law (such as public databases, credit bureaus, ID verification partners, resellers and channel partners, joint marketing partners, and social media platforms).
PURPOSES FOR WHICH WE USE YOUR PERSONAL DATA
We will only use your personal data within the limits allowed by law. Most commonly, with reference to the types of legal basis specifically outlined in the GDPR, we will use your personal data where:
Please see the below Glossary to find out more about the types of lawful basis that we will rely on to process your personal data.
We have set out below, in table format, a description of the ways we plan on using your personal data, and on what basis we do so. We have also identified what our legitimate interests are where appropriate.
Please 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||Type of personal data||Lawful basis for processing, including basis of legitimate interest|
|To register you as a new user||Performance of a contract with you|
To deliver the Services including:
To deliver the Services including:
|To enable you to partake in a prize draw, competition or complete a survey|
|To administer and protect our business, this Interface and the Services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)|
|To deliver relevant Interface and Services content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||Necessary for our legitimate interests (to study how customers use our Services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our Interface, Services, marketing, customer relationships and experiences||Necessary for our legitimate interests (to define types of users for our Services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To identify or verify you in order to comply with applicable laws such as anti-money laundering and terrorist financing laws|
|To make suggestions and recommendations to you about Services that may be of interest to you||Necessary for our legitimate interests (to develop our Services and grow our business)|
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 with respect to the Interface or the provision of the Services. Based on your communication preferences, we may send you marketing communications to inform you about our events or our partner events; to deliver targeted marketing and advertising; and to provide you with promotional offers based on your communication preferences.
INFORMATION SHARED WITH THIRD PARTIES
From time to time we may request your permission to allow us to share your personal data with third parties. We will only share your personal data with third parties who have a legitimate purpose for accessing it, particularly:
You may opt out of having your personal data shared with third parties, or allowing us to use your personal data for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorisation. If you choose to do so, certain features of our Interface or Services may not be available to you.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which 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 get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
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, in compliance with the above rules, where this is required or permitted by law.
Your personal data may be transferred, stored, and processed in any country in which we operate.
Data Subjects of the European Economic Area (“EEA”) Only:
Where we transfer your personal data outside of the EEA, this is done either on the basis that it is necessary for the performance of the contract between you and BTSE, or that the transfer is subject to the European Commission’s model contracts for the transfer of personal data to third countries (i.e., the standard contractual clauses), pursuant to Decision 2004/915/EC and Decision 2010/87/EU as appropriate or, in the event that the transfer is to a US entity, we may transfer personal data if the transferee is part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
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.
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.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data, which include the right to:
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:
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.
You have the right to make a complaint at any time to the Information and Data Protection Tribunal (“Tribunal”). We would, however, appreciate the chance to deal with your matter internally before approaching the Tribunal.