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Privacy Policy

Introduction

Bayham Investments Ltd is committed to ensuring that your privacy is protected. This privacy policy is a legal document which explains how we use the information we collect about you, how you can instruct us if you prefer to limit the use of that information and procedures that we have in place to safeguard your privacy. Our privacy policy forms part of our Legal Policy, which should be read together with this document.

1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Bayham Investments Ltd collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter or contact us through the website form(s) on this site.

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 provided when we collect or process personal data, so that you are fully aware of how and why we are using your data. This policy supplements other notices and policies and does not override them.

Controller

Bayham Investments Ltd is the controller and is responsible for your personal data (referred to as “Bayham Investments”, “we”, “us” or “our” in this privacy policy).

We have appointed a data privacy manager who is responsible for overseeing questions relating to this privacy policy.

Contact details

Full name of legal entity: Bayham Investments Ltd (company number 10201527).

Email address: hello@bayhaminvestments.co.uk

We keep our privacy policy under regular review. This version was last updated on 16 January 2019.

Please keep us informed if the personal data we hold about you changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. We do not control those third parties and are not responsible for their privacy statements.

2. The data we collect about you

Personal data means any information about an individual from which that person can be identified. It does not include anonymous data.

  • Identity Data includes first name, last name, username or similar identifier and title.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • 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 IP address, login data, browser details, time zone, location, operating system, platform and device technology.
  • Profile Data includes your username and password, purchases or orders, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing and your communication preferences.

We also collect, use and share Aggregated Data for statistical or demographic purposes. If aggregated data is combined with personal data so that it can identify you, we treat it as personal data under this policy.

We do not collect Special Categories of Personal Data or information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law or under a contract and you fail to provide it when requested, we may not be able to perform the contract or provide the relevant product or service.

3. How is your personal data collected?

We use different methods to collect data from and about you, including direct interactions, automated technologies or interactions, and third parties or publicly available sources.

  • apply for our products or services;
  • subscribe to our newsletter;
  • create an account with us;
  • request marketing;
  • give us feedback or contact us.

As you interact with our website, we automatically collect Technical Data about your equipment, browsing actions and patterns using cookies, server logs and similar technologies. We may also receive data from analytics providers such as Google.

4. How we use your personal data

We will only use your personal data when the law allows us to, including where necessary to perform a contract, for our legitimate interests where your rights do not override them, or to comply with a legal obligation. We generally do not rely on consent except for certain direct marketing, and you may withdraw consent at any time.

Purposes for which we will use your personal data

  • To register you as a new customer and perform a contract with you.
  • To process and deliver contracts, manage payments, fees and charges, and recover money owed to us.
  • To manage our relationship with you, notify you of changes and request reviews or survey responses.
  • To administer and protect our business and website, including troubleshooting, analysis, testing, maintenance, support and security.
  • To use analytics to improve our website, products, services, marketing and customer experience.

Marketing

We strive to provide you with choices regarding personal data uses for marketing. You may opt out at any time. We may use Identity, Contact, Technical, Usage and Profile Data to determine what products, services and offers may be relevant to you. We will obtain express opt-in consent before sharing personal data with third parties for marketing.

Cookies

You can set your browser to refuse all or some cookies or to alert you when websites set or access cookies. Some parts of the website may not function properly if cookies are disabled. Please see our Cookie Policy.

Change of purpose

We will use personal data only for the purposes for which it was collected unless another use is compatible with the original purpose. If an unrelated purpose is required, we will notify you and explain the legal basis.

5. Disclosures of your personal data

We may share personal data with service providers, professional advisers, HM Revenue & Customs, regulators and authorities, and third parties involved in a sale, transfer, merger, acquisition or restructuring. Third parties must respect the security of your data and may process it only for specified purposes and in accordance with our instructions.

6. International transfers

We do not transfer your personal data outside the European Economic Area (EEA).

7. Data security

We have put in place appropriate security measures to prevent personal data from being accidentally lost, used, accessed, altered or disclosed without authorisation. Access is limited to those with a business need to know, who process data on our instructions and are subject to confidentiality obligations.

We have procedures to deal with suspected personal data breaches and will notify you and any applicable regulator where legally required.

8. Data retention

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, including legal, regulatory, tax, accounting and reporting requirements. We may retain it longer where there is a complaint or a reasonable prospect of litigation.

By law, we keep basic customer information, including Contact, Identity, Financial and Transaction Data, for six years after a person ceases to be a customer.

9. Your legal rights

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

  • Request access to your personal data.
  • Request correction of incomplete or inaccurate personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing.
  • Request transfer of your personal data.
  • Withdraw consent at any time where processing is based on consent.

No fee usually required

You will not usually have to pay a fee to exercise your rights. We may charge a reasonable fee, or refuse to comply, where a request is clearly unfounded, repetitive or excessive.

What we may need from you

We may request specific information to confirm your identity and may ask for further information to help us respond.

Time limit to respond

We try to respond to legitimate requests within one month. Complex or multiple requests may take longer, in which case we will notify you.

10. Glossary

Lawful basis

Legitimate Interest means the interest of our business in conducting and managing our business to provide the best service, product and secure experience, while balancing any impact on you and your rights.

Performance of Contract means processing personal data where necessary to perform a contract with you or take steps at your request before entering into a contract.

Comply with a legal obligation means processing personal data where necessary to comply with a legal obligation.

Third parties and external third parties

  • Service providers who provide IT and system administration services.
  • Professional advisers including lawyers, bankers, auditors and insurers.
  • HM Revenue & Customs, regulators and other authorities.

11. About

Bayham Investments Ltd is a company registered in England and Wales under company number 10201527. You can read more about data protection law on the Information Commissioner’s Office website.