Privacy Policy

BGII Privacy Policy

This privacy notice describes how and why we process your personal information. Your privacy is very important to us and we are committed to using your personal information lawfully and protecting your privacy. 

BGII is committed to protecting your personal information when you are using BGII services. We want our services to be safe and enjoyable environments for our clients. This Privacy Policy relates to our use of any personal information you provide for example via phone or text, by email, online or in letters or correspondence. In order to provide you with the full range of BGII services, we sometimes need to collect information about you.

01 This Privacy Policy

explains the following: 

• What information BGII may collect about you and on what basis;
• How BGII will use information we collect about you;
• When BGII may use your details to contact you;
• Whether BGII will disclose your details to anyone else;
• Your choices regarding the personal information you provide to us;
• The use of cookies on BGII websites and how you can reject these cookies.
   

BGII is committed to safeguarding your personal information. Whenever you provide such information, we are legally obliged to use your information in line with all laws concerning the protection of personal information, including the Data Protection Act 1998 and General data Protection Regulations introduced on 25th May 2018, (these laws are referred to collectively in this Privacy Policy as the “data protection laws”). 

BGII websites contain hyperlinks to websites owned and operated by third parties. These third party websites have their own privacy policies, and are also likely to use cookies, and we therefore urge you to review them. They will govern the use of personal information you submit, which may also be collected by cookies whilst visiting these websites. We do not accept any responsibility or liability for the privacy practices of such third party websites and your use of such websites is at your own risk. 

02 Who are we? 

BGII is a UK firm with offices in the UK only. We do have clients from all over the world and this policy is intended to comply with UK/EU requirements only. If you are outside of the EU and you have any concerns please do not hesitate to contact us for more information about how we can help you. 

• When we refer to BGII we are referring to BGII Ltd.
   

03 What information will BGII collect about me?

When you participate in, access or sign up to any of BGII services, activities or online content, such as newsletters, competitions, live chats, message boards, telephone or text BGII, vote, donate money to a BGII charity appeal, register to attend for a BGII event or create an account using BGII online registration systems we may receive personal information about you. 

This can consist of information such as your name, email address, postal address, telephone or mobile number, confirmation of adult age, or date of birth*, depending on the activity. [*future] 

By submitting your details, you enable BGII (and where applicable its contractors) to provide you with the services, activities or online content you select. 

Please note that sometimes we will require you to provide additional personal information, and sometimes sensitive personal information (e.g. if you’re sending in an application to be a contractor for a secure site we may need to know and collect data your political leanings and personal circumstances). When we do this, we will provide further information as to why we are collecting your information and how we will use it. 

BGII also uses cookies (see section 13 below for details) and collects IP addresses (an IP address is a number that can uniquely identify a specific computer or other network device on the internet) from visitors to BGII websites. 

We will only collect, hold, use and/or process (together “process”) your personal information where we are legally allowed to do so. We will ensure that your personal information is: 

• processed lawfully, fairly and transparently
• collected for specific, explicit and legitimate purposes
• adequate, relevant and limited to what is necessary for the purpose of the processing
• kept accurate and up to date
• only kept for so long as is necessary
• processed securely using reasonable and appropriate technical and organisational measures to ensure integrity and confidentiality

We may rely on the following lawful reasons when we collect and use personal data to operate our business and provide our products and services: 

Contractual performance: 

where we process your personal information for contractual performance. This includes: 

• Enabling us to take steps you request prior to us entering into a contract; and then;
• Once we have entered into a contract, to enable us to perform the contract and to provide you with the products and services. We will process your personal information in accordance with the contract.

Legitimate interests: 

We may rely on legitimate interests based on our evaluation that the processing is fair, reasonable and balanced. These include: 

• Delivering services to our clients – To deliver the professional services our clients have engaged us to provide.
• Direct marketing – To deliver timely market insights and speciality knowledge we believe is welcomed by our business clients, subscribers and individuals who have interacted with us. Where we process your personal information for our interests we will do so only where we have carefully considered both our and your interests. We will not process your personal information if our interests are overridden by your interests or fundamental rights and freedoms.

Consent: 

where we rely solely on your consent to process your personal information 
There may be circumstances where we need to, or are required to obtain and/or rely upon your consent to process your personal information. If this is the case we will give you: 

• the reason for needing your consent, including details as to how we will process your information
• the choice as to whether to provide consent
• information to enable you to withdraw your consent

04 How will BGII use the information it collects about me? 

BGII will use your personal information for a number of purposes including the following: 

• to provide our services, activities or online content and to deal with your requests and enquiries;
• for service administration purposes, which means that BGII may contact you for reasons related to the service, activity or online content you have signed up for, as set out in section 5 below (e.g. to provide you with password reminders or to notify you that a particular service, activity or online content has been suspended for maintenance);
• to contact you about a submission you have made, including any content you provide.
• to provide you with information about our services, activities or online content;
• to personalise the way BGII content is presented to you (e.g. if the first thing you look at every day on BGII’swebsite is our news feed, we may present this information or a link to it on your homepage); 
• to use IP addresses to identify the location of users, to block disruptive use, to establish the number of visits from different countries and to determine whether you are accessing the services from the UK or not. If not, you may be re-directed to a more appropriate eginternational versions of our web pages (see section 12 for details); 
• to analyse and improve the services offered on BGII websites;
• to provide you with the most user-friendly navigation experience. BGII may also use and disclose information in aggregate (so that no individuals are identified) for marketing and strategic development purposes; and
• when you access BGII website from outside the UK, you may see international based web pages which may feature advertising. A certain amount of this advertising is tailored to the individual user and location.
• BGII uses web tracking cookies to work out what advertising might be most relevant to you based on the pages you look at on the BGII website and other BGII worldwide pages, and your IP address information. This is a practice widely used by other major web publishers and is known as “onsite behavioural targeting”. The tracking system is anonymised and therefore it does not know who you are. See our cookie policy  for further details.
• Where BGII proposes using your personal information for any other uses we will ensure that we notify you first. You will also be given the opportunity to withhold or withdraw your consent for the use of your personal information for purposes other than those listed above.

05 When will BGII contact me? 

BGII may contact you: 

• in relation to any service, activity or on-line content you have signed up for in order to ensure that BGII can deliver the services to you;
• in relation to any correspondence we receive from you or any comment or complaint you make about BGII products or services;
• in relation to any contribution you have submitted to BGII, e.g. on BGII message boards or via text or voice mail message;
• to invite you to participate in surveys about BGII services (participation is always voluntary); and
• for marketing purposes, either where we have legitimate reason to do so, or you have specifically agreed to this (see section 6 below).
• Relevant webpages will give you detailed information about how BGII will contact you in relation to specific services, activities or on-line content.

06 Will I be contacted for marketing purposes? 

BGII will only use your non-business, personal information provided by you for marketing purposes, or to promote new services, activities or on-line content where you have agreed to this. 

07 Will BGII share my personal information with anyone else? 

• We will keep your information confidential except where disclosure is required or permitted by law (for example to government bodies and law enforcement agencies) or as described in section 8 below. Generally, we will only use your information within  However, sometimes BGII uses third parties to process your information on our behalf. BGII requires these third parties to comply strictly with its instructions and BGII requires that they do not use your personal information for their own business purposes, unless you have explicitly consented to the use of your personal information in this way. We will never sell your information to a third party.
• We will only share your information with a third party or transfer your data outside of the UK / EU if we need to. Where we do this we will comply with all of our legal obligations and we ensure that there are adequate protections in place to protect your information.

If we need your consent we will: 

• explain why we need to share your personal information
• explain the purpose for which we will be sharing it
• provide you with details of the third party
• obtain your explicit consent for such.
• You will be able to easily withdraw your consent in the same way in which you gave it.
• Where we rely on a different lawful basis, such as ‘legitimate interests’ or ‘contractual’, we will do so only to the extent permitted by such lawful basis.

08 Offensive or inappropriate content on BGII websites 

If you post or send offensive, inappropriate or objectionable content anywhere on or to BGII websites or otherwise engage in any disruptive behaviour on any BGII service, BGII may use your personal information to stop such behaviour. 

Where BGII reasonably believes that you are or may be in breach of any applicable laws (e.g. because content you have posted may be defamatory), BGII may use your personal information to inform relevant third parties such as your employer, school email/internet provider or law enforcement agencies about the content and your behaviour. 

09 What if I am a user aged 16 or under? 

BGII policy is not to engage nor keep information on persons under 16 years of age. If you are aged 16 or under, please get your parent/guardian to provide any personal information to BGII on your behalf stating clearly the purpose for sharing such information. Only where it is necessary to comply with the law will such information be recorded and kept. 

10 How long will BGII keep my personal information? 

We will hold your personal information on our systems for as long as is necessary for the relevant activity, or as long as is set out in any relevant contract you hold with BGII or BGII corporate retention schedule (a database that defines which documents should be kept and for how long). If your circumstances change a flag goes on the database and, while BGII cannot use the personal information, it stays on the system for a period of one year for administration purposes before being deleted automatically. 

Where you contribute material to BGII we will generally only keep your content for as long as is reasonably required for the purpose(s) for which it was submitted. 

BGII, as brokers of contemporary thought, also has an obligation to record snapshots of history which may include some User Generated Content i.e. content provided by the public. Therefore, some content submitted to, or shared with, BGII may be retained for prolonged periods of time or potentially indefinitely in BGII Archive, which is true of News contributions which are published. There may also be rare instances where we will share your contribution with third parties in the interests of maintaining archives. Where possible, we will endeavour to inform you upfront or let you know at a later date where we are likely to keep content indefinitely. 

11 Can I find out what personal information BGII holds about me? 

Under the Data Protection Act, and General Data Protection Regulations (GDPR) you have the right to request a copy of the personal information BGII holds about you. We will use reasonable efforts to supply, correct or delete personal information about you on our files in accordance with the regulations. Please address requests and questions about this or any other question about this Privacy Policy to the Data Protection Officer, via email  info@bgii.com or to the address at the end of this policy. 

12 What if I am accessing BGII websites outside the UK? 

BGII website is published in the UK by BGII as www.BGII.com The website, www.BGII.com, is also made available to international users accessing the website from outside the UK (and EU). All personal information submitted by non UK citizens will be processed in accordance with this Privacy Policy as if the person was in the UK. 

13 Cookies Policy – Information BGII collects from you 

What is a cookie? 

A cookie is a small amount of data, which often includes a unique identifier that is sent to your computer, tablet or mobile phone (referred to here as a device) browser from a website’s computer and is stored on your device’s hard drive. Each website can send its own cookie to your browser if your browser’s preferences allow it, but (to protect your privacy) your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other websites. Many websites do this whenever a user visits their website in order to track on-line traffic flows. 

On BGII websites, cookies record information about your on-line preferences and allow us to tailor our websites to your interests. 

During the course of any visit to a BGII website, the pages you see, along with a cookie, are downloaded to your device. Many websites do this, because cookies enable website publishers to do useful things like find out whether the device (and probably its user) has visited the website before. This is done on a repeat visit by checking to see, and finding, the cookie left there on the last visit. 

• How does BGII use cookies?
  Information supplied by cookies can help us to analyse the profile of our visitors and help us to provide you with a better user experience. BGII uses this type of information to help improve the services it provides to its users. All third parties are strictly required not to use any information for their own business or other purposes (see section 6 above). 
• Third Party Cookies in embedded content on BGII pages
  Please note that during your visits to BGII websites you may notice some cookies that are not related to BGII or BGII’s When you visit a page with content embedded from, for example, YouTube or LinkedIn, you may be presented with cookies from these websites. BGII does not control the dissemination of these cookies. You should check the third party websites for more information about these. Find out more about third party cookies in embedded content. 
• BGII cookies and how to reject cookies?
  Full information about how BGII uses cookies can be found in the cookies policy section of BGII Privacy & Cookies website post (see below). 

If you wish to control what cookies are set on your device through BGII website then you can find out how to do this in instructions that come with your web browser. It is important to note that if you change your settings and block certain cookies, this means that certain personalised features cannot then be provided and accordingly you may not be able to take full advantage of all of the website’s features. 

14 Changes to BGII’s Privacy Policy 

This Privacy Policy may be updated from time to time so you may wish to check it each time you submit personal information to BGII. The date of the most recent revisions will appear on this page. If you do not agree to these changes, please do not continue to use BGII websites to submit personal information to BGII. If material changes are made to the Privacy Policy we will notify you by placing a prominent notice on the website. 

15 How do we secure your personal data? 

We place a great deal of importance on the security of all personal information. We have in place appropriate technical and security measures which are reviewed routinely. Our approach to information security is validated by our internal security audit performed by the Head of Technology. 

16 Your rights; including your right to object and right to withdraw consent 

We respect and place significant importance on your rights. The recently EU adopted General Data Protection Regulations outlines your rights, and provides further information in relation to those rights and details what we must and will do, when you wish to exercise your rights. In summary, your rights include the right to: 

• Basic information (such as our identity, or that of the controller if not us, the reason and basis on which we process your personal data, together with as much information to ensure fairness and transparency) and to be informed
• Object: to object to processing of personal data where such is done by us in certain circumstances, for example for our legitimate interests or direct marketing
• Withdraw consent: to withdraw your previously given consent
• Access: to be aware of and verify the lawfulness of the processing
• Rectification: to correct personal data if it is inaccurate or incomplete
• Erasure:  to request the removal or deletion of personal data
• Restrict processing:  to restrict the processing of personal data
• Data portability:  to obtain and reuse personal data
• Be aware of any automated decision making or profiling, and to request such is restricted

If you wish to object or to withdraw consent, you may contact us though one of the methods detailed below in the ‘Contact us’ section. In addition, where we have sent you a marketing email, we will have provided an ‘unsubscribe’ or ‘set your preferences’ or ‘opt-out’ link which you can use to stop any future marketing communications. 

17 Contacting BGII about this Privacy Policy 

If you any questions or comments about this Privacy Policy please contact: 

BGII
address coming soon.

Attn: The Data Protection Officer 

Or email: info@bgii.com

For full contact details see:
https://www.bgii.com/contact

Updated 18/01/2021