Legal Notices

We respect your privacy and are committed to protecting your personal data.

This privacy policy aims to give you information on how Business Clan Ltd (“we”, “us” or “our”) collects and processes your personal data, including any data you may provide through your use of our website (e.g. through using our website contact form), when you email or telephone us, when you/your organisation enters into a contract for services with us or when you apply to work with us. We are the controller and are responsible for your personal data.

Our 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 privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements any privacy notices and is not intended to override them.

If you have any questions about this privacy policy, our privacy practices or the information we hold about you, please contact our Data Protection Lead in the following ways:

Full name of legal entity: Business Clan Ltd
Email address: privacy@businessclan.com
Postal address: 16 West Barnes Lane, West Wimbledon, SW20 0BU

You have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

If you want to submit a written complaint to us about how we handle your personal information, please contact us or email us at privacy@businessclan.com. If you make a privacy complaint, we will respond to let you know how your complaint will be handled. We may ask you for further details, consult with other parties and keep records regarding your complaint.

We keep our privacy policy under regular review and it is subject to change from time to time without notice. Changes may be made when our business practices change or when data privacy laws are updated. You should therefore check this policy regularly to ensure that you are aware of any changes. Historic versions can be obtained by contacting us.

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.

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

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 the following personal data about you:

• Attendance and Events Data includes attendance records for Company-related meetings/training courses and feedback forms in relation to any events we may organise.
• Business Data includes data identifying you in relation to matters on which you/your organisation instructs us or in which you are involved.
• Contact and Identity Data includes your name, title, marital status, date of birth, gender, position, role, company or organisation, physical address, email address and telephone numbers (including mobile phone number). In relation to due diligence under relevant anti-money laundering regulations or right to work checks this may include passport and/or driving licence and/or other forms of identification.
• Criminal Convictions Data includes information such as the existence of prior criminal offences or confirmation of clean criminal record.
• Financial Data includes bank account and payment card details.
• Health Data includes information that relates to your health status, including information relating to dietary, disability or similar requirements for events and meetings.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Profile Data includes any usernames and passwords (e.g. for access to extranets and other client services or platforms), purchases or orders made by you/your organisation, your interests, preferences, feedback and survey responses.
• Qualifications Data includes details relating to academic and professional qualifications which we may require in relation to recruitment.
• Social Media Data means posts, likes, tweets and other interactions with our social media presence.
• Supplier Data means contact details and other information about you/your organisation where you provide services to us.
• Technical Data includes internet protocol (IP) address, browser type and version (e.g. Internet Explorer, Firefox, Safari), device type, hardware model, MAC address, unique identifiers, mobile network information, time zone setting and location, browser plug-in types and versions, operating system and platform (e.g. Windows, MacOS, Vista), and other technology on the devices you use to access our website.
• Transaction Data includes details about payments to and from you/your organisation and other details of services and products you/your organisation have purchased from us.
• Usage Data includes information about how you use our website, services and products.

Please note that we may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We will only collect 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) with your explicit consent or, if you are or become one of our employees, where the processing is necessary for the purposes of exercising your or our employment law rights or obligations. We do not collect any information about criminal convictions and offences other than where permitted by law and appropriate to do so e.g. under our legal obligations to conduct anti-money laundering checks.

Where we need to collect personal data by law, or under the terms of a contract we have with you/your organisation, 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/your organisation (for example, to provide you with services). In this case, we may have to cancel the service you/your organisation has with us but we will notify you if this is the case at the time. Where we collect personal data with your explicit consent (e.g. Health Data collected in relation to an event) we may not be able to respond to your particular needs or preferences if you fail to provide us with such information.

1. Information which you provide us through direct interactions

You provide us with personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal information you provide when you:

• enquire about or apply for our services or products;
• enquire about a job advertisement;
• subscribe to our newsletter;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us feedback or contact us.

2. Information we collect about you

We collect information about you when you engage with us online or by email e.g. when you visit our website, open or forward an email sent by us, engage with us on social media networks or when you are served one of our tailored adverts. Information may be collected via cookies and similar technologies, as detailed below.

3. Information we receive from third parties or publicly available sources

We may, if this is permitted by law, receive personal data about you from various reputable third parties or public sources as set out below:

• social media sites such as Facebook;
• advertising networks such as Google;
• professional networks or directories such as Chambers of Commerce;
• analytics providers such as Google;
• search engine providers;
• networking event providers;
• business partners;
• recruitment agencies;
• publicly available sources such as Companies House;
• providers of technical, payment and delivery services such as PayPal and Stripe;
• identity and credit reference agencies; and
• Disclosure and Barring Service (“DBS”) check providers such as uCheck.

We use your information:

• where it is necessary for the preparation or performance of a contract with you/your organisation;
• where it is necessary in connection with a professional or legal obligation (e.g. in relation to anti-money laundering regulations);
• to verify your identity;
• so that we can tell you about other products or services that may be of interest to you/your organisation;
• to personalise and improve our services to you/your organisation;
• to respond to your requests for information and services;
• (if you/your organisation has a business or professional relationship with us) to develop our business relationship with you/your organisation;
• if you apply to work with us as an employee or consultant to consider you in relation to such role;
• to conduct research, statistical analysis and behavioural analysis;
• to compile anonymous statistics, for example, website usage statistics;
• to customise our website and its content to your particular preferences;
• to notify you of any changes to our website or to our services that may affect you/your organisation;
• to detect and prevent fraud;
• for other everyday business purposes, such as payment processing and financial account management, contract management, website administration, analytics, corporate governance, reporting and legal compliance;
• where we otherwise consider such use of your information as not detrimental to you, within your reasonable expectations and necessary to fulfil our legitimate business interests.

We have set out below, in a table format, a more detailed description of all the ways we may use your personal data, and which of the lawful bases we may rely on to 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 basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific lawful basis we are relying on to process your personal data where more than one lawful basis has been set out in the table below.

We recognise that your information is valuable and will take all reasonable measures to protect your information while it is in our care (see how below).

We may share your personal data with the parties set out below for the purposes set out in the table above.

• Service providers who process information on our behalf, including providers of:
• IT and system administration services such as Office 365 and Zoho CRM Platform
•  identity management
• DBS checks such as uCheck
• right to work checks such as veriphy
• event management and ticketing providers such as Eventbrite
• payment services such as Paypal and Stripe
• accounting and tax software such as Xero, Quickbooks, Sage, Fluidly and taxfiler
• website hosting and management such as Squarespace and SiteGround
• data analysis, data back-up, security and storage services such as Sharepoint and Dropbox
• Contractors, consultants and professional advisers (including lawyers, bankers, auditors and insurers) that provide a service to us or act as our agents.
• Insurance companies, law enforcement, regulatory or other government agencies for the purposes of fraud prevention and/or to comply with any legal and regulatory issues and disclosures.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We may also share certain pieces of aggregated, non-personal information about you with third parties. For example, we may provide a third party with information such as the number of users who searched for a particular term or how many users clicked on a particular advertisement. This information does not identify you individually.

We do not sell, rent, distribute or otherwise make personal information commercially available to any third party except as described in this policy or with your prior permission.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

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.

Personal data which you submit to us will only be retained for as long as is required for the purposes for which it was collected. We will also take into account our need to meet any legal, statutory or regulatory obligations. Our need to use or retain your information will be reassessed on a regular basis and information which is no longer required will be disposed of.

We use cookies and similar technologies such as pixel tags and web beacons on our website and in some of our emails.

1. What is a cookie?

A cookie is a small text file which is sent to and stored on your computer (or other electronic device) to identify you whenever you visit a website.

There are many types of cookies but broadly they can be grouped by purpose:

• strictly necessary e.g. to make a website work;
• performance e.g. to provide and improve services;
• functionality e.g. to personalise content when you return to a website;
• targeting e.g. to deliver tailored advertising to you and to others.

Cookies can also be grouped according to whether they are ‘first-party’ cookies or ‘third-party’ cookies. The difference is that first-party cookies are placed and controlled by the website you are visiting whereas third-party cookies are placed and controlled by a third-party.

2. What are pixel tags and web beacons?

Pixel tags and web beacons are tiny graphic images embedded in a web page or in emails to achieve similar purposes as those described above.

3. How and why we use cookies and similar technologies

We use the following cookies and similar technologies:

• Strictly necessary cookies to verify who you are if and when you log in to our website.
• Zoho cookies to securely collect information via forms on our website.
• Google Analytics cookies for statistical purposes to collect data about website usage. This data does not include personally identifiable information.
• Google Ads, Google DoubleClick, Facebook, LinkedIn and Zoho cookies to determine whether you have performed a specific action when you engage with us via an advertising or email campaign, or visit our website, so that we can select and carefully tailor the products and services that we market to you and improve our web pages, promotions and our communications with you.

To learn how to manage cookies and control your privacy and how to opt out of receiving marketing materials, please read the relevant sections below. For a detailed cookie report, please contact us.

4. How to manage cookies and control your privacy

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, please visit www.allaboutcookies.org and www.youronlinechoices.com/uk/. For some helpful videos about cookies please visit www.youronlinechoices.com/uk/helpful-videos.

You can choose to disable cookies in your internet browser but please note that if you delete cookies or decline to accept them you may not be able to use all of the features we offer, or store your preferences; in addition, some of our web pages might not display properly. If you want to turn off the more invasive cookies but leave most other functionality in working order, then a good option is to turn off third-party cookies using your browser settings.

In addition, we recommend that you check your privacy settings on any site which requires you to register or login, and that you never save your passwords in your browser or on your device, other than in a reputable password management system.

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, consultants 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.

While we will use all reasonable efforts to safeguard your personal data you acknowledge that the use of the internet is not entirely secure and understand that we cannot guarantee the security or integrity of any personal data that is transferred from you or to you via the internet. If you want detailed information on how to protect your information and your computers and devices against fraud, identity theft, viruses and other online problems you can visit Get Safe Online, which is supported by HM Government and leading businesses.

Whenever we transfer your personal data out of the UK we will ensure that at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data (e.g. the UK has recognised that the EU and EEA member states are adequate).
• We will obtain your explicit consent for the transfer.
• We will use standard contractual clauses (SCCs) approved for use in the UK which gives your personal data a similar degree of protection that is afforded to it in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

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/your organisation.

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, business efficiency needs and the applicable legal, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available by contacting us.

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

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

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:

• If you want us to establish the data’s accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services or products to you. We will advise you if this is the case at the time you withdraw your consent.

You can exercise your rights by contacting us. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

You have the right to opt out from receiving marketing emails from us. You can do this by contacting us or by clicking on the relevant link in the email itself. You may choose to opt out of one or all lists.