Updated and effective as of [12 December 2019].
This Site is owned and operated by Urban Markets Limited, a company registered in England and Wales under number 11113204 with its registered office at 5th Floor, 10 Finsbury Square, London EC2A 1AF ("Bricks&Logic", “we”, “our”, and “us”).
Bricks&Logic is registered as a data controller with the Information Commissioner’s Office under data protection registration number [to be inserted once registration is complete].
DATA PROTECTION PRINCIPLES
We adhere to the following principles when processing your personal information as data controller:
- Lawfulness, fairness and transparency: data must be processed lawfully, fairly and in a transparent manner.
- Purpose limitation: data must be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
- Data minimisation: data must be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
- Accuracy: data must be accurate and, where necessary, kept up to date.
- Storage limitation: data must be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal information are processed.
- Integrity and confidentiality: data must be processed in a manner that ensures appropriate security of the personal information, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage by using appropriate technical or organisational measures.
PERSONAL INFORMATION WE COLLECT
Information you give us
You may provide us with information by email, over the phone or otherwise communicate or be in contact with us, when:
- you request additional information about our business or ask us to contact you;
- you subscribe to our newsletter;
- we provide our services to you; or
- you send any other information about you to us.
The categories of personal information you provide may include:
- first and last name;
- job title and company name;
- phone number; and
- email address.
We do not generally seek to collect sensitive personal information through our Site or as part of our business transactions. Sensitive personal information is information relating to racial or ethnic origin; political opinions; religious or philosophical beliefs; trade-union membership; health; sex life, sexual orientation; or genetic or biometric information. If we do collect sensitive personal information, we will ask for your explicit consent to our proposed use of that information at the time of collection.
Information we collect from you
We collect, store and use information about your visits to the Site, and about your computer, tablet, mobile or other device through which you access the Site. This includes the following information:
- technical information, including the Internet protocol (IP) address, browser type, internet service provider, device identifier, your login information, time zone setting, browser plug-in types and versions, preferred language, activities, operating system and platform, and geographical location; and
- information about your visits and use of the Site, including the properties you have added to your Dashboard, the properties you have viewed and searched for, full Uniform Resource Locators (URL), clickstream to, through and from our Site, pages you viewed and searched for, page response times, length of visits to certain pages, referral source/exit pages, page interaction information (such as scrolling, clicks and mouse-overs), date and time pages are accessed, and website navigation and search terms used.
We may also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. For example, we may use Aggregated Data to publish report on trends in the usage of our applications and services. Aggregated Data could be derived from your personal information but is not considered personal information as this data will not directly or indirectly reveal your identity.
The Site is not intended for or directed at persons under the age of 18 years and we do not knowingly collect information relating to children under this age.
WHAT WE DO WITH YOUR PERSONAL INFORMATION
As data controller, we will only use your personal information if we have a legal basis for doing so. The purpose for which we use and process your information and the legal basis on which we carry out each type of processing is explained in the table below.
Purposes for which we will process the information
Legal Basis for the processing
To enable you to access and use our Site and to allow us to supply services to you.
Such processing is necessary for our legitimate interests in providing a service to our customers.
To carry out our obligations arising from any contracts entered into with you.
It is necessary for us to process your personal information in this way in order to enter into a contract with you and to fulfil our contractual obligations to you.
To send you promotional materials and other materials that may be of interest to you, including information about us, our services, events or general promotions.
It is necessary for our legitimate interests to develop our services and grow our business. To ensure we offer an efficient service, we consider this use to be proportionate and will not be prejudicial or detrimental to you. You can unsubscribe or opt-out from receiving these communications at any time by clicking the “unsubscribe” link in the email.
To provide you with information and materials that you request from us.
It is in our legitimate interests to respond to your queries and provide any information and materials requested in order to generate and develop business.
To send you information regarding changes to our policies, other terms and other administrative information such as reminders, technical notices, updates and security alerts.
It is in our legitimate interests to ensure that any changes to our policies, terms and other such technical updates are communicated to you.
For both these categories, it is in our legitimate interests to continually monitor and improve our services and your experience of the Site and to ensure network security.
To help create and maintain a trusted and safe environment on the Site by, among other things, detection and prevention of fraud and other harmful activity, conducting investigations and risk assessments, verifying any identifications provided by you, and conducting checks against databases and information sources for fraud detection and prevention, risk assessment and harm prevention purposes.
It is in our legitimate interests to carry out such checks to ensure prevention against fraud and other harmful activity and that our Site and platform is safe and secure.
Other than as described above, we do not generally rely on consent as a legal basis for processing your personal information although we may need your consent before sending direct marketing communications to you via email or text message in certain circumstances. Where you provide consent, you can withdraw your consent at any time and free of charge, but without affecting the lawfulness of processing based on consent before its withdrawal. You can update your details or change your privacy preferences by contacting us as provided in the Contacting Us section above.
DISCLOSURE OF YOUR PERSONAL INFORMATION TO THIRD PARTIES
Personal information will be shared with our third party service providers and business partners who assist with the running of the Site and the operation of our business including third party hosting providers. Our third party service providers and business partners are subject to security and confidentiality obligations and are only permitted to process your personal information for specified purposes and in accordance with our instructions.
In addition, we may disclose information about you:
- to our professional advisers including lawyers, auditors and insurers;
- in the event that we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets;
- if all or substantially all of our assets are acquired by a third party, in which case personal information held by it about you will be one of the transferred assets;
- if we are under a duty to disclose or share your personal information in order to comply with any legal or regulatory obligation. We will use commercially reasonable efforts to notify you where this is the case, to the extent permitted by law;
- if necessary, to protect the vital interests of a person; or
- to enforce or apply our contracts or to establish, exercise or defend the rights of Bricks&Logic, its staff or other related persons.
Where we collect personal information from you, it may be necessary for us to transfer your personal information outside of the UK or the European Economic Area (“EEA”) to our service providers and business partners located outside the UK or the EEA.
Where personal information is transferred to and stored in a country not determined by the European Commission as providing adequate levels of protection for personal information, we take steps to provide appropriate safeguards to protect your personal information, including entering into standard contractual clauses approved by the UK or the European Commission, obliging recipients to protect your personal information.
If you would like further information on the specific mechanism used by us when transferring your personal information outside of the UK or the EEA, please contact us using the details set out in the Contacting Us section above.
SECURITY OF YOUR PERSONAL INFORMATION
We use appropriate technical and organisational security measures to protect personal information both online and offline from unauthorised use, loss, alteration or destruction. We use physical and procedural security measures to protect information from the point of collection to the point of destruction. Where data processing is carried out on our behalf by a third party, we take steps to ensure that appropriate security measures are in place to prevent unauthorised disclosure of personal information.
Despite these precautions, however, we cannot guarantee the security of information transmitted over the Internet or that unauthorised persons will not obtain access to personal information.
HOW LONG WE KEEP YOUR PERSONAL INFORMATION
We will only retain your personal information 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 information 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 information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
ACCESS TO AND UPDATING YOUR PERSONAL INFORMATION
You have the right to access information which we hold about you (“data subject access request”).
You may also have the right to receive personal information which you have provided to us in a structured and commonly used format so that it can be transferred to another data controller (“data portability”). The right to data portability only applies where your personal information is processed by us with your consent or for the performance of a contract and when processing is carried out by automated means.
We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate. Please keep us informed if your personal information changes during your relationship with us.
RIGHT TO OBJECT
You have the right to object at any time to our processing of your personal information for direct marketing purposes.
Where we process your information based on our legitimate interests
You also have the right to object, on grounds relating to your particular situation, at any time to processing of your personal information which is based on our legitimate interests. Where you object on this ground, we shall no longer process your personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.
YOUR OTHER RIGHTS
You also have the following rights under data protection laws to request that we rectify your personal information which is inaccurate or incomplete.
In certain circumstances, you have the right to:
- request the erasure of your personal information: this enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it (“right to be forgotten”); and
- restrict the processing of your personal information.
Please note that the above rights are not absolute and we may be entitled to refuse requests, wholly or partly, where exceptions under the applicable law apply.
For example, we may refuse a request for erasure of personal information where the processing is necessary to comply with a legal obligation or necessary for the establishment, exercise or defence of legal claims. We may refuse to comply with a request for restriction if the request is manifestly unfounded or excessive.
EXERCISING YOUR RIGHTS
Where we have reasonable doubts concerning the identity of the person making the request, we may request additional information necessary to confirm your identity.
COOKIES AND SIMILAR TECHNOLOGIES
The Site may, from time to time, contain links to and from the websites of our business partners, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.