Privacy Policy
 

1). INTRODUCTION 
1. What This Privacy Notice Covers
The purpose of this Privacy Notice is to explain how Charterhouse Systems Associates Ltd., a UK corporation ("BP Group," "we," "us," or "our"), as the data controller secures, shares, and uses personal information that it collects and receives from you through its website (www.bpgroup.org), website hosting and design services, communication tools, mobile applications, app marketplace, ecommerce tools, and other services (collectively, the “Service”).  If you have any questions or concerns regarding this Privacy Notice or our practices, please see the “Contact details” section below.
Contact Details
Our full details are:
Full name of legal entity: Charterhouse Systems Associates Ltd T/A BP Group
Email address: privacy@bpgroup.org
Postal address: 124 New Bond House, New Bond Street, London, W1S 1DX.
Telephone number: 0203 3030 894
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at privacy@bpgroup.org

2).  WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND WE PROCESS IT
Personal data means any information capable of identifying an individual. It does not include anonymised data.
We may process the following categories of personal data about you:

• Communication Data that includes any communication that you send to us whether that be through the contact form on our website (created via Weebly, based outside of the EU, privacy policy here), through email, text, social media messaging (such as Facebook or LinkedIn), social media posting, by business card or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
• Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, job title, billing address, delivery address, email address, phone number, contact details, training location preferences, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
• User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.
• Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.
• Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as services, products, competitions, prize draws and free give-aways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. If you sign up to special offers and information via our newsletter, your details are stored on Constant Contact, there is an easy unsubscribe on all Newsletters. We limit the number of emails to specifically location-based interest. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.
• We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).

Sensitive Data
We do not collect any Sensitive Data about you. Sensitive data refers to data that 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. We do not collect any information about criminal convictions and offences.
We require your explicit consent for processing sensitive data, so when you submit your details you will be asked to confirm your consent to this processing.
Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.
We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at privacy@bpgroup.org. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
We do not carry out automated decision making or any type of automated profiling.

3).  HOW WE COLLECT YOUR PERSONAL DATA
We may collect data about you by you providing the data directly to us (for example by filling in forms on our website, by sending us emails, by telephoning us, providing your business card or signing up to our newsletter). We may automatically collect certain data from you as you use our website by using cookies and similar technologies. Please see our cookie policy below for more details about this. 
We may receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as Facebook based outside the EU, such as search information providers such as Google based outside the EU, providers of technical, payment and delivery services, such as Eventbrite based outside the EU (privacy policy can be viewed here), data brokers or aggregators.
We may also receive data from publicly availably sources such as Companies House and the Electoral Register based inside the EU. 

4).  MARKETING COMMUNICATIONS
Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).
Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However, you can still opt out of receiving marketing emails from us at any time.
Before we share your personal data with any third party for their own marketing purposes we will get your express consent.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing us at privacy@bpgroup.org at any time.
If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc.

5).  DISCLOSURES OF YOUR PERSONAL DATA 
We do not share your information with third parties, other than those required by law or business purpose, detailed below. We will never sell your information to third parties.
Your information may be shared with our trusted partners for billing purposed and location specific training, for example:
Charterhouses Ltd, a UK corporation, who are authorized to provide our services, fulfil billing and marketing purposes.
And;
IQ Business, a South Africa corporation, who are authorized to provide our services, fulfil billing and marketing purposes.
This is only done with your knowledge and request for information or billing.
We may have to share your personal data with the parties set out below:

• Service providers who provide IT and system administration services.
• Professional advisers including lawyers, bankers, auditors and insurers
• Government bodies that require us to report processing activities.
• Third parties to whom we sell, transfer, or merge parts of our business or our assets.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

6).  INTERNATIONAL TRANSFERS 
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:

• We will only transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or
• Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
• If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

7).  DATA SECURITY
We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.
 
8).  DATA RETENTION 
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.
For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.
In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
 
9).  YOUR LEGAL RIGHTS 
Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.
You can see more about these rights at:
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
If you wish to exercise any of the rights set out above, please email us at privacy@bpgroup.org. 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 or refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may 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.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

10).  THIRD-PARTY LINKS
Of course, other sites that we have links to are not in our control and this privacy policy does not cover the links within this site that go elsewhere. Where you do find links on this site they have been put there because we think they may have something of use to you.

11).  COOKIES
Cookies are small, harmless, helpful files which are stored on your computer in order to gather information or to aid the functionally of a website. Cookies are extremely common and are used by almost every website you visit.
Cookies will not harm your computer. We do not store identifiable information such as your name, address or credit card details in cookies.
We use cookies to gather information on visitor’s journeys through our website. Collecting this information allows us to understand how visitors use our website and gives us the ability to improve and tailor our website to the needs of our users.
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, visit www.allaboutcookies.org. If you wish to block cookies there are lots of ways of doing this and you will still be able to view our website. 
Like many other websites we use cookies to customise content and advertising, to provide social media features and to analyse traffic to my site. We also share information about your use of our site with our trusted social media, advertising and analytics partners. The Cookies we use are Google Analytics.

12).  CHANGE LOG:
May 23, 2018: Changes were made to this notice in accordance with the General Data Protection Regulation.
 
13).  CHANGES TO THIS PRIVACY NOTICE:
BP Group reserves the right to revise, modify, or update this notice at any time. We will notify you about material changes in the way we treat personal information by sending a notice to the primary email address specified in your communications or by placing a prominent notice on our site.