IMPORTANT INFORMATION AND WHO WE ARE
Bluebird is the controller and responsible for your personal data.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority 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.
It is important that the personal data we hold about is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual data from which hat person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes first name, last name, username or similar identifier and date of birth;
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 you have purchased on our platform;
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the website;
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses;
Usage Data includes information about how you use our website, products and services; and
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We 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.
We do not collect any Special Categories of Personal Data about you (this includes details about your race, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic or biometric data). We also do not collect data about criminal convictions and offences.
HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including as follows:
Direct Interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
apply for our products or services;
create an account on our website;
request marketing to be sent to you; or
give feedback or contact us.
Automated technologies or interactions. As you interact with our website we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
Third parties or publicly available sources. We will receive personal data about you from various third parties such as analytics providers data brokers or aggregators and publicly available sources.
HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
where it is necessary for our legitimate interest (or those of a third party) and your interests and fundamental rights do not override those interests; and
where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
Below is a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified our legitimate interest where appropriate.
To register you as an account holder. This collects Identity and Contact Data. This enables you access to buy and sell on our platform and gives those from which you sell/buy the ability to perform their contracts with you.
Manage payments, fees and charges. This collects Identity, Contact, Financial and Transaction Data. It is necessary for the performance of the contract you enter into using our platform.
To administer and protect our business and this website. This will collect Identity and Contact Data for the purpose of maintaining the website and providing this platform. This includes administration, IT services, network security etc.
To make suggestions and recommendations to you about good or services that may be of interest to you. This will collect Identity, Contact, Technical, Usage, Profile and Marketing and Communications Data. This is necessary to develop our business and promote the products listed on our site.
You can ask us or third parties to stop sending you marketing messages at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us.
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 we need your personal data for an unrelated purpose we will notify you and we will explain the legal basis which allows us to do so.
We may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required by law.
DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below for the purposes set out in the ‘PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA” clause above:
Internal Third Parties;
External Third Parties; and
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 specific purposes and in accordance with our instructions.
If we transfer your personal data out of the European Economic Area (“EEA”), we ensure a similar degree of protection is afforded to it.
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
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, contractors 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.
We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, includingfor 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 of our relationship with you.
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 acieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data: see “YOUR LEGAL RIGHTS” below.
In some cases we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You may have the right to
request access to your personal data;
request correction of your personal data;
request erasure of your personal data;
object to processing of your personal data;
request restriction of processing your personal data;
request transfer of your personal data; or
If you wish to exercise any of the rights set out above please contact us.
You will not have to pay a fee to access your personal data (or to exercise any 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 may 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 personal who has no right to receive it. We may also contact you to ask 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 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.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on your (unless we have your consent or are otherwise required to or permitted to by law).
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Internal Third Parties means any other companies in the Bluebird Exchange Limited Group.
External Third Parties means:
any service providors