Blue International Holdings Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, BlueHoldings.com, and will only collect and use personal data through it in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
means an account required to access and/or use certain areas and features of our Site;
means a small text file placed on your computer or device by our Site when you visit certain parts of our Site and/or when you use certain features of our Site; and
means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003.
Information About Us
Our Site is owned and operated by Blue International Holdings Limited, registered in England under company number 10638438.
Registered address: 5th Floor West, Cottons Centre, 47-49 Tooley Street, London SE1 2QN
VAT number: 342 8170 10
Data Protection Officer: Howard Shaw.
Email address: Howard.Shaw@BlueHoldings.com.
Telephone number: +44 (0) 207 499 7985
Postal address: 5th Floor West, Cottons Centre, 47-49 Tooley Street, London SE1 2QN
What Does This Policy Cover?
What Is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data and other online identifiers.
What Are Your Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
· The right to be informed about our collection and use of your personal data.
· The right to access the personal data we hold about you.
· The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete.
· The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold.
· The right to restrict (i.e. prevent) the processing of your personal data.
· The right to object to us using your personal data for a particular purpose.
· The right to withdraw consent once given. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
· The right to data portability. This means that if you have provided personal data to us directly, and we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
· Rights relating to automated decision-making and profiling. Please note that we do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights, please contact us using the details provided above.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed for so long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office (www.ico.org.uk).
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve any concerns you may have ourselves, however, so please contact us in the first instance.
What Data Do We Collect?
We may collect and process the following data about you:
· Information that you provide by filling in forms on our Site. This includes information provided at the time of registering to use our Site, subscribing to our service, posting material or requesting further services. We may also ask you for information if you report a problem with our Site.
· If you contact us, we may keep a record of that correspondence.
· Details of your visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data and the resources that you access.
We do not collect any ‘special category’ or ‘sensitive’ personal data as defined by the Data Protection Legislation.
How Do We Use Your Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. We use information held about you in the following ways:
· To ensure that content from our Site is presented in the most effective manner for you and for your device.
· To provide you with information which we feel may interest you, where you have consented to be contacted for such purposes.
· To allow you to participate in interactive features of our Site, when you choose to do so.
· To notify you about changes to our Site.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and/or telephone or post, with information and news about our business. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
Third parties whose content appears on our Site may use third-party Cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third party.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
How Long Will We Keep Your Personal Data?
We will not keep your personal data for any longer than is necessary in light of the purpose(s) for which it was first collected. Subject to the above principle we shall not retain your data, unless actively renewed, for more than 24 months.
How and Where Do We Store or Transfer Your Personal Data?
The security of your personal data is very important to us and to protect your data, we take a number of measures, including the following:
· limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
· procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so;
· encrypting data and password protecting documents containing personal data.
· Using secure storage servers.
We may store and may transfer some of your personal data within the UK or the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the Data Protection Legislation, GDPR, and/or to equivalent standards by law.
We share your data within the group of companies of which we are a part. Where this involves the transfer of personal data outside the EEA, our group ensures that personal data is protected by requiring all companies within the group to follow the same rules with respect to personal data usage that we apply.
We may store or transfer some or all of your personal data to countries that are not part of the EEA. These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK.
We may transfer your personal data to third countries whose levels of data protection are deemed ‘adequate’ by the European Commission. For external third parties we will use specific contracts that require the same levels of personal data protection that would apply under Data Protection Legislation in the UK.
Should we transfer your data to a third party based in the United States, the data may be protected if they are part of the EU-US Privacy Shield. This requires the third party to apply data protection to standards similar to those in Europe.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
By submitting your personal data, you agree to this transfer, storing or processing.
Do We Share Your Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.
· In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
· We may share your personal data with other companies in our group including subsidiaries or our holding companies and subsidiaries.
· We may sometimes contract with the third parties to supply certain services, for example audit services.
How Can You Control Your Personal Data?
In addition to your rights under the Data Protection Legislation, when you submit personal data via our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes, including the ability to unsubscribe from further contact.
You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service, the Corporate Telephone Preference Service and the Mailing Preference Service. These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
Can You Withhold Information?
You may access certain areas of our Site without providing any personal data at all. However, to use all features and functions available on our Site you may be required to submit or allow for the collection of certain data.
How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
We ask that subject access requests are made in writing and sent to the email or postal addresses shown above. Although there is no particular form to complete this link provides details of things you should include (and not include) within your request: https://ico.org.uk/your-data-matters/your-right-to-get-copies-of-your-data/preparing-and-submitting-your-subject-access-request/
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within one month. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request.
By using our Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. These third-party Cookies are not integral to the functioning of our Site and your use and experience of our Site will not be impaired by refusing to consent to them.
All Cookies used by and on our Site are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be provided a prompt requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of our Cookies; however certain features of our Site may not function fully or as intended should you decline.
Certain features of our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
In addition to the controls that we provide during use of our Site, you can choose to enable or disable Cookies directly in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.