Welcome to the Buy Women Built (“BWB”) privacy policy.
1 Important information and who we are
Purpose of this privacy policy
This privacy policy sets out how BWB collects and uses the personal data of its members and individuals who are part of the BWB network. Whilst our members are brands, the personal data collected by BWB is that of individuals. The purpose of this is to allow BWB to manage its membership programme and promote the interests of the BWB brands.
Please read this privacy policy carefully to understand what data BWB collects from you as a membership applicant or member (“you” or “your”), how it is used, the lawful basis and purpose for doing so and your rights.
Controller
Buy Women Built Limited (Registration Number: 13815299) is the data controller and responsible for your personal data.
If you have any questions about this privacy notice or our data protection practices, please contact us through our website contact form located at CONTACT | Buy Women Built
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.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated on 30 March 2023.
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.
2 Information we collect about you
You may give us information about you by completing our BWB Brand Submission Form, contacting us by phone or e-mail or in person. This includes information you provide if you complete a membership application on behalf of a business to become a BWB member.
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 different kinds of personal data, which may cover information such as: name, date of birth, job title, address, business address, e-mail address, phone number,
financial and debit card information, marketing and communications data and data relating to access or dietary requirements. Personal data covers any information from which you can be identified.
We also collect information regarding BWB events which we require for the purposes of event attendance. We collect data through direct interactions, and occasionally through third parties and publicly available sources.
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.
Certain categories of data such as information relating to ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic, biometric or health information are ‘special categories’ of data. We ask you to provide information regarding your ethnicity as part of your membership application to us. We will get your express opt-in consent before we use this data and you are under no obligation to provide this to us. If such data is provided we will use it to monitor and report statistics about diversity of BWB members and attendees at our events.
3 If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, 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 (for example, to provide you with membership services). In this case, we may have to cancel a membership service you have with us but we will notify you if this is the case at the time.
4 Use of your personal data
We will only use your personal data when the law allows us to. Most commonly we will use your data in the following circumstances:
4.1 To administer your BWB membership application;
4.2 To provide membership services;
4.3 To contact you in relation to member surveys;
4.4 To inform you of any other relevant services, those of BWB and other parties whose products and/or services we have agreed should be made available to you;
4.5 To update and correct our membership records;
4.6 To organise BWB events;
4.7 To circulate newsletters; and
4.8 To promote BWB members.
5 Legal basis for collecting, holding and using your data
We have set out below the lawful legal bases which allows BWB to collect, hold and use your personal data. Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which you are using your data.
5.1 Performance of a contract with you: examples of this cover completing your BWB membership application, managing our membership records and relationships, conducting BWB member surveys.
5.2 Necessary for our own legitimate interest: BWB have a legitimate interest in being able to provide services to our BWB members which requires us to collect and use personal data about individuals. This legal basis is only used where these interests are not overriding by your interests and fundamental rights or freedoms.
5.3 Necessary to comply with a legal obligation: for example this covers managing our relationships with BWB members and notifying you of any changes to our policies.
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.
Please contact us if you need details about the specific legal ground, we are relying on to process your personal data.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
6 Sharing your information
We may share your personal data with third parties, including in the following situations:
6.1 Event organisers: BWB may share your information with event venues, sponsors and organisers;
6.2 Service providers: who provide system administration services;
6.3 Professional advisers: including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services; and
6.4 HM Revenue & Customs, regulators and other authorities: based in the United Kingdom who require reporting of processing activities in certain circumstances.
7 International Transfers
We do not transfer your personal data outside the UK.
8 Data Security
We have implemented 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.
9 Data Retention
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.
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, and the applicable legal, regulatory, tax, accounting or other requirements. Details of retention periods for different aspects of your personal data can be requested from us by contacting us.
10 Your Legal Rights
Under certain circumstances you have the following rights under data protection laws in relation to your personal data:
10.1 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;
10.2 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;
10.3 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;
10.4 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;
10.5 Request restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
10.5.1 If you want us to establish the data’s accuracy;
10.5.2 Where our use of the data is unlawful, but you do not want us to erase it;
10.5.3 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;
10.5.4 You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it;
10.6 Request 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; and
10.7 Right to 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 to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
11 No fee usually required
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.
12 What we may need from you
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.
13 Time limit to respond
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.