Privacy Policy
INTRODUCTION
This privacy notice provides you with details about how we collect and process your personal data here at Brazen – vis a vis when you visit and interact with our website (including any information you may provide through our site and when you sign up to our e-shots), plus through our business dealings and engagements (specifically relating to our clients and suppliers).
Brazen Ltd is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
Our email address is gdpr@wearebrazenpr.com. We are registered under number 4239583, and our registered office is Bass Warehouse, 4 Castle Street, Castlefield, Manchester M3 4LZ.
We are registered as a data controller with the UK Information Commissioner’s Office and our data protection registration number is A8274168.
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.
It is very important that the information we hold about you is accurate and up to date. Please do let us know if at any time your personal information changes by emailing us at gdpr@wearebrazenpr.com.
WEBSITE PRIVACY NOTICE
(This section is relevant to anybody visiting our website)
1. Introduction
1.1 We are committed to safeguarding the privacy of our website visitors; in this policy we explain how we will treat your personal information
1.2 By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy
2. Personal information
2.1 We may collect and use the following types of personal info:
- (a) Information about your visits to and use of this website including but not limited to: your IP address, location, browser type, operating system, referral source and website navigation paths
- (b) Information that you provide to us when registering or subscribing. For example your name and email address
- (c) Information contained in any communication that you send to us or send through our website, including metadata associated with the communication
2.2 Before you disclose to us the personal information of another person, you must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with this policy
3. Using personal information
3.1 We may use your personal information to:
- (a) Update our website
- (b) Send you our e-shots, if you have requested them You can inform us at any time if you no longer wish to receive them
- (c) Send you marketing communications relating to our business which we think may be of interest to you
- (d) Keep our website secure and prevent fraud
3.2 We will not supply your personal information to any third party for the purpose of their or any other third party’s direct marketing
4. Disclosing personal information
4.1 We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors if reasonably necessary for the purposes set out in this policy
4.2 We may disclose your personal information:
- (a) To the extent that we are required to do so by law
- (b) In connection with any ongoing or prospective legal proceedings
- (c) In order to establish, exercise or defend our legal rights
5. Retaining personal information
5.2 Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes
5.2 Notwithstanding the other provisions of this Section, we will retain documents (including electronic documents) containing personal data:
- (a) to the extent that we are required to do so by law;
- (b) if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
- (c) in order to establish, exercise or defend our legal rights
6. Security of personal information
6.1 We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information
6.2 We will store all the personal information you provide on our secure firewalled servers
6.3 You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet
7. Amendments
7.1 We may update this policy from time to time by publishing a new version on our website
7.2 You should check this page occasionally to ensure you are happy with any changes to this policy
8. Your rights in relation to personal data
8.1 You can unsubscribe from our marketing communications at any time.
9. Third party websites
9.1 Our website includes hyperlinks to, and details of, third party websites
9.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties
HOW WE USE YOUR PERSONAL DATA
(This section is relevant to clients and suppliers)
We will only use your personal data when legally permitted. The most common uses of your personal data are:
- Where we need to perform the contract between us (if you are a client of Brazen)
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
- Where we need to comply with a legal or regulatory obligation
Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or by post. You have the right to withdraw consent to marketing at any time by emailing us at gdpr@wearebrazenpr.com
Purposes for processing your personal data
Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.
We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us at gdpr@wearebrazenpr.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing |
|---|---|---|
| To register you as a new client | (a) Identity
(b) Contact |
Performance of a contract with you |
| To process and deliver our services including:
(a) Manage payments, fees and charges (b) Collect and recover money owed to us |
(a) Identity
(b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
(a) Performance of a contract with you
(b) Necessary for our legitimate interests to recover debts owed to us |
| To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey |
(a) Identity
(b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests to keep our records updated and to study how customers use our services |
| To enable you to partake in a prize draw, competition or complete a survey | (a) Identity
(b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
(a) Performance of a contract with you
(b) Necessary for our legitimate interests to study how customers use our services, to develop them and grow our business |
| To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity
(b) Contact (c) Technical |
(a) Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise
(b) Necessary to comply with a legal obligation |
| To deliver relevant content and marketing to you and measure and understand the effectiveness of their marketing | (a) Identity
(b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests to study how customers use our services, to develop them, to grow our business and to inform their marketing strategy |
| To use data analytics to improve our website, services, marketing, customer relationships and experiences | (a) Technical
(b) Usage |
Necessary for our legitimate interests to define types of customers for our services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy |
Marketing communications
You will receive marketing communications from us:
(i) If you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications; and
(ii) In each case, you have not opted out of receiving that marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by emailing us at gdpr@wearebrazenpr.com at any time.
Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a service experience or other transactions.
DISCLOSURES OF YOUR PERSONAL DATA
(This section is relevant to clients and suppliers)
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 2 above:
- Service providers who provide IT and system administration services
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances
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.
INTERNATIONAL TRANSFERS
(This section is relevant to clients and suppliers)
We may share your personal data within our group of companies which involves transferring your data outside the European Economic Area (EEA).
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.
We may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
Please email us at gdpr@wearebrazenpr.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
DATA SECURITY
(This section is relevant to clients and suppliers)
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 such data. 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.
DATA RETENTION
(This section is relevant to clients and suppliers)
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.
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 requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we may 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
(This section is relevant to all clients, suppliers and website visitors)
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include 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
- Right to withdraw consent
You can see more about these rights at:
If you wish to exercise any of the rights set out above, please email us at gdpr@wearebrazenpr.com
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 may 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 and keep you updated.