Effective date: April 26, 2018
For the purpose of the General Data Protection Regulations (“GDPR”), the company in charge of your information (as known as the Data Controller) is BeLogical UK Limited (“BeLogical UK,”us”, “we”, or “our”) of Offices 1, 2 & 3 Damhouse, Astley Hall Drive, Astley M29 7TX (no. 08169856).
1 – Definitions
Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Account Data means the data associated with the activity of an account (for example, campaign history, number data or transaction history).
Cookies are small pieces of data stored on a User’s device.
Lawful Basis means the legal reason for processing Personal Data.
Data Controller means a person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any Personal Data are, or are to be, processed.
Data Processor (or Service Providers)
Data Processor (or Service Providers) means any person (other than an employee of the Data Controller) who processes the data on behalf of the Data Controller.
For the purpose of you uploading Customer Personal Data to the Service, we are the Data Processor.
Customer Data means any Personal Data that is submitted and uploaded to our Service by you in the capacity as the Data Controller.
Data Subject is any living individual who is the subject of Personal Data.
The User is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.
2 – Information Collection
We collect several different types of information for various purposes to provide and improve our Service to you.
Types of Data Collected
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:
We may also collect information how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
As you are assigned a dedicated account to use our Service, we collect information regarding the accounts activity (“Account Data”). This Account Data may include information about your previous campaigns, number data and transactional history.
Tracking Cookies Data
Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyse our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may limit some of the functions of our Service. To learn more about cookies in general please visit https://www.aboutcookies.org.
Examples of Cookies we use:
3 – Use of Data
You have a choice on whether to submit your Personal Data to us:
You may choose to disclose your Personal Data by seeking further information via our websites, registering a new account or over the phone, signing up and accessing an online account, by entering into a contract or interacting with our sales, customer services or helpdesk team.
Provision of this personal information is entirely voluntary but by submitting it to us, you are you affirming your consent for such information to be processed only for the purposes for which you have submitted it to us.
Your Personal Data
BeLogical UK may access and use your personal data only for the purposes for which you have disclosed it to us: (a) to make contact with you in relation to an online, email, SMS or telephone enquiry (b) to provide services to you (c) to process a payment that you have made (d) to process an order that you have submitted (e) to carry out our obligations arising from any contracts entered into by you and us (f) to maintain the operations and security of the services we provide to you (g) to seek your views or comments on the services we provide.
Unless we have obtained your specific consent regarding marketing communication, we will not use your Personal Data for any other purpose.
Your Customers Data
Through our services and websites, we provide you with the facility to upload, store and process Personal Data of your customers (“Customer Data”), in that situation we act as a ‘Data Processor’ and yourself as a ‘Data Controller’. You must ensure that you also comply with the GDPR as you are responsible for your own data as well as the Personal Data you possess, upload and process through the Service offered to you by BeLogical UK. We will not use any Personal Data obtained this way for any other purpose and will not release it to anyone other than yourself, in your capacity as the Data Controller, unless we are required to do so by law.
4 – Retention of Data
We will hold your Personal Data on our systems for as long as is necessary for the relevant service, as long as is set out in any relevant contract you hold with us or for as long as an account is active. If you wish to terminate your account or request that we no longer use your Personal Data, please contact us.
In the case that you wish to cancel your registration as a BeLogical UK account User or in event your account remains inactive for 12-month period we will delete the User information but will retain the account data, such as the invoice history for a period of 6-years, whereupon the information will be permanently deleted from our Service.
We will only ever keep data as is necessary to comply with our legal obligations, resolve disputes and enforce our agreements, contractual or otherwise.
5 – Transfer of Data
The Personal Data that we collect from you as a Data Controller is stored securely on hosted services that require dual authentication to access.
As a Data Processor, all of the Customer Data given to BeLogical UK by you is stored on secure password encrypted servers.
If you are located outside the United Kingdom and choose to provide information to us, please note that we transfer the data, including Personal Data, to inside the EEA and process it there.
Should your Personal Data be processed by any of our GDPR-compliant Service Providers, in order to fulfill our services to you, that are based outside of the EEA – your data and the transfer is protected under the EU-US Privacy Shield framework.
6 – Disclosure of Data
Under certain circumstances, BeLogical UK may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
BeLogical UK may disclose your Personal Data in the good faith belief that such action is necessary to:
7 – Security of Data
The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. However once we receive your information, we make our best effort to ensure its security on our systems.
Where we have given (or where you have chosen) a password which enables you to access certain parts of our Service, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
8 – Your Rights
You have a choice about whether or not you wish to receive information from us. If you do not want to receive direct marketing communications from us about our exciting products and services, then please contact us and we will remove you from any campaigns.
We will not contact you for marketing purposes by post, email, phone or text message unless you have given your prior consent.
BeLogical UK aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.
If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.
In certain circumstances, you have the right:
You have the right to data portability for the information you provide to BeLogical UK. You can request to obtain a copy of your Personal Data in a commonly used electronic format so that you can manage and move it.
Please note that we may ask you to verify your identity before responding to such requests.
We are committed to working with you, if BeLogical UK does not address your request in a reasonable period of time, usually within 30 days or we fail to provide a valid reason why we are unable to deliver on your request, you have the right to contact the ICO to make a complaint. They can be contacted via their website https://www.ico.org.uk or alternatively by telephone 0303 1231113.
9 – Service Providers
BeLogical UK does not and will not sell Personal Data about our customers.
We may employ third-party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analysing how our Service is used.
We may share your information with third-parties for marketing purposes but only on behalf of BeLogical UK and only if we have your consent to receive these marketing communications. These third-parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
We may use third-party Service Providers to monitor and analyse the use of our Service.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://www.google.com/intl/en/policies/privacy/
We may provide paid products and/or services within the Service. In that case, we use third-party services for online payment and Direct Debit processing (e.g. payment processors).
These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information. The payment processors we work with are:
We are also permitted to share some information with third parties who use such data for non-marketing purposes (including credit and risk assessment and management, identification and fraud prevention, debt collection and returning assets to you).
This would include the data you provide to us today, at any time in the past and in the future.
10 – Links to Other Sites
In addition, if you linked to our website from a third-party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third-party site and recommend that you check the policy of that third-party site.
11 – Children’s Privacy
We are concerned to protect the privacy of children aged 16 or under. BeLogical UK services and websites are not directed at children and we do not knowingly collect personally identifiable information from anyone under this age.
If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers and systems..
12 – Sensitive Personal Data
GDPR also specifies a set of Personal Data categories which are deemed ‘sensitive’ and which require special consideration by Data Controllers. BeLogical UK’s websites and available services, do not knowingly collect or process any sensitive Personal Data.
14 – Contact Us