1.1 We are committed to safeguarding the privacy of bbird.co.uk website visitors and service users.
1.2 This policy applies where we are acting as the Data Controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
1.5 In this policy, “we”, “us” and “our” refer to bbird.co.uk. For more information about us, see Section 13.
2. Information we collect from you
2.1 We will collect and process the following data about you:
2.1.1 Information you give us. Information about you that you give to us by filling in forms on our Site www.bbird.co.uk (’Site’) or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our Site, subscribe to our service, search for a product, place an order on our site, participate in discussion boards or other social media functions on our Site, enter a competition, promotion or survey and when you report a problem with our site.
2.1.2 Information we collect about you. With regard to each of your visits to our site we will automatically collect the following information:
184.108.40.206 technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
220.127.116.11 Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Site (including date and time), products you viewed or searched for’, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page and any phone number used to call our customer service number.
3. How we use your personal data
3.1 In this Section 3 we have set out:
3.1.1 the general categories of personal data that we may process;
3.1.2 in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
3.1.3 the purposes for which we may process personal data; and
3.1.4 the legal bases of the processing.
3.2 We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is wix.com, the bbird.co.uk website and chat service and Google Analytics. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is legitimate interest, namely monitoring and improving our website and services.
3.3 We may process your account data (“account data”). The account data may include your name, phone number and email address. The source of the account data is you. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases. The legal basis for this processing is legitimate interest.
3.4 We may process your information included in your personal profile on our website (“profile data”). The profile data may include your name; address; telephone number; email address. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is legitimate interest.
3.5 We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is Consent and this is provided by you selecting to Opt-In to this processing via our preference centre or via the registration process
3.6 We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is legitimate interest, namely the proper administration of our website and business and communications with users.
3.7 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is legitimate interest, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
3.8 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is legitimate interest, namely the proper protection of our business against risks.
3.9 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
3.11 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
4. Providing your personal data to others
4.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
4.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4.3 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject.
6. Retaining and deleting personal data
6.1 Section 6 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. Our retention of your personal data is linked to your actions.
6.3 We will retain your personal data as follows: Type of data Retention period defined in the data retention policy
6.4 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
7.1 We may update this policy from time to time by publishing a new version on our website.
7.2 We will notify you of changes to this policy by email.
8. Your rights 8.1 In Section 8, we have summarised the rights that you have under current data protection legislation. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the Information Commission’s Office (www.ico.org.uk) for a full explanation of these rights. You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:
8.1.1 The supply of appropriate evidence of your identity for this purpose, we will usually accept an original copy of a utility bill showing your current address.
8.2 Your principal rights under data protection law are:
8.2.1 the right to access;
8.2.2 the right to rectification;
8.2.3 the right to erasure;
8.2.4 the right to restrict processing;
8.2.5 the right to object to processing;
8.2.6 the right to data portability;
8.2.7 the right to complain to a supervisory authority; and
8.2.8 the right to withdraw consent.
8.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data.
8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
8.5 In some circumstances, you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
8.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
8.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
8.9 To the extent that the legal basis for our processing of your personal data is:
8.9.1 consent; or 8.9.2 that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
8.10 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
8.11 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
8.12 You may exercise any of your rights in relation to your personal data by emailing email@example.com in addition to the other methods specified in this Section 8.
9. About cookies
9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
9.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
9.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
10. Cookies that we use
12. Managing cookies
12.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can, however, obtain up-to-date information about blocking and deleting cookies via these links:
12.1.1 https://support.google.com/chrome/answer/95647?hl=en (Chrome);
12.1.2 https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website- preferences (Firefox);
12.1.3 http://www.opera.com/help/tutorials/security/cookies/ (Opera);
12.1.4 https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete- manage-cookies(Internet Explorer);
12.1.5 https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data- sfri11471/mac(Safari);
12.2 Blocking all cookies will have a negative impact upon the usability of many websites.
12.3 If you block cookies, you will not be able to use all the features on our website.
13. Our details
13.1 This website is owned and operated by Bluebird
13.2 Our principal place of business is in Surrey. UK 13.3.1 by email, using the email address published on our website from time to time. 13.3.2 using our website contact form; 13.3.3 by telephone, on the contact number published on our website from time to time.
14. Data protection lead
14.1 Our data protection lead’s email address is firstname.lastname@example.org