What is the purpose of this document?
Broadway Partners Limited is committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information about you, in accordance with the General Data Protection Regulation (GDPR) which will come into force on 25 May 2018, and the Data Protection Act 2018). It applies to all customers, potential customers and users of our website, goods and services.
Broadway Partners Limited is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
Data protection principles
We will comply with data protection law. This says that the personal information we hold about you must be:
1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.
The kind of information we hold about you
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). There are “special categories” of more sensitive personal data which require a higher level of protection.
We will collect, store, and use the following categories of personal information about you:
* your name, age/date of birth and gender;
* your contact details: postal address including installation, billing and delivery addresses, telephone numbers (including mobile numbers) and e-mail address;
* your current broadband speed;
* property ownership/tenancy status;
* any previous government grants or subsidies;
* purchases and orders made by you;
* your IP address;
* your on-line browsing activities on our Website;
* your password(s);
* when you make a purchase or place an order with us, your payment card details;
* your communication and marketing preferences;
* your interests, preferences, feedback and survey responses;
* your location;
* your correspondence and communications with us; and
* other publicly available personal data, including any which you have shared via a public platform (such as a Twitter feed or public Facebook page).
We do not anticipate collecting, storing or using any “special categories” of more sensitive personal information and we do not knowingly collect data relating to children.
How is your personal information collected?
We collect personal information about you from a number of sources, however the principal source will be directly from you. When you visit or register on or contact us via our websites or you request information from the website or complete an enquiry or order form, you may be asked to provide information about yourself. You may also provide personal information to us when you contact us by email, telephone or letter, when you register to use our site, subscribe to our service, search for a product, place an order on our site, completing an enquiry form on our site enter a competition, promotion or survey and when you report a problem with our site, goods or services.
We may collect or receive information about you from third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies).
How we will use information about you
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
1. Where we need to perform any contract we have entered into with you or taking steps at your request prior to entering a contract.
2. Where we need to comply with a legal obligation.
3. 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.
We may also use your personal information in the following situations, which are likely to be rare:
1. Where we need to protect your interests (or someone else’s interests).
2. Where it is needed in the public interest or for official purposes.
Situations in which we will use your personal information We need all the categories of information in the list above (see The kind of information we hold about you) primarily to allow us to perform our contract with you or to take steps at your request prior to entering a contract, and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below.
Examples of why we will process customer data include:
* checking availability of our goods and services for potential customers;
* selling and supplying goods and services to our customers;
* protecting customers, employees and other individuals and maintaining their safety, health and welfare;
* promoting, marketing and advertising our products and services;
* sending promotional communications which are relevant and tailored to individual customers;
* understanding our customers’ behaviour, activities, preferences, and needs;
* improving existing products and services and developing new products and services;
* complying with our legal and regulatory obligations;
* preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies;
* handling customer contacts, queries, complaints or disputes;
* managing insurance claims by customers;
* protecting us, our employees and customers, by taking appropriate legal action against third parties who have committed criminal acts or are in breach of legal obligations to us;
* effectively handling any legal claims or regulatory enforcement actions taken against us; and
* fulfilling our duties to our customers, colleagues, shareholders and other stakeholders.
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
If you fail to provide personal information
If you fail to provide certain information when requested, we may not be able to enter into a contract, or perform the contract we have entered into, with you, or we may be prevented from complying with our legal obligations.
Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
How we use particularly sensitive personal information
“Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances: 1. In limited circumstances, with your explicit written consent. 2. Where we need to carry out our legal obligations and in line with our data protection policy. 3. Where it is needed in the public interest, such as for equal opportunities monitoring, and in line with our data protection policy. Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public. We do not envisage there will be many, if any, situations where we are required to hold or use special categories of your sensitive personal information.
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:
1. Where we have notified you of the decision and given you 21 days to request a reconsideration.
2. Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.
3. In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights. If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.
We may have to share your data with third parties, including third-party service providers and other entities within our group. We require third parties to respect the security of your data and to treat it in accordance with the law. We may transfer your personal information outside the EU. If we do, you can expect a similar degree of protection in respect of your personal information.
Why might you share my personal information with third parties?
We will share your personal information with third parties where required by law, where it is necessary to administer the contractual relationship with you or where we have another legitimate interest in doing so.
We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.
Which third-party service providers process my personal information?
“Third parties” includes:
* third-party service providers, business partners, suppliers and sub-contractors (including telecommunications, telephony and internet service providers) for the performance of any contract we enter into with you;
* advertisers and advertising networks that require the data to select and serve relevant adverts to you and others.
We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience;
* analytics and search engine providers that assist us in the improvement and optimisation of our site;
* credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
How secure is my information with third-party service providers and other entities in our group?
All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our
third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
We have put in place measures to protect the security of your information. Details of these measures are available upon request. Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from the CFO or DPM (see details below).
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
How long will you use my information for?
We will only retain your personal information 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.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
We retain and destroy personal information in accordance with applicable laws and regulations.
Rights of access, correction, erasure, and restriction
Please inform us of any changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
Your rights in connection with personal information
Under certain circumstances, by law you may have the right to:
* Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
* Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
* Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
* Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
* Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
* Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the Data Protection Manager in writing at the contact details below.
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
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 the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Data Protection Manager. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Data protection manager
We have appointed a data protection manager (DPM) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPM at the contact details below. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.
Changes to this privacy notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
If you have any questions about this privacy notice, please contact the Data Protection Manager at, Broadway Partners, Tempest, Tithebarn Street, Liverpool, L2 2DT United Kingdom or at firstname.lastname@example.org