1.1. This privacy notice (the “Privacy Notice”) applies to all personal information processing activities carried on by the Commercial and Northern Ltd, trading as B-North.
1.2. B-North is a data controller in respect of personal information that we process in connection with our business (including the products and services that we provide). In this notice, references to “we”, “us” or “our” are references to B-North.
1.3. Our principal address is B-North, Suite 20A, Manchester One, 53 Great Portland Street, Manchester M1 3LD, and our contact details can be located at www.b-north.co.uk
1.4. We respect individuals’ rights to privacy and to the protection of personal information. The purpose of this Privacy Notice is to explain how we collect and use personal information in connection with our business. “Personal information” means information about a living individual who can be identified from that information (either by itself or when it is combined with other information). We may update our Privacy Notice from time to time, by communicating such changes to you and publishing the updated Privacy Notice on our website. We would encourage you to visit our website regularly to stay informed of the purposes for which we process your information and your rights to control how we process it.
We collect and process various categories of personal information. We will limit the collection and processing of information to information necessary to achieve one or more legitimate purposes as identified in this notice. Personal information may include:
a) basic personal information, including name and contact details;
b) goods and services provided;
3.1 Your information is made up of all the personal information we collect and hold about you. It includes:
a) information you give to us;
b) information that we learn about you through our relationship with you;
c) information that we gather from the technology which you use to access our services (for example location data from your mobile phone, or an IP address or telephone number) and how you use it (for example pattern recognition).
4.1 We want to make sure you are aware of your rights in relation to the personal information we process about you. We have described those rights and the circumstances in which they apply below.
4.2 If you wish to exercise any of these rights, or if you have any queries about how we use your personal information which are not answered here, please contact us at email@example.com
4.3 Our Data Protection Officer can be contacted at firstname.lastname@example.org
Access – You have a right to get access to the personal information we hold about you.
If you would like a copy of the personal information we hold about you, please write to: B-North, Suite 20A, Manchester One, 53 Great Portland Street, Manchester M1 3LD.
Rectification – You have a right to rectification of inaccurate personal information and to update incomplete personal information.
If you believe that any of the information that we hold about you is inaccurate, you have a right to request that we restrict the processing of that information and to rectify the inaccurate personal information.
Restriction – You have a right to request us to restrict the processing of your personal information.
You may request us to restrict processing your personal information if you believe that:
– any of the information that we hold about you is inaccurate;
– we no longer need to process your information for the purposes for which it was provided, but you require the information to establish, exercise or defend legal claims; or
– we are not using your information in a lawful manner.
Portability – You have a right to data portability.
Where we have requested your permission to process your personal information or you have provided us with information for the purposes of entering into a contract with us, you have a right to receive the personal information you provided to us in a portable format. You may also request us to provide it directly to a third party, if technically feasible. We’re not responsible for any such third party’s use of your account information, which will be governed by their agreement with you and any privacy statement they provide to you. If you would like to request the personal information you provided to us in a portable format, please write to: B-North, Suite 20A, Manchester One, Great Portland Street, Manchester M1 3LD.
Objection – You have a right to object to the processing of your personal information.
You have a right to object to us processing your personal information (and to request us to restrict processing) unless we can demonstrate compelling and legitimate grounds for the processing, which may override your own interests or where we need to process your information to investigate and protect us or others from legal claims. Depending on the circumstances, we may need to restrict or cease processing your personal information altogether, or, where requested, delete your information.
Marketing – You have a right to object to direct marketing.
You have a right to object at any time to processing of your personal information for direct marketing purposes, including profiling you for the purposes of direct marketing. For more information see section 9 – Marketing.
Withdraw consent – You have a right to withdraw your consent.
Where we rely on your permission to process your personal information, you have a right to withdraw your consent at any time. We will always make it clear where we need your permission to undertake specific processing activities.
Lodge complaints – You have a right to lodge a complaint with the regulator.
If you wish to raise a complaint on how we have handled your personal information, you can contact our Data Protection Officer who will investigate the matter. We hope that we can address any concerns you may have, but you can always contact the Information Commissioner’s Office (ICO). For more information, visit www.ico.org.uk
From time to time we may change the way we use your information. Where we believe you may not reasonably expect such a change we will notify you and will allow a period of at least 30 days for you to raise any objections before the change is made. However, please note that in some cases, if you do not agree to such changes it may not be possible for us to continue to operate your account and/or provide certain products and services to you.
We will only use and share your information where it is necessary for us to lawfully carry out our business activities.
7.1 We will not share your information with anyone outside B-North except:
a) where we have your permission;
b) where required for your product or service;
c) where we are required by law and by law enforcement agencies, judicial bodies, government entities, tax authorities or regulatory bodies around the world;
d) where permitted by law, it is necessary for our legitimate interests or those of a third party, and it is not inconsistent with the purposes listed above.
7.2 If you ask us to, we will share information with any third party.
7.3 We will not share your information with third parties for their own marketing purposes.
8.1 We may transfer your information to organisations in other countries the basis that anyone to whom we pass it protects it in the same way we would and in accordance with applicable laws.
8.2 In the event that we transfer information to countries outside of the European Economic Area (which includes countries in the European Union as well as Iceland, Liechtenstein and Norway), we will only do so where:
a) the European Commission has decided that the country or the organisation we are sharing your information with will protect your information adequately;
b) the transfer has been authorised by the relevant data protection authority; and/or
c) we have entered into a contract with the organisation with which we are sharing your information (on terms approved by the European Commission) to ensure you information is adequately protected. If you wish to obtain a copy of the relevant data protection clauses, please write to: B-North, Suite 20A, Manchester One, Great Portland Street, Manchester M1 3LD.
Unless you have told us that you do not want to hear from us, we will send you relevant marketing information by mail, phone, email, text and other forms of electronic communication. If you change your mind about how you would like us to contact you or you no longer wish to receive this information, you can tell us at any time by writing to: B-North, Suite 20A, Manchester One, Great Portland Street, Manchester M1 3LD.
10.1 We manage our records to help us to serve our brokers and investors well and to comply with legal and regulatory requirements. Records help us demonstrate that we are meeting our responsibilities and to keep as evidence of our business activities.
10.2 Retention periods for records are determined based on the type of record, the nature of the activity, product or service, and the applicable local legal or regulatory requirements. We normally keep broker records for xxxxxxx years and investor records for Xxxxxxxxxx years. Retention periods may be changed from time to time based on business or legal and regulatory requirements.
10.3 We may on exception retain your information for longer periods, particularly where we need to withhold destruction or disposal based on an order from the courts or an investigation by law enforcement agencies or our regulators. This is intended to make sure that B-North will be able to produce records as evidence, if they’re needed.
10.4 If you would like more information about how long we keep your information, please contact us at : B-North, Suite 20A, Manchester One, Great Portland Street, Manchester M1 3LD.
We are committed to ensuring that your information is secure with us and with the third parties who act on our behalf. For more information about the steps we are taking to protect your information please contact our Data Protection Officer.
We promise to treat any personal information about you securely, fairly and lawfully. We are committed to protecting your privacy.
When we ask you to provide personal information online it will only be to gather interest from brokers who may wish to work with Project B-North, or potential investors in Project B-North.
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