Brookbourne Ltd Privacy Policy 

Introduction

Definitions

This Privacy Policy explains in detail the types of personal data Brookbourne Holdings Limited (“we”, “us”, “our”) may collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe.

We may change this Privacy Policy at any time and from time to time. All updates and amendments are effective immediately upon notice, which we may give by any means, including, but not limited to, by posting a revised version of this Privacy Policy or other notice on the Website. You’re welcome to come back and check it whenever you wish.

Personal data, or personal information, means any information about an individual from which that person can be identified and includes any expression of opinion about the individual and any indication of the intentions of the data controller or any other person in respect of the individual. It does not include data where the identity has been removed (anonymous data).

For the purpose of the current Data Protection legislation Brookbourne Holdings Limited is categorised as a data controller and processor and is registered with the Information Commissioner in the Isle of Man, Registration No: R003589.

Information we collect

We may collect and process the following data about you:

• Information you provide to use when you subscribing or asking us to add you to our mail list: Contact details, such as name, address, telephone number and email address;
• Information we collect when sign a legal documents with you: Date of birth, nationality, country of birth, country of residence, employment status and tax identification number (i.e. National Insurance Number);
  
• Information we collect to process a legal agreements with you: Passport details, driving licence and utility bills;
  
• Information we collect to define a type of service for you: Details of the services a Client request from us;
  
• Cookies and tracking: We and our partners may use various technologies to collect and store information when you use our Services, and this may include using cookies and similar tracking technologies on our Website, such as pixels and web beacons, to analyse trends, administer the website, track users’ movements around the website, serve targeted advertisements, and gather demographic information about our user base as a whole; and
  
• Any records held by providers of utility services.

If you have requested information or a service from us, we will not be able to provide it without certain information, such as your contact details. Before we can begin providing you with our services, we need to obtain certain information about you, so that we can verify your identity to meet our obligations under the Money Laundering and Terrorist Financing Regulations and any other applicable legislation and for the purposes of crime prevention and fraud prevention. If you do not provide this information, we will be unable to provide you with our services.

We collect you personal data:

• When you visit our website.
  
• When you sign up to our terms of business.
• When you engage with us on social media.
  
• When you contact us by any means with queries, complaints etc.
  
• When you’ve given a third party permission to share with us the information they hold about you.
• If you contact us, we may keep a record of that correspondence

Use of personal data

We use information held about you in the following ways

• To undertake checks such as identification verification checks with fraud prevention agencies to enable us to comply with our anti-money laundering obligations and for the purposes of crime prevention and fraud prevention
• To carry out obligations arising from any contracts entered into between you and us.
  
• To notify you about changes to our service.
  
• To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes. You may opt out of receiving information at any time by notifying us.
  

If you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below. Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for.

Whenever we collect or processes your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected; including in order to:

• provide you with the services you have requested;
• comply with other laws, including for the period demanded by our tax authorities;
  
• in support of a claim or defence in court.

Legal terms

The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:

• Consent: Where you have given consent we can collect and process your data for one or more specific purposes.
• Contractual obligations: In certain circumstances, we may need to process your personal data to provide the services under our contract with you.
  
• Legal compliance: If the law requires us to, we may need to collect and process your data. 
  
• Legitimate interest: In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.
  

Third parties

We may disclose your personal information to third parties:

• Our appointed auditors, accountants, lawyers and other professional advisers (e.g. compliance consultants), to the extent that they require access to the information in order to advise us;
• If we or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• Fraud prevention agencies and other organisations to allow us to undertake the checks set out below. We will supply details of such agencies on request;
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms and other agreements; or to protect the rights, property, or safety of us, our Clients, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
• For the provision of services to you.

Personal data storage and processing

The data that we collect from you may be transferred to and stored at, a destination outside the Isle of Man or the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services.

By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. Such steps may include only transferring your data to jurisdictions in respect of which there is a European Commission adequacy decision or, where this is not the case, by using model clauses which have been approved by the European Commission.

All information you provide to us is stored on our secure servers and hardware. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Rights over personal data

The Act gives you rights about the information held about you. Your right of access can be exercised in accordance with the Act and is known as a Subject Access Request.

You will have the right to obtain, on request, confirmation as to whether your personal data is being processed, together with the following information:

• The purpose of processing your data
• Information about the recipients of your data
  
• Recipients or categories of recipient to whom the personal data will be disclosed (in particular third countries or international organisations)
  
•  The right to lodge a complaint with a data protection authority
  
• In cases of automated processing, details of profiling
  
• Information about the sources of data
  

Information must be provided to you within one month at no cost to you. However we have the right to refuse or charge a reasonable fee when a request is manifestly unfounded or excessive, particularly if it is repetitive.

Under the Data Protection Act, you also have the following rights:

• Right to be informed
• Right to rectification
  
• Right to be forgotten (erasure)
  
• Right to restrict processing
• Right to data portability
• Right to object
• The right not be subject to automated decision-making, including profiling

You have the right to withdraw consent at any time, this must be provided in writing.

Contact

We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it.

If you have any questions that haven’t been covered, please contact our Data Protection Officer who will be pleased to help you:

Data Protection Officer, Brookbourne Holdings Limited, Mollfort House, 2 Water Street, Ramsey, Isle Of Man, IM8 1JP