The Privacy Statement Regarding Customer and Online User Information applies to Blue Saffron Limited (“BSL”) and its worldwide corporate affiliates (“we” or “our”), but not to those Blue Saffron Limited corporate affiliates that have published their own privacy and security statements. This privacy statement also does not apply to the websites of our business partners or to any other third parties, even if their websites are linked to our website. We recommend you review the privacy statements of the other parties with whom you interact.

This privacy statement governs personal information we collect from our customers and online from our website users (“you”), through Blue Saffron Limited products, services, software, websites, contacts, or our relationship with you. For the purposes of this privacy statement, “corporate affiliates” means any entity or joint venture that is wholly or partially owned or controlled by Blue Saffron Limited “Business partners”. This means any subcontractor, vendor or other entity with whom we have an ongoing business relationship to provide products, services, or information. “Personal information” means information which identifies you, such as your name, telephone number, and email address.

Information We Collect

We may ask you to provide personal information in the course of our business, including;

• Through the use of our website(s) including support portals
• Requests for quotes, services, support, or information
• Place orders for products or services
• Participate in surveys, sweepstakes, or other promotional activities
• Subscribe to newsletters, promotional emails, or other materials
• As a result of your relationship with one or more of our staff and clients
• Apply for a job, submit your resume/CV
• data supplied through “Contact us” dialogue.

Information we may request includes your email address, name, company you work for, job title, postal address, telephone number, and your relationship to a person. If you make a purchase, we may ask for your billing and payment related information. Job applicants may be requested to provide information such as educational background, employment experience, and job interest. We may also collect demographic information, such as your business or company information, age, gender, interests, preferences and favourites. Forms that you may fill in will indicate whether information requested is mandatory or voluntary.

Blue Saffron Limited may collect information you provide to us for the purposes of attending meetings and events, or any other information relating to you that you may provide to us.

We may collect information about your visits to our websites, including the pages you view, the links and ads you click, search terms you enter, and other actions you take in connection with the Blue Saffron Limited websites and services. We may also collect certain information from the browser you used to come to our website, such as your Internet Protocol (IP) address, browser type and language, access times, the Uniform Resource Locator (URL) of the website that referred you to our website and to which URL you browse away from our site if you click on a link on our site.

In order to offer you a more consistent and personalized experience in your interactions with Blue Saffron Limited, information collected through one source may be combined with information obtained through other Blue Saffron Limited resources. We may also supplement the information we collect with information obtained from other parties.

We may also monitor and record our communications with you, including e-mails and phone conversations which may then be used for training purposes, quality assurance, to record details about the products and services you order from us, and in order to meet our legal and regulatory obligations generally.

Some Blue Saffron Limited services may be co-branded and offered in conjunction with another company. If you register for, or use such services, both Blue Saffron Limited and the other company may receive information collected in conjunction with the co-branded services, and may use the information according to each company’s privacy statement and other agreements with you.

How We Use Personal Information

Blue Saffron Limited uses your personal information to:

• Deliver the services and support, provide information requested by you, or carry outour obligations arising from any contracts entered into between you and Blue Saffron Limited
• Send communications to you, such as product safety information, your transactions status (for example, order confirmations), information about products and services available from Blue Saffron Limited and its corporate affiliates, promotional offers, publications, details of events and surveys
• Customise, analyse, and improve our products, services (including the content and advertisements on our website), technologies, communications and relationship with you
• Enforce our conditions of sale, website terms, notifications about changes to our services and/or separate contracts (if applicable) with you
• Prevent fraud and other prohibited or illegal activities
• Protect the security or integrity of the website, our business, or our products and services
• Otherwise, as disclosed to you at the point of collection.

By writing to the Data Protection Manager, Legal Department, Blue Saffron Limited, 80-83 Long Lane, London, EC1A 9ET or by emailing privacy@bluesaffron.com you can ask us at any time for details of the credit reference and fraud prevention agencies to whom we disclose and obtain information about you.

Where necessary or otherwise allowed, BSL may also pass your information to certain third parties (some of which may be based outside of the European Union). Such third parties may include:

• those who provide to BSL or its group companies products or services that support BSL’s services
• if your bill is paid by someone-else (for example, your employer), that person’s agencies and organisations involved in the prevention or detection of fraud or crime or the apprehension or prosecution of offenders, including the operators and participants of crime prevention schemes in which BSL participates who may compare your information with information collected from other sources and who may keep a record of the searches BSL makes against your name
• anyone to whom BSL transfers that part of its business of which you are a customer or a potential customer in accordance with paragraph 13 below[PO1] . Such entities including their professional advisers may use and disclose your information for the same purposes as BSL and its advisers. By entering into product and/or a services agreement with BSL, you consent to such transfers of your personal data.

If you wish to use BSL’s products or services abroad, for example, if you wish to roam on a foreign mobile telephone network, it may be necessary to transfer your information outside of the European Union to that country. BSL’s web, and similar sites and those of BSL’s group companies may also be based on servers located in countries outside of the European Union, whose laws may not protect you as well as that in countries within the European Union.

In the event that BSL’s business is sold or integrated with another business, your information will be disclosed to our advisors and any prospective purchaser’s advisors and will be passed to the new owners of the business.

If you are a consumer and have ticked the relevant box on your contract or otherwise given your consent, BSL may also contact you by phone, post, fax, email, or SMS from time to time about the products and services of carefully selected third parties which BSL believes may also be of interest to you and, without passing control of your information, enable you to receive marketing and/or promotional information from them.

Personal information collected may be stored and processed in the United Kingdom or any other country in which Blue Saffron Limited or its corporate affiliates, subsidiaries or agents maintain facilities, and by using Blue Saffron Limited products and services (including our website), you consent to any such transfer of information outside of your country.

Disclosing Personal Information

We may share your personal information with corporate affiliates to carry out transactions you request or to make our business or that of our corporate affiliates more responsive to your needs. We may also disclose your personal information in connection with law enforcement, fraud prevention, or other legal action; as required by law or regulation; or if Blue Saffron Limited reasonably believes it is necessary to protect Blue Saffron Limited, its customers, or the public. In addition, we may share your personal information with business partners that help Blue Saffron Limited carry out transactions you request or that help Blue Saffron Limited to customise, analyse, and/or improve our communication or relationship with you, and then only with business partners who share Blue Saffron Limited’s commitment to protecting your personal information. Except as described above, we will not disclose your personal information to third parties for their own marketing purposes unless you have provided consent.

Selecting Your Communication Preferences

You may choose to receive or not receive marketing communications from Blue Saffron Limited by indicating your preferences. Opportunities to select your preferences include the following:

• Email details of your preferences to marketing@bluesaffron.com

Any marketing by Blue Saffron Limited, or any third parties on behalf of Blue Saffron Limited, will be conducted in accordance with applicable laws.

How You Can Access Your personal information and your other rights

You have the following rights in relation to the personal information we hold about you:

(a) Your right Your right of access. If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.

Please request access by writing to the Data Protection Manager, Legal Department, Blue Saffron Limited, 80-83 Long Lane, London, EC1A 9ET or emailing servicedesk@bluesaffron.com. Please provide proof of your identity, confirm your account number(s) with BSL (if applicable), and briefly describe the information you require.

(b) Your right to rectification. If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and its lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

(c) Your right to erasure. You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where possible and it is lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly

(d) Your right to restrict processing. You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where possible. If you ask us, where possible and it is lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

(e) Your right to data portability. With effect from 25 May 2018, you have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or ask us to transfer this to a third party of your choice.

(f) Your right to object. You can ask us to stop processing your personal information, and we will do so, if we’re:

• relying on our own or someone else’s legitimate interests to process your personal information except if we can demonstrate compelling legal grounds for the processing; § processing your personal information for direct marketing; or
• processing your personal information for research unless such processing is necessary for the performance of a task carried out in the public interest.

(g) Your rights in relation to automated decision-making and profiling. You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, and it produces a legal effect or similarly significantly affects you unless such profiling is necessary for entering into, or the performance of, a contract between you and us.

(h) Your right to withdraw consent. If we rely on your consent as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.

(i) Your right to lodge a complaint with the supervisory authority. If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the UK Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.

Implementation of changes

Please allow up to 10 business days for your email preferences to take effect.
Because some promotions, such as e-mail campaigns, are developed in advance, you may sometimes receive solicitations after we receive your preference request.

How We Secure Your Personal Information

Blue Saffron Limited is committed to protecting the security of your personal information. We use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure, such as encryption, passwords, physical security, etc. While we strive to protect your personal information, Blue Saffron Limited cannot ensure or warrant that the personal information or private communications you transmit to us will always remain private, and you do so at your own risk. For more information about our security measures, please contact us via servicedesk@bluesaffron.com.

If a password is used to help protect your accounts and personal information, it is your responsibility to keep your password confidential. Do not share this information with anyone. If you are sharing a computer with anyone you should always log out before leaving a site or service to protect access to your information from subsequent users.

Collection and Use of Children’s Personal Information

Blue Saffron Limited takes children’s privacy seriously. We do not knowingly collect personal information from children under the age of 18 through our websites.
If you are under 18 years of age, please do not submit any personal information through our websites without the express consent and participation of a parent or guardian.

Your Rights Regarding Your Personal Information

The General Data Protection Regulation (enforceable from 25^th May 2018) protects an individual’s rights regarding their personal data and privacy of data linked to them.

You are entitled to request details of the information we hold about you and how we process it.

You have the right to request that we do not use your personal data for marketing purposes.

How We Use Cookies

Blue Saffron Limited web sites use Blue Saffron Limited and third party “cookies” to help personalise your online experience. A cookie is a tiny piece of text asking permission to be placed on your computer’s hard drive. If you agree, then your browser adds the text in a small file.

We use cookies to store your preferences and other information on your computer in order to save you time by eliminating the need to enter the same information repeatedly.

We also work with third party advertising and personalisation partners that use cookies to help us display personalised content and appropriate advertising on your visits to www.bluesaffron.com and other websites. Cookies placed by our third party partners also assist us with measuring the performance of our advertising campaigns.

Similarly, third parties use cookies to deliver advertising on the internet, whether you are on www.bluesaffron.com or another website, based on your visits to www.bluesaffron.com and other websites, and to measure the effectiveness of those advertising campaigns. These cookies assist the third parties in identifying the pages you view, the links and ads you click on, and other actions you take on those web pages, and the site from which you came before arriving at a web page.

You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to use  interactive features of Blue Saffron Limited web sites and services that depend on cookies.

IP Addresses

We may collect your IP address, operating system and browser type for system administration, and to use for aggregate information reporting for both Blue Saffron Limited and our third party advertising and personalisation partners. This data does not identify an individual.

Third-Party Websites and Services

Please be aware that other websites that may be accessed through our website may collect personally identifiable information about you. The information practices of those third-party websites linked to www.bluesaffron.com are not covered by this privacy statement.

Please be aware that, in providing services on Blue Saffron Limited’s behalf, our business partners may collect personal information about you.

 

Changes to Our Privacy Statement

We will occasionally update this privacy statement. If we make changes to the privacy statement regarding customer and online user information or make any material changes to how Blue Saffron Limited will use your personal information, we will revise the privacy statement to reflect such changes and revise the statement’s effective date, included at the end of this section. We encourage you to periodically review this statement to be informed of how Blue Saffron Limited is protecting your personal information.

Contacting Us

If you would like to contact us for any reason regarding our privacy practices, please write to the Data Protection Manager, Legal Department, Blue Saffron Limited, 80-83 Long Lane, London, EC1A 9ET or email privacy@bluesaffron.com.

Privacy Statement Regarding Customer and Online User Information Effective Date:  21^st May 2018