Privacy Policy AND NOTICE

1. Privacy and Your Personal Data

B.C. Strategy UK Limited (with company number 08153977) is committed to protecting the privacy of our website’s users and others who make contact with our company. This privacy policy (Privacy Policy) is intended to inform you on how we gather, define, and utilise your personally identifiable information (Personal Data) as listed in clause 3 below.

It applies to Information collected by us, and provided by you. It is also intended to assist you in making informed decisions when using our Website, and/or contact us. It is important that you read this Privacy Notice together with any Terms of Business, Letters of Engagement, or any other notice we may provide. This Privacy Notice supplements other notices and is not intended to override them.

All your personal Information shall be held and used in accordance with Data Protection Laws, being: (i) the Data Protection Act 1998, until the effective date of its repeal (ii) the General Data Protection Regulation ((EU) 2016/679) (GDPR) and any national implementing laws, regulations and secondary legislation, for so long as the GDPR is effective in the UK, and (iii) any successor legislation to the Data Protection Act 1998 and the GDPR, in particular the Data Protection Bill 2017-2019, once it becomes law and any other legislation relating to the protection of Personal Data.
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B.C. Strategy UK Limited, City Point, 1 Ropemaker Street, Moorgate, London, EC2Y 9HT, UK

Our Data Protection Lead can be contacted at info@blackcube.com
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2. Data Controller

Black Cube is the Data Controller and responsible for your personally identifiable information (Personal Data) as listed in clause 3 below.

Our Head of Compliance is our appointed Data Protection Officer who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights as set out in Clause 7 of this Privacy Policy, please contact the data privacy manager using the details set out above.
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3. What information do we collect?

We may collect, receive from you, use, store and transfer different kinds of Personal Data about you, the reader who has accessed this website, which we have grouped together follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

Contact Data includes billing address, delivery address, email address and telephone numbers.

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

Usage Data includes information about how you use our website.

1. We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data but is not considered Personal Data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this privacy notice.
2. We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Our Data Collection Purposes, Processed Information Categories, and Reasons for Processing:
Registration as a New Client: We collect and process identity and contact information when you register as a new client. This information is processed for the purpose of engaging in a contract with you.
Relationship Management: We collect and process identity and contact information to manage our relationship with you. This includes notifying you about changes to our terms or privacy policy. Such processing is necessary to comply with legal obligations and for our legitimate interests in keeping our records updated.
Analytics: We utilize data analytics to improve our website by collecting technical and usage information. This helps us understand how users interact with our website, allowing us to analyse performance and enhance our service. This processing is conducted for our legitimate interests in keeping our website relevant and updated.
Delivery of Relevant Website Content: We process identity, contact, and technical information to deliver relevant website content to you. This includes studying user behaviour to develop our website and inform our marketing strategy. Such processing is necessary for our legitimate interests in growing our business and providing tailored content.
Administration and Protection of Business and Website: We collect and process identity, contact, and technical information for the administration and protection of our business and website. This includes troubleshooting, data analysis, and system maintenance. Such processing is necessary for our legitimate interests in running our business and ensuring network security.

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4. The legal basis for processing your Personal Data

Black Cube will only process Personal Data where there is a lawful basis as per Data Protection Laws. This lawful basis shall be one or more of the following:

1. Express consent from you;
2. In order to perform and/or complete a contract with a third party;
3. To comply with a legal obligation;
4. To protect your vital interest;
5. It is in the public interest; and
6. There is a legitimate interest.

Legitimate interests are a flexible basis upon which the law permits the processing of an individual’s Personal Data. To determine whether we have a legitimate interest in processing your data, we balance the needs and benefits to us against the risks and benefits for you of us processing your data. This balancing is performed as objectively as possible by our Data Protection Lead. You are able to object to our processing and we shall consider the extent to which this affects whether we have a legitimate interest. If you would like to find out more about our legitimate interests, please contact us via the email address set out above.
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5. How we share your information

In certain circumstances we will share your Information with other parties. Details of those parties are set out below along with the reasons for sharing it.
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6. Data Retention

1. Black Cube will retain your Personal Data for as long as is necessary for the purposes set out in this Privacy Policy and for the services and products which Black Cube provides.
2. We will retain and use your Personal Data to the extent necessary to:
3. comply with our legal obligations;
4. comply with applicable laws;
5. resolve disputes and potential future litigation; and
6. enforce our legal agreements and policies.
7. Black Cube will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our website or service, or we are legally obligated to retain this data for longer time periods.
8. If ‘consent’ is the basis for our lawful processing of your data, we will retain your data so long as both the purpose for which it was collected, and your consent, are still valid. We review the status of your consent every twelve (12) months and treat non-response to our requests for renewal of consent as if they were your request to withdraw consent. Occasionally, we might identify a legitimate interest in retaining some of your Personal Data that has been obtained by consent. If we do, we will inform you that we intend to retain it under these conditions and identify the interest specifically.
9. If we process your data on the basis of ‘legitimate interests’, we will retain your data for so long as the purpose for which it is processed remains active. We review the status of our legitimate interests every twelve (12) months and will update this notice whenever we determine that either a legitimate interest no longer exists or that a new one has been found.
10. All categories of Personal Data that are held by us because they are essential for the performance of a contract, will be held for a period of six years, as determined by reference to the Limitations Act 1980, for the purposes of exercising or defending legal claims.
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7. Your rights as a Data Subject

When reading this notice, it might be helpful to understand that your rights arising under Data Protection Laws include:

1. The right to be informed of how your Personal Data is used (through this notice);
2. The right to access any Personal Data held about you;
3. The right to withdraw consent at any time, by emailing us using the details set out above.;
4. The right to rectify any inaccurate or incomplete Personal Data held about you;
5. The right to erasure where it cannot be justified that the information held satisfies any of the criteria outlined in this policy, or where you have withdrawn consent;
6. The right to prevent processing for direct marketing purposes, scientific/historical research or in any such way that is likely to cause substantial damage to you or another, including through profile building; and
7. The right to object to processing that results in decisions being made about you by automated processes and prevent those decisions being enacted.
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8. Cookies

Similar to other commercial websites, our Website uses a technology called “cookies” and web server logs to collect information about how our Website is used. Cookies are small text files that are placed on your computer’s hard drive through your web browser when you visit any web site. They are widely used to make web sites work, or work more efficiently, as well as to provide information to the owners of the site.

Like all other users of cookies, we may request the return of information from your computer when your browser requests a web page from our server. Cookies enable our web server to identify you to us, and to track your actions and the pages you visit while you use our website. The cookies we use may last for a single visit to our site (they are deleted from your computer when you close your browser), or may remain on your computer until you delete them or until a defined period of time has passed.

Although your browser software enables you to disable cookies, we recommend that you allow the use of cookies in order to take advantage of the features of our website that rely on their use. If you prevent their use, you will not be able to use all the functionality of our website. Here are the ways we may use cookies:

to record whether you have accepted the use of cookies on our web site. This is solely to comply with the law. If you have chosen not to accept cookies, we will not use cookies for your visit, but unfortunately, our site will not work well for you.
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to allow essential parts of our web site to operate for you.

to operate our content management system.

to operate the online notification form – the form that you use to contact us for any reason. This cookie is set on your arrival at our web site and deleted when you close your browser.

to enhance security on our contact form. It is set for use only through the contact form. This cookie is deleted when you close your browser.

to collect information about how visitors use our site. We use the information to improve your experience of our site and enable us to increase sales. This cookie collects information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from, and the pages they visited.

to record that a user has viewed a webcast. It collects information in an anonymous form. This cookie expires when you close your browser.

to record your activity during a web cast. For example, as to whether you have asked a question or provided an opinion by ticking a box. This information is retained so that we can serve your information to you when you return to the site. This cookie will record an anonymous ID for each user, but it will not use the information for any other purpose. This cookie will last for a period of time after which it will delete automatically.

to store your personal information so that you do not have to provide it afresh when you visit the site next time. This cookie will last for a period of time after which it will delete automatically.

to enable you to watch videos we have placed on YouTube and other video sharing websites, who will not store personally identifiable cookie information when you use their privacy-enhanced mode.
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9. Data Security

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
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10. Does your Personal Data leave the EU?

Your Personal Data may be transferred to our affiliated companies including B.C. Strategy Limited.

We may transfer your Personal Data to third parties which are outside the EU, this will be carried out in accordance with Data Protection Laws and for the purposes of carrying out any services we provide for you.

Black Cube may from time to time use overseas web and IT providers. We can disclose such details of what data is sent where, and the safeguards in place, following your written request.
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11. Changes to our Privacy Policy

This Privacy Policy can be changed by us at any time. If we change our Privacy Policy in the future, we will advise you of material changes or updates to our Privacy Policy by email, where we are holding your email address.
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12. Complaints

If you are unhappy about our use of your Information, you can contact us at the address or email address above. You are also entitled to lodge a complaint with the UK Information Commissioner’s Office using any of the below contact methods.
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Telephone: 0303 123 11113

Website: https://ico.org.uk/concerns/

Post: Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow, Cheshire

SK9 5AF

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