Privacy Policy

 

Barcats Privacy Notice

 

1. General terms

Purpose of this privacy notice

Barcats UK Limited, including each of its affiliates and subsidiaries (collectively, "Barcats", "we", or "us") respects your privacy and is committed to protecting your personal data. This privacy notice explains how we collect and process the personal data that you provide to us through your use of our website located at https://barcats.co.uk/ or https://barcats.com/ and any derivations thereof (Website) and through our communications with you. Where we refer to "personal data", it means "personal data" as defined in the Data Protection Laws.

Please see the Glossary below that gives the meaning of some of the terms used in this privacy notice. This privacy notice applies in addition to any other agreement that you might enter into with us.

We are a Data Controller of the personal data that we collect and process through our Website, which means that we are responsible for deciding how we hold and use it. We may in certain circumstances also be a Data Processor, for example where we are performing some of our services for clients.

We are required under Data Protection Laws to notify you of the information contained in this privacy notice. It is important that you read and retain this notice so that you are aware of how and why we are using your personal data and what your rights are under Data Protection Laws.

Contact details

If you have any questions about this privacy notice or would like to enforce any rights that you may have under Data Protection Laws, please contact us at:

Global CEO
Email: info@barcats.co.uk
Address: c/o DJH Mitten Clarke, The Glades, Festival Way, Festival Park, Stoke on Trent, ST1 5BB

If you believe we are using your personal data unlawfully, please contact us in the first instance. You have the right to make a complaint at any time to the UK supervisory authority for data protection issues, the Information Commissioners Office (“ICO”), or other relevant supervisory authority.

Changes to this privacy notice and your duty to inform us of changes

We keep this privacy notice under regular review. This version was last updated in April 2022. We reserve the right to update this privacy notice and we will provide you with a new privacy notice when we make substantial updates. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links and service providers

Our Website and communications may, from time to time, contain links to and from third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. We encourage you to read the privacy notice of every website you visit.

2. The data we collect about you

Personal data 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). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data (e.g., first name, last name, username or similar identifier, title, date of birth and gender).
  • Contact Data (e.g., billing address, physical address, email address and telephone numbers).
  • Financial Data (e.g., payment card details).
  • Transaction Data (e.g., details about payments to and from you and other details of products and services you have purchased from us).
  • Technical Data (e.g., 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 our Website).
  • Profile Data (e.g., your username and password, purchases or orders made by you, feedback and survey responses).
  • Usage Data (e.g., information about how you use our Website, products and services).
  • Marketing and Communications Data (e.g., your preferences in receiving marketing from us and your communication preferences).
  • Location Data (e.g., your current location disclosed by GPS technology)

We also collect, use and share Aggregated Data such as statistical or demographic data for other purposes including research and analysis. Aggregated Data could be derived from your personal data but is not considered personal data under Data Protection Laws as this data will 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.

We generally 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. However, we may collect and process health data for the purposes described below.

Lawful Processing basis

Data concerning health

Compliance with a legal obligation or necessary for the performance of a contract with you

Processing condition

Necessary for the purposes of performing or exercising obligations or rights which are imposed or conferred by law on the controller or the data subject in connection with employment, social security or social protection.

(Paragraph 1(1)(a), Schedule 1, DPA 2018.)

We do not knowingly collect the personal data of children under the age of 15 and our Website is not intended for children under the age of 15.

If you fail to provide personal data

Where we need to collect personal data by law or under the terms of a contract we have with you, and you fail to provide that personal data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with a service). In this case, we may have to cancel a product or service you have with us, or we may not be able to enter into that contract with you, but we will notify you of this at the time.

3. How is your personal data collected?

We use different methods to collect personal data from and about you, including through:

  • Direct interactions. You may give us your Identity, Contact, Financial or Marketing and Communications Data on the Website or by corresponding with us by email.
  • Automated technologies or interactions. We will automatically collect Technical and Usage Data about your equipment, browsing actions and patterns as you interact with our Website. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookies Notice for further details.
  • Third parties or publicly available sources. In some instances we may collect personal data from third parties, some of which may be based outside the UK. We will only collect personal data this way where such information is publicly available or for legitimate business purposes, for example Technical Data from analytics providers such as Google.
  • Location Data. We use GPS technology to determine your current location for location-enabled features. You can withdraw your consent at any time by disabling Location Data in your settings.

4. Cookies

Our Website uses cookies to distinguish you from other users. This helps us to provide you with a good experience when you browse the Website and also allows us to improve it. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you block all cookies (including essential cookies) you may not be able to access all or parts of the Website. For more information about the cookies we use, please see our Cookies Notice.

5. How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the services and contract we are about to enter into or have entered into with you.
  • 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.
  • Where we need to comply with a legal or regulatory obligation. Please see the Glossary to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending marketing communications to you. In this respect, please see the Marketing section below.

Purposes for which we will use your personal data

We have set out below, in a table format, a non-exhaustive description of the ways we plan to process your personal data and which of the lawful bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. We may process your personal data on more than one lawful ground.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

Enter into a contract with you

Identity
Contact

Performance of a contract

Process and deliver your services, including managing payments

Identity
Contact
Financial
Transaction

Performance of a contract

Manage our relationship with you (e.g., responding to your communications, notifying you

Identity
Contact

Performance of a contract Necessary for our legitimate interests

about changes to our privacy notice)

Marketing and Communications

Necessary to comply with a legal obligation

Administer and protect our business and the Website (e.g., troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Identity
Contact
Technical

Necessary for our legitimate interests
Necessary to comply with a legal obligation

Deliver relevant Website content to you and measure or understand the effectiveness of the content we serve to you

Identity
Contact
Technical
Usage
Marketing and Communications
Location

Necessary for our legitimate interests

Use data analytics to improve the Website, products/services, marketing, customer relationships and experiences

Technical
Usage

Necessary for our legitimate interests

Make suggestions and recommendations to you about products or services that may be of interest to you

Identity
Contact
Technical
Usage
Marketing and Communications
Location

Necessary for our legitimate interests

We will only use your personal data 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 data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. We may also process your personal data without your knowledge or consent where this is required or permitted by law.

Marketing

You will receive marketing communications from us if you have given us your consent. We will not share your personal data with any third party for marketing purposes. You can withdraw your consent at any time by contacting us or by following the opt-out links on any marketing message sent to you.

6. Disclosures of your personal data

When you consent to providing us with your personal data, you also consent to share your personal data with certain of our third party service providers. We will only share your personal data for our legitimate business purposes relating to our business activities. We require all third parties to respect the security of your personal data and to treat it in accordance with Data Protection Laws. We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. Examples of third parties that we may share your personal data include:

  • Other companies in the Barcats group based in Australia that provide certain services.
  • Service providers such as technology companies in Australia or the United States that provide hosting or analytics services.
  • Professional advisers such as lawyers and accountants based in the UK or Australia that provide legal and accounting services.
  • Regulators based in the UK or Australia that require reporting in certain circumstances.
  •  
International transfers

Some of our third parties, for example hosting and analytics service providers, may be based outside of the UK, so their processing of your personal data will involve a transfer of data. Whenever we transfer your personal data internationally, we ensure a similar and adequate degree of protection is afforded to it by ensuring safeguards are implemented, for example:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data (for example, by the ICO or the European Commission).
  • Where we use certain service providers, we may use specific standard contracts which give personal data the necessary level of protection (for example, model clauses approved by the ICO or the European Commission).

Please contact us if you want further information on how we transfer your personal data internationally.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, falsified, used or accessed in an unauthorised way, altered or disclosed. All information you provide to us is stored on our or our third party's secure servers. 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.

8. Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. 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 regulatory, tax, accounting or other requirements. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances, you have rights under Data Protection Laws in relation to your personal data and to check that we are lawfully processing it. Your rights include those listed below.

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected.

Request erasure of your personal data. This enables you to ask us to delete your personal data, but only in specific circumstances, for example where the personal data is no longer necessary in relation to the purpose for which it was originally collected or processed. It may not always be possible for us to delete all of the information we hold about you if you request this, for example if we have an ongoing contractual relationship with you.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in specific circumstances, for example while we are reviewing the accuracy or completeness of data or deciding whether any request for erasure is valid.

Request the transfer of your personal data. The right to data portability means you have the right to receive, move, copy or transfer your personal data to another Data Controller, when we are processing your personal data based on consent or on a contract and the processing is carried out by automated means.

Withdraw consent at any time where we are processing your personal data based on consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us using the contact details stated above.

10. General

Automated decision-making. 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.

No fee usually required. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these 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 a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

Time limit to respond. We try to respond to all legitimate requests as soon as is reasonably practicable and in any event within the statutory time-limits. It could take us longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

11. Glossary

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Consent means when an individual gives consent which is freely given, specific, informed and is an unambiguous indication of their wishes. It is done by a statement or by a clear positive action in respect of the processing of any personal data relating to them.

Data Controller means an organisation that determines when, why and how to process personal data. It is responsible for establishing practices and policies in line with Data Protection Laws.

Data Processor means an organisation that processes personal data on behalf of a Data Controller. It is also responsible for establishing practices and policies in line with Data Protection Laws and its contractual obligations with Data Controllers.

Data Protection Laws means the UK's version of the EU's General Data Protection Regulation 2016/679 which has been amended and transposed into the UK law by way of the Data Protection Act 2018 and the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 (SI 2019/419).

Legitimate interest means the interest of our business in conducting and managing our business. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you unless we have your consent or are otherwise required or permitted to by law. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Processing or process means any activity that involves the use of personal data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transmitting or transferring personal data to third parties.