Bridge Wind Management Group Limited – Privacy Policy

At Bridge Wind Management Group Limited we take privacy seriously and are committed to protecting the data you provide to us.

This notice explains when and why we collect personal data about you, how this data is used, the conditions under which it may be disclosed to others and how it is kept secure.

About Bridge Wind Management Group

Bridge Wind Management Group Limited is a limited company with registered company number 11441915 and registered office at Suite 2A, Century Mews, 100A Church Road, Tiptree, Essex, CO5 0AB

Bridge Wind Management Group Limited is the controller of your personal data and is registered with the Information Commissioner under registration number ZA047540.

How we collect your personal data

We may collect and process information about you in the following ways.

We may receive information about you from you or from third parties when we are acting for, or considering acting for, a client and we are required to obtain information about you, for example if you are providing services for an asset that we manage on behalf of a client.

The information we receive may include your contact details, identification information, financial information, employment information, details included in any correspondence and information about you in connection with any matter on which we are acting. Where we receive information about you, we will only use that information for the purposes intend.

Information that you give to us

You provide information about yourself when you make an enquiry to us or ask us to provide services to you, or when entering information via our website, opt-in/consent forms, apps or by communicating with us by telephone, post, email, live chat, social media or otherwise. It includes additional information that you provide to us during the course of any activities that we undertake together.

The information you give to us mainly includes your contact details, identification information, financial or billing information, employment information, details included in any correspondence and information about you in connection with any matter on which we are acting.

Information we receive from other sources

We may receive information about you from third parties.

You and/or our client may be a party to or otherwise concerned in a transaction and your details may be received by us by being available in an online data room, in a commercial contract or via the process of due diligence.

From banks and finance companies from whom we are given or request information, where you are their customer.

From people connected to recruitment, including recruitment consultants who may provide information about you to us in relation to a potential job or employers who may provide a reference about you to us.

From regulatory bodies when making regulatory enquiries or where we are required to obtain information to satisfy our regulatory obligations.

From introducers and referrers, including professional advisers who may refer you to us.

We may supplement the personal data collected about you with information from publicly available sources, such as information to validate your identity or address, or to perform other checks.

The information that we receive about you from others can include both personal and special category data. Special categories of personal data are personal data about an individual’s:

(a)     race;
(b)     ethnic origin;
(c)     politics;
(d)     religion;
(e)     trade union membership;
(f)      genetics;
(g)     biometrics (when used for ID purposes);
(h)     health;
(i)      sex;
(j)      sexual orientation.

Criminal convictions or offences must be treated in the same way as special category data.

Information we may collect about you

We may automatically collect information about you that we may observe, detect or create without directly asking you to provide the information to us. In common with most other businesses, this will mainly include information gathered automatically through your use of our website or online services, but it may also include information from publicly available sources such as your company website or your social media profile, or from our subsequent communications with you.

Type of personal data we may process about you

We may process a range of personal data about you. To make it easier to understand the information that we use about you, we have divided this information into categories in the table below and provided a short explanation of the type of information each category covers (please note that not all categories may be applicable to you):

Category  Personal data included in this category
Banking/billing Information used to send/receive funds to/from you or that appears on your bills
Behavioural Your activities, actions and behaviours
Biographical Your qualifications, certifications and circumstances
Cardholder Your payment card details
Contact Information that can be used to address, send or otherwise communicate a message to you (i.e. email address, postal address, employer name and job title)
Correspondence Information contained in our correspondence or other communications with you or about you, about our products, services or business
Employment Your previous, current or future employment details
Geo-location Information that contains or reveals the location of your electronic device
Identification Information contained in a formal identification document or social security or other unique reference relating to you
Monitoring We may record phone calls and retain transcripts of dialogue (i.e. livechat conversations) either for our records or for training purposes. If you visit one of our offices your image may be recorded on CCTV for security purposes
Special categories of personal data Your racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, any personal data that relates to your health, sex life, sexual orientation or criminal offences or records or any genetic or biometric data about you

How and why we may use your personal data

We may use the information we collect about you in the following ways:

Where it is necessary for us to perform a contract with you

We may use and process your personal data where we have supplied you (or continue to supply you) with services, where we have arranged for the supply of another party’s services to you, or where you are in discussions with us about a particular subject or matter on which you are considering entering into a contract with us.

We will use your information in connection with the contract for the provision of services when it is necessary to carry out that contract or for you to enter into it.

We may also use and process your personal data in connection with our recruitment activities, if you apply for a position with us (whether directly or through a third party) or send your details to us on a speculative basis.

Where we have a legitimate interest

We may use and process your personal data where it is necessary for us to pursue our legitimate interests as a business for the following purposes:

  • to carry out our onboarding checks so we are able to provide services to you;
  • to enter into and perform the contract we have with you or your business;
  • to assess and improve our service to clients or our clients’ customers (where applicable) through recordings of any calls and livechat sessions;
  • for the prevention of fraud and other criminal activities;
  • to verify the accuracy of the data that we hold about you and to create a better understanding of you as a client and our clients’ customers (where applicable);
  • to send you email and/or hard copy communications (set out in Marketing below). Such communications may include content on relevant services and other news/announcements. Please note that your information may be used to send you details of our products or services that we have identified as likely to be of interest to you, based (where applicable) on the preferences you have indicated to us;
  • to create a profile of you (based, where applicable, on any preferences you have indicated) to enable us to decide what products and services to offer to you for marketing purposes;
  • to undertake analysis to inform our business and marketing strategy;
  • to manage and deliver internal projects for business improvement;
  • for network and information security purposes to enable us to take steps to protect your personal data against loss or damage, theft or unauthorised access;
  • to comply with a request from you in connection with the exercise of your rights (for example, where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request);
  • to assist in the management of queries, complaints or claims; and
  • for the establishment, exercise or defence of our legal rights.

Where you have provided consent

We will seek separate and specific consent from you in circumstances where we wish to feature your identity in any case study, press release, advertisement or testimonial or wish to include your image in a photograph or video in connection with public relations or promotional activities.

You have the right to withdraw your consent at any time. Please see ‘Withdrawing your consent’ for further details.

Where required by law

Where you engage us to provide services to you, we will process your personal data and the personal data of third parties in order to comply with our legal obligations.

We may also use and process your personal data in order to comply with other legal obligations to which we are subject, as follows:

  • to maintain a register of corporate gifts and hospitality to comply with anti-bribery laws;
  • to comply with our other legal and regulatory obligations.

Special categories of personal data

We may have to process sensitive personal data (known as ‘special categories of personal data’) about you or others associated with you, for example your family. We will only use this kind of information where:

  • we have your explicit consent;
  • it is necessary for us to use this information to protect your vital interests or those of another person where it is not possible to obtain consent;
  • it is necessary to do so in connection with the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity; or
  • in exceptional circumstances, another ground for processing special categories of personal data is met.

Where you have provided us with explicit consent to use special categories of personal data about you, you may withdraw your consent for us to process this data at any time. Please see ‘Withdrawing your consent’ for further details.

Others who may receive or have access to your personal data

Our suppliers and service providers

Our work for you, or a client, may require us to provide information to third parties who will use your information for the purposes of providing services to us or directly to you on our behalf.

Other professional advisers involved in a contract or service provision

Our work for you, or a client, may require us to provide information to third parties such as law firms, accountants and other professional advisers, who will use your information in connection with the contract or services. They may provide their own services directly to you.

Any third party to whom we disclose information about you will be under an obligation to keep your information secure and not to use it for any purpose other than that for which it was disclosed unless you agree with them otherwise.

Other ways in which we may share your personal data

We may transfer your personal data to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation. We may also transfer your personal data if we are under a duty to disclose or share it to comply with any legal obligation, to detect or report a crime, to protect your vital interests, to enforce or apply the terms of our contracts or to protect the rights, property or safety of our visitors and clients. However, we will ensure that your privacy rights continue to be protected.

Where we store your personal data

All information you provide to us for our use is stored on our secure servers, which are located within the UK and the European Economic Area (EEA).

The third parties who may receive and have access to your personal data may be located outside the EEA or they may transfer your data outside the EEA. Those countries may not have the same standards of data protection and privacy laws as in the UK, which means additional safeguards must be put in place. Whenever we transfer your data outside the EEA, we impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the UK. We may also require the recipient to subscribe to ‘international frameworks’ intended to enable secure data sharing. Any third parties transferring your data outside the EEA must also have in place appropriate safeguards as required under data protection law.

How long we keep your personal data for

If we collect your personal data, the length of time for which we retain it is determined by a number of factors including the type of data, the purpose for which we use that data and our regulatory and legal obligations attached to its use. We do not retain personal data in an identifiable format for longer than is necessary.

Your rights

You have various rights in relation to your personal data under data protection legislation. In relation to certain rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal data. Except in rare cases, we will respond to you within 30 days from either (i) the date that we have confirmed your identity; or (ii) where we do not need to do this because we already have this information, from the date we received your request.

Accessing your personal data

You have the right to ask for a copy of the data that we hold about you by emailing or writing to us at the address at the end of this policy. We may not provide you with a copy of your personal data in certain circumstances but we will explain why we are unable to provide the data.

Correcting and updating your personal data

The accuracy of your data is important to us.  If you change your name or address/email address, or you discover that any of the other data we hold is inaccurate or out of date, please contact us using the details at the end of this policy.

Withdrawing your consent

Where we rely on your consent as the legal basis for processing your personal data, as set out under ‘How we use your personal data’, you may withdraw your consent at any time by emailing us at info@bridge-wind.co.uk using ‘Withdrawal of consent’ as the subject heading of your email.  If you withdraw your consent, our use of your personal data before you withdraw your consent is still lawful.

Objecting to our use of your personal data

Where we rely on our legitimate interests as the legal basis for processing your personal data for any purpose(s), as set out under ‘How we use your personal data’, you may object to our using your personal data for these purposes by emailing or writing to us at the address at the end of this policy. Except for the purposes for which we are satisfied we can continue to process your personal data, we will temporarily stop processing your personal data in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection legislation, we will permanently stop processing your data for those purposes. Otherwise, we will provide you with our justification as to why we have to continue processing your data.

You may object to our processing your personal data for direct marketing purposes and we will immediately comply with your request. If you would like to do so, please email us at info@bridge-wind.co.uk using ‘Unsubscribe’ as the subject heading of your email

Erasing your personal data or restricting its processing

In certain circumstances, you may ask for your personal data to be removed from our systems by emailing or writing to us at the address at the end of this policy. Provided we do not have any continuing lawful basis to continue processing or holding your personal data, we will make reasonable efforts to comply with your request.

You may also ask us to restrict processing your personal data where you believe our processing is unlawful, you contest its accuracy, you have objected to its use and our investigation is pending, or you require us to keep it in connection with legal proceedings. We may only process your personal data while its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings.

Transferring your personal data in a structured data file

Where we rely on your consent as the legal basis for processing your personal data or have to process it in connection with your contract, as set out under ‘How we use your personal data’, you may ask us to provide you with a copy of that data in a structured data file. We will provide this to you electronically in a structured, commonly used and machine-readable form, such as a CSV file.

You can ask us to send your personal data directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal data in certain circumstances but we will explain why we are unable to provide the data.

Complaining to the UK data protection regulator

You have the right to complain to the Information Commissioner’s Office (ICO) if you are concerned about the way we have processed your personal data. Please visit the ICO’s website for further details.

Security and links to other sites

Security measures we put in place to protect your personal data

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 website, and any transmission is at your own risk. Once we have received your personal data, we have in place reasonable and appropriate controls to ensure that it remains secure against accidental or unlawful destruction, loss, alteration or unauthorised access.

Where we have given you (or where you have chosen) a password that enables you to access any of our online or electronic resources, you are responsible for keeping this password confidential. We advise you not to share your password with anyone.

Links to other websites

Our website may contain links to other websites run by other organisations. This policy does not apply to those other websites, so you should read their privacy statements. We are not responsible for the privacy policies and practices of other websites even if you access them using links that we provide, and their security cannot be guaranteed.

If you linked to our website from a third party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party website and recommend that you check the policy of that third party website.

Cookies

Use of cookies

Like many other websites, our website uses cookies (including Google Analytics cookies to obtain an overall view of visitor habits and visitor volumes to our website). Cookies are small pieces of information sent to your computer and stored on its hard drive to allow our website to recognise you when you visit. It is possible to switch off cookies by setting your browser preferences.

Marketing and other communications

If we are contacting you in your personal capacity

You will only receive communications from us (including information about our products and services, relevant updates and other news/announcements) if you indicate to us a preference (‘opt in’) to do so. You will be invited to complete a client consent/opt-in process by email as a result of any of the following:

  • you becoming a client;
  • your attendance at an event or seminar hosted, or co-hosted, by us;
  • your attendance at a ‘public’ event organised or co-hosted by us;
  • your providing a business card directly to an employee of ours at (for example) a trade or networking/business event;
  • your registering your brief contact details to obtain information or free downloads from our website;
  • an email request from you to attend an event we have advertised via social media or on our website or via a third party.

We may contact you in response to an article or social media promotion that you have carried out.

If we are contacting you in connection with the business or organisation you work for

We may contact you to notify you of services we provide that may benefit you or your business.

We will never share your information with third party partners for their own marketing uses, although we may use service providers to assist us with our own marketing.

If you no longer wish to receive such communications, please or email info@bridge-wind.co.uk.  Please see ‘Withdrawing your consent’ and ‘Objecting to our use of your personal data and automated decisions made about you’ above for further details on how you can do this.

Contact us

The person responsible for data protection at Bridge Wind Management Group Limited is the Managing Director. Please direct any queries about this policy or about the way we process your personal data to them at the contact details below.

Please write to the Managing Director at Bridge Wind Management Group Limited, Suite 2A, Century Mews, 100A Church Road, Tiptree, Essex, CO5 0AB, UK. Our email address for data protection queries is info@bridge-wind.co.uk. If you would prefer to speak to us by phone, please call 0345 647 0657.

Changes to this privacy notice

We reserve the right to update this privacy notice at any time.

BRIDGE WIND MANAGEMENT GROUP LIMITED

Reviewed November 2023