Privacy Policy

Bespoke Technology Labs (“We”) are committed to protecting and respecting your privacy.

This privacy policy, together with our privacy notice(s), and our terms of service(s) set out the basis of which any personal data we collect from you, or that you provide to us, will be processed by us. It is is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

Purpose of this privacy policy
This privacy policy aims to give you information on how we collect and processes your personal data through your use of this website and our products or services, including any data you may provide when you enter into a contracted service with us, sign up to use our products, or make a support or contact request.

It is important that you read this privacy policy together with any other privacy notice(s) or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements our other notices and is not intended to override them.

Controller
Bespoke Technology Labs Limited is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy policy).

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact our data protection team using the details set out below.

Contact details
If you have any questions, comments or requests regarding this privacy policy, the practices or your dealings with our products and services, you can get in touch with us using the Contact page or the details below:

Data Protection Team
Bespoke Technology Labs Limited
dataprotection@bespoketechlabs.co.uk

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to our Privacy Policy or Notices and your duty to inform us of changes
Changes to our privacy policy or privacy notices and archived versions are detailed at the bottom this of this document.

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
This website contains links to third-party websites, plug-ins and applications such as Smooch.io who provide the capabilities for us to provide online chat support.

Clicking on external links indicated within our products and services, or enabling external 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. When you leave our website, we encourage you to read the privacy notice of every website you visit.

We may collect, use, store and transfer different kinds of personal data about you which include:

  1. Identity Data includes first name, last name, username, date of birth, and gender.
  2. Contact Data includes billing addresses, home or work contact address, email address, and telephone numbers.
  3. Financial Data includes bank account and payment card details.
  4. Transaction Data includes details about payments to and from you and details of products and services you have purchased from us.
  5. Technical Data includes internet protocol (IP) addresses, MAC addresses (where applicable), 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, products, and services.
  6. Profile Data includes your username, encrypted password(s), purchases or orders made by you, your interests, preferences, feedback and survey responses.
  7. Usage Data includes information about how you use our websites, products, and services.
  8. Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

 

We 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 policy and notice will be provided.

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.

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

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

  • Direct interactions
    You may give us your Identity, Contact, or Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • apply for our products or services;
    • create an account on our website;
    • subscribe to our service or publications;
    • request marketing to be sent to you;
    • enter a competition, promotion or survey; or
    • give us some feedback.

 

  • Automated technologies or interactions
    As you interact with our products and services, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, and other similar technologies. For more information, please see our cookie policy.

 

  • Your actions
    In all scenarios where we request for you to input your personal data, we will do so using web-based forms. In this instance, we have indicators on particular fields of information stating the purpose(s) for the collection of the data.

    An example of where data collection purposes are specified.

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

  • To carry out our obligations arising from any contracted services in effect between you and us, or those we are about to enter into with you.
  • To ensure that our products and services are accessible and presented in the most effective manner for you and for your computer.
  • To provide you with information about 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.
  • To allow you to participate in, or use interactive features in our products or services when you choose to do so.
  • To notify you about changes to our products or services, where we have an obligation or consent to do so.
  • To comply with a legal or regulatory obligation.

 

Generally, we only rely on consent as a legal basis for processing your personal data. You have the right to withdraw consent to marketing or processing at any time by filing a request.

We will never share your personal data with third parties to use your data.  To keep your inbox clean from spam we will only contact you if necessary, or if you are subscribed to receive communications from us. If you do not want us to use your data in the specified ways, please tick the relevant boxes which can be found in our products and services. Alternatively, you can contact us to initiate this process.


Purposes
In our privacy notices, we have set out descriptions of all the ways we may use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact Us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in our notices.

To view our privacy notices by product and service, please scroll to the bottom of this page.

The data that we collect from you will be transferred to, and stored at, a destination inside the European Economic Area (“EEA”). It could also be processed by staff operating inside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the support of data processing for our systems, the processing of your usage details, and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We strictly endeavour to take every step necessary to ensure that your data is treated securely and in accordance with this privacy policy and in alignment with relevant legislation.

Where you have chosen a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

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 mitigate unauthorised access.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, 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.

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements.

Details of retention periods for different aspects of your personal data are available in our product-specific privacy notice documents which are available at the bottom of this page.

In summary, we are legally required to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being our customers for accounting and tax based purposes.

In some circumstances, you can ask us to delete your data by utilising your legal rights and requesting your personal details to be erased.

To file an erasure request, please click here.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:


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 may 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 your personal data (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. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month 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.

Our policy is to request that “Minors” (the age of Minors is determined by local laws where you reside) do not engage in the use of our services without the consent of a parent, legal guardian, and to tell someone if any problems occur online.

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to the given e-mail address.

Personal data, or personal information, 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).

Lawful basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. 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.

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

Third parties

Internal third parties
Other companies within our group acting as joint controllers or processors and who are based in the UK and provide managed sales and support services to our group.

External third parties

  • Service providers acting as processors based in the UK who provide managed sales and support services.
  • Professional advisers including mentors, lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.

All our products and services adhere to this privacy policy, however, we also provide individual privacy notices for each of our products and services detailing the types of data we collect and the purposes of doing so.

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Privacy Notice relating
to Business Processes
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Privacy Notice for
EPQ Spaces
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