We
are committed to respecting your privacy. This Notice is intended to inform you
about how we collect, use and protect any personal data we collect about you.
It sets out how we comply with the data protection laws and what your rights
are.
This
Notice applies to you if we process your personal data and you are not an
employee. You could be an individual customer, a sole trader, a partnership, a
user of our Website, www.9BFT.EU, someone who works at a supplier or customer
of ours or another organisation that we deal with, someone who enters one of
our marketing competitions or attends one of our events, a recruitment
candidate or someone else who is affected by our activities.
We
are 9BFT.EU (“9BFT BEAUFORT”) part of Nederland-kite.nl
Dutch chamber of commerce 39098443
VAT NO: NL002175002B43
Regstration address:
Rudolf nureyevstraat 6
1326 TH ALMERE
Netherlands
If
you have any queries regarding your personal data and how it may be used by 9BFT.EU,
then you can contact us by email on support@9BFT.EU .
References
to we, our or us in this Notice are references to 9BFT.EU.
This
Notice provides details about:
- What personal
data we collect
- Where we collect
your personal data from
- How we use your
personal data
- Who we share your
personal data with
- How we aim to
protect your privacy
- How long we will
keep your personal data
- International
transfers of your personal data
- Your Rights
- Changes to this
notice
- Contact Us
WHAT PERSONAL DATA DO
WE COLLECT?
We
may collect the following personal data about you:
- Contact details such as your
name, address (including billing and delivery addresses), telephone number
(including mobile number) and email address.
- Identification information such
as your passport and other official identification details, information
from a third-party money laundering check provider, Companies House information
and your national insurance number.
- Personal data including your
age or date of birth, gender, family details and dietary requirements.
- Your social media handles,
posts and information about your followers and the people that follow you.
- Details of financial and
transaction data including purchases, orders, returns and refunds.
- Online browsing activities on
our Website including which items you store in your shopping cart.
- Your usage of our website and
your username and password.
- Information about the device
you use to browse our Website including the IP address, device type,
usernames, account details and passwords.
- Information connected with any
purchases made on our Website including financial and transaction data.
- Communication and marketing
preferences.
- Interests, preferences,
feedback and competition and survey responses.
- Your real-time location.
- Correspondence and
communications with us including relating to complaints, allegations,
disputes and claims.
- Other publicly available
personal data, including any which you have shared via a public platform
(such as LinkedIn, Instagram, YouTube, Twitter or a public Facebook page).
- Business information, such as
where you are a sole trader, a partner or a company director.
- Creditworthiness, where we are
required to undertake investigations in order to establish whether to
enter into or continue a business relationship with you or the
organisation you work for.
- Details of your performance
when working with or for us or in relation to any project or work we are
engaged in.
- Videos, photographs and audio
recordings which you or other people take and provide to us or we take
ourselves.
- Subscription Information such
as when you subscribe to one of our blogs or other materials.
This
list is not exhaustive and in specific instances, we may need to collect
additional personal data for the purposes set out in this Notice.
Special Categories of Personal Data
There
are limited situations in which we collect, store and use the following
“special categories” of more sensitive personal data including:
- information about your race or
ethnicity, religious beliefs and sexual orientation;
- information about your health,
including any medical condition, dietary requirements, health and sickness
records, medical records and health professional information; and
- biometric data including your
height and weight.
Where
we do collect any special category personal data, we will do so based on your
explicit consent.
We
may collect, store and use any criminal records information in relation to you;
in which case we will do so based on legal obligation or your explicit consent.
WHERE DO WE COLLECT
YOUR PERSONAL DATA FROM?
You
We
may collect your personal data directly or indirectly from you, for example
when you:
- engage with us during our
relationship with you or the organisation you work for;
- set up an online account on our
Website and /or purchase products from us;
- Register to use, Website or
other services we provide;
- communicate with us regarding
one of our App, Website or services, to ask a question, report a problem
or for any other reason;
- register for, attend and/or
participate in one of our events or enter one of our competitions;
- enquire about a vacancy or
apply to become an employee of ours;
- enquire about and/or become one
of our content contributors; and
- raise a query, complaint,
claim, legal dispute on behalf of yourself or the organisation you work
for.
Third Parties
We
may also collect personal data from third parties who have your consent or some
other lawful basis for doing so including:
- professional bodies;
- credit reference agencies
including those which carry out data cleansing services;
- organisations who carry out
research and analysis;
- Companies House;
- social media platforms
including such as LinkedIn; Instagram, YouTube, Twitter or public Facebook
page;
- referrals and recommendations,
usually given by other people who know you or have a working relationship
with you;
- your employer or the
organisation you work for;
- our professional advisors
including lawyers, accountants and other advisors;
- your professional advisors
including lawyers, accountants and other advisors; and
- Government, local authorities
or relevant regulators.
HOW WE USE YOUR DATA
Purpose |
Personal data Used |
Lawful Basis |
To carry out
identity and credit checks |
Contact details and
payment information relating to you or the organisation you work for |
We may have a legal
obligation to undertake identification We also have a
legitimate interest in knowing your identity and carrying out money
laundering checks and ensuring that we are likely to be paid |
To enter into and
perform contracts, where we may be supplying products/services to you and/or
the organisation you work for and/or you may be supplying products/services
to us and/or the organisation you work for or where we may be involved in
similar arrangements with third parties |
All the personal
data we collect |
To enter into and
perform contracts with either yourself or the organisation that you represent We have a legitimate
interest to properly perform contracts with third parties |
To deal with
queries, complaints, claims, legal disputes submitted by you or the
organisation you work for and to make queries, complaints, claims, legal
disputes in which relate you or the organisation you work for |
All the personal
data we collect |
This may be
necessary to perform a contract with you or the organisation that you
represent We have a legitimate
interest to improve the services and/or products we provide To defend, bring or
establish legal claims |
To maintain and
improve our services and/or products |
All the personal
data we collect |
We have a legitimate
interest to improve the services and/or products we provide |
Data analytics,
statistical analysis and other research to help us improve our products and
services |
All the personal data
we collect |
We have a legitimate
interest to improve the products and services we provide and to improve user
experience |
Security of our IT
systems |
All the personal
data we collect |
We have a legitimate
interest in ensuring the security of our IT systems |
Direct marketing |
Contact details and
services and products that we have determined may be of interest to you or
your organisation and/or which you or your organisation has purchased in the
past |
We may ask for your
consent to process your data for this purpose, you may revoke your consent at
any point. Alternatively, if you or your organisation has purchased similar
services or products from us previously, we may market similar products or
services as a legitimate interest in developing our business. You have
the right to opt out from such marketing at any time. For more details see
the ‘Marketing’ section below. |
For the prevention,
detection or investigation of crime or the prosecution of offenders |
All of the personal
data we collect |
We have a legitimate
interest in protecting our rights and interests (for example in court cases)
and in protecting the rights and interests of our employees, customers and
any other third party with who we engage. To comply with any
legal obligations and regulatory requirements |
To comply with our
legal and regulatory obligations |
All the personal
data we collect |
To comply with any
legal obligations and regulatory requirements |
To manage our
relationship with you or the organisation you work for and to operate and
manage our business and internal reporting |
All the personal
data we collect |
We have a legitimate
interest to operate our business in an efficient way and to expand our
business To enter into and
perform contracts with either yourself or the organisation that you represent |
Storage of records
relating to you and also records relating to our business |
All the personal
data we collect |
To be able to manage
and fulfil any contract with you, we may have a legal obligation to do so and
we also have a legitimate interest to keep proper records |
Marketing activities
including 9BFT.EU’s website, social media sites and Apps, internal employee
engagement and presentations by 9BFT.EU employees at internal and external
meetings |
All the personal
data we collect |
We have a legitimate
interest in tracking attendance at events and using the images and footage
produced for business and marketing purposes We may also have a
legal and/or regulatory obligation to comply with |
For
some of your personal data you may have a legal, contractual or other
requirement or obligation for you to provide us with your personal data.
If you do not provide us with the requested personal data, we may not be able
to properly perform our contract with you or the organisation you represent or
comply with legal obligations and we may have to terminate our
relationship. For other personal data you may not be under an obligation
to provide it to us, but if you do not provide it then we may not be able to
properly provide you with our goods and services or perform our arrangements
with you or the organisation you represent.
Where
you have given us your consent to use your personal data in a particular
manner, you have the right to withdraw this consent at any time, which you may
do by contacting us as described in the Contact us section
below. We will generally only process your personal data based on your
consent in relation to direct marketing or in relation to the processing of
special category data and data relating to criminal convictions and offences.
Please
note however that the withdrawal of your consent will not affect any use of the
data made before you withdrew your consent and we may still be entitled to hold
and process the relevant personal data to the extent that we are entitled to do
so on a basis other than your consent. Withdrawing consent may also have
the same effects as not providing the information in the first place, for
example we may no longer be able to provide marketing information to you.
We
may anonymise and aggregate any of the personal data we hold (so that it does
not identify you). We may use anonymised and aggregated information for
purposes that include testing our IT systems, research, data analysis,
improving our site and developing new products and services and for any other
purpose.
You have the right to opt out of receiving marketing
communications from us at any time, by:
1. informing us that you wish to change your
marketing preferences by contacting our customer support team at support@9BFT.EU;
2. making use of the simple “unsubscribe” link in
emails
This will not stop
service messages such as order updates and other non-marketing communications.
Personalisation and Automated Decision Making
If
you visit our Website or use our App, you may receive personalised banner
advertisements whilst browsing website of other companies. Any banner
advertisements you see will relate to your browsing activity on our website
from your computer or other devices.
These
advertisements are provided by us via external market leading specialist
providers using techniques such as pixels, web beacons, ad tags, mobile
identifiers and ‘cookies’ placed on your computer or other devices (see
further information on the use of cookies in our Cookie policy. You
can remove or disable cookies at any time – see our cookie policy for further
information.
We
may analyse your browsing and purchasing activity online and your responses to
marketing communications. The results of this analysis, together with
other demographic data, allow us to decide what marketing communications are
suitable for you and to ensure that we contact you with information on
products, services, events and offers that are tailored and relevant to you.
To do so, we use software and other technology for automated decision making.
This
allows us to provide more personalised services and experiences, we may review
personal data held by external social media platform providers about you, such
as the personal data available on social media platforms such as Twitter,
Instagram, YouTube, Twitter and Facebook. Some of our services enable you to
sign-in via external social media platform providers such as Facebook. If you
choose to sign-in via a third party app, you will be presented with a dialog
box which will ask your permission to allow us to access your personal data
(e.g. your full name, date of birth, email address and any other information
you have made accessible).
We
aim to update you about products and services which are of interest and
relevance to you as an individual. To help us do this, we process personal
data by profiling and segmenting, identifying what our customers like and
ensuring messages we send them are relevant based on their demographics,
interests, purchase behaviour, online web browsing activity and engagement with
previous communications. We may also use your personal data to exclude you from
communications which we feel are irrelevant to you. For example, we may exclude
someone from resends of marketing emails when we know that person has already
opened the original email sent.
Another
example of how we may tailor our communications with you is that we may group
individuals with similar interests using this data so we can send them product
news or promotional offers that are relevant to that shared interest.
You may have the right to opt out of some automated processing,
including profiling, at any time by:
1. informing us that you wish to opt out of
automated processing by contacting our customer support team at support@9BFT.EU; and/or
Cookies
Our
Website uses cookies to capture personal data such as the browsing and
purchasing behaviours of people who visit our Website including the pages
viewed, products purchased and the journey around our Website.
We
currently use a cookies tool on our Website which relies on implied consent of
users. In recognition of the fact that the implementation date for the
revised e-Privacy Regulation remains unknown, we are taking reasonable steps
now to align our use of cookies the standard of consent required by GDPR. This
means that we are in the process of updating the tool which, by default,
requires explicit opt in action by users of our Website. This will apply to the
non-necessary cookies. We will ensure any necessary cookies for functionality
and security are marked so that they are not deleted by the tool.
Detailed
information about how we use cookies is in our Cookie policy This will
allow you to make an informed choice as to whether you wish to accept our
cookies.
WHO WE SHARE YOUR
PERSONAL DATA WITH
We
may share your personal data with the following third parties:
- The organisation that you
represent.
- Other companies within our
group.
- Other organisations within our
supply chain so that they can contact you about any issues in the supply
chain or where your personal data is relevant to a subcontractor or party
above us in the supply chain.
- Other organisation including
but not limited to organisations who own the venues at which our events
take place, organisations who market and/or facilitate our events and
photographers and videographers who attend our events.
- Purchasers, investors, funders
and advisers if we sell or negotiate to sell all or part of our business
or assets or restructure our business whether by merger, re-organisation
or otherwise.
- Third parties who ask for or
want referrals for example we may provide your details to a third party
who is seeking services/products which are the same or similar to those
that you provide.
- Other service providers and
advisors to us including companies that support our IT, help us analyse
the data we hold, process payments, send communications to our customers,
provide us with legal, property or financial advice and generally help us
deliver our products and services to you or the organisation that you
represent or for us to purchase them from you or the organisation you
represent.
- Our professional advisors
including lawyers, accountants and other advisors.
- Your professional advisors
including lawyers, accountants and other advisors.
- Credit reference agencies and
other identification agencies so that we can assess your creditworthiness
or verify your identity.
- Organisations who carry out
research, analysis and/or data cleansing services.Governmental bodies,
regulators, law enforcement agencies, security services, courts/tribunals
and insurers including where we are required to do so in order to comply
with our legal obligations and the administration of justice.
HOW WE PROTECT YOUR
DATA
Our controls
9BFT.EU
is committed to keeping your personal data safe and secure and so we have
numerous security measures in place to protect the loss, misuse and alteration
of information under our control. Our security measures include: -
- encryption of personal data;
- regular cyber security
assessments of all service providers who may handle your personal data;
- regular planning to ensure we
are ready to respond to cyber security attacks and data security
incidents;
- weekly penetration testing of
systems;
- security controls which protect
our IT systems infrastructure and our premises from external attack and
unauthorised access;
- internal policies setting out
our data security rules for our personnel; and
- regular training for our
employees.
We
take data security very seriously and will use all reasonable endeavours to
protect the integrity and security of the personal data we collect about you.
WHAT YOU CAN DO TO
HELP PROTECT YOUR DATA
You
should always be cautious when sharing your personal data. No one from our
company will ever ask you to confirm any bank account or credit card details
via email. If you receive an email claiming to be from 9BFT.EU asking you
to do so, please ignore it and do not respond.
If
you are using a computing device in a public location, we recommend that you
always log out and close the website browser when you complete an online
session.
In
addition, we recommend that you take the following security measures to enhance
your online safety:
- When creating a password, use a
difficult word/number combination of at least 8 characters and something
that is not easily guessed or something that cannot be easily obtained
such as your name, email address, or other personal data that can be
easily obtained.
- Frequently change your password
(you can do this in your account settings.
- Avoid using the same password
for different online accounts.
HOW LONG WE KEEP YOUR
DATA
We
will not retain your personal data for longer than necessary for the purpose
for which is has been obtained and then for as long as there is any risk of a
potential claim, which will be dependent upon the limitation period for the
particular type of claim. Various laws, accounting and regulatory requirements
applicable to us also require us to retain certain records for specific amounts
of time. In relation to your personal data, we will hold this only for so long
as we require that personal data for legal or regulatory reasons or for
legitimate organisational purposes. We will not keep your data for longer than
is necessary for the purposes for which we collect them.
Our
Data Retention Policy sets out the length of time we will usually retain
personal data and where these default periods might be changed.
It
is important to ensure that the personal data we hold about you is accurate and
up-to-date, and you should let us know if anything changes, for example if you
move position or work for a different organisation or change your phone number
or email address. You can contact us by using the details set out in the
Contact us section below.
INTERNATIONAL
TRANSFERS
The
personal data we collect may be transferred to and stored in countries outside
The netherlandss and the European Union. This will typically occur when service
providers are located outside the THE NETHERLANDS and the European Union or if
you are based outside theThe Netherlands and the European Union. These
transfers are subject to special rules under data protection laws.
Some
of these jurisdictions require different levels of protection in respect of
personal data and, in certain instances, the laws in those countries may be
less protective than the jurisdiction you are typically resident in. We will
ensure that your personal data is only used in accordance with this Notice and
applicable data protection laws and is respected and kept secure and where a
third party processes your personal data on our behalf we will ensure that one
of the following safeguards is implemented:
- we will only transfer your
personal data to countries that have been deemed to provide an adequate
level of protection for personal data by the European Commission;
- where we use certain service
providers, we may use specific contracts approved by the European
Commission which give personal data the same protection it has in the THE
NETHERLANDS and the European Union; and
- where we use providers based in
the US, we may transfer data to them if they are part of the Privacy Shield
which requires them to provide similar protection to personal data shared
between the Europe Union and the US.
Our
directors and other individuals working for us may in limited circumstances
access personal data outside of the THE NETHERLANDS and European Union if they
are on holiday abroad outside of the THE NETHERLANDS or European Union.
If they do so they will be using our security measures and will be subject to
their arrangements with us which are subject to English Law and the same legal
protections that would apply to accessing personal data within the THE
NETHERLANDS.
In
limited circumstances the people to whom we may disclose personal data as
mentioned in the “Who We Share Your Personal Data With” section above may be
located outside of the THE NETHERLANDS and European Union. In these
cases, we will impose any legally required protections to the personal data as
required by law before it is disclosed.
For
further details please contact us by using the details set out in the Netherlands section
below.
YOUR RIGHTS
You
have the following rights in relation to your personal data:
- The right to be
informed about how your personal data is being used.
- The right to request access to
personal data we hold about you.
- The right to ask us to
update and correct any out-of-date or incorrect personal data
that we hold about you.
- The right to object to
processing of your personal data and/or to withdraw any consent you
have given us and to opt out of any marketing communications that we may
send you.
- The right to restrict
processing of your personal data.
- The right to object to
certain automated decision-making processes using your personal data
including profiling.
- The right to request
that we erase your personal data in certain circumstances (the
right to be forgotten) for example when the data are no longer
necessary for the purpose for which we collected them.
- The right to have your
personal data provided to you by us in a structured, commonly used and
machine-readable format and transmitted to another data
controller. This is known as the right to data portability.
You
should note that some of these rights, for example the right to require us to
transfer your data to another service provider or the right to object to
automated decision making, may not apply as they have specific requirements and
exemptions which apply to them and they may not apply to personal data recorded
and stored by us. However, some have no conditions attached, so your
right to withdraw consent or object to processing for direct marketing are
absolute rights.
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 another appropriate security measure to ensure that
personal data is not disclosed to any person who has no right to receive it.
Whilst
this Notice sets out a general summary of your legal rights in respect of personal
data, this is a very complex area of law. More information about your legal
rights can be found on the Information Commissioner’s website at KVK.NL
If
you wish to exercise any of the above rights, you can always contact us using
the details set out in the 'Contact Us' section below.
CHANGES TO THIS
NOTICE
We
may update this Notice from time to time. When we change this Notice in a
material way, we will update the version date at the bottom of this Notice. For
significant changes to this Notice we will try to give you reasonable notice
unless we are prevented from doing so. Where required by law we will seek
your consent to changes in the way we use your personal data.
CONTACTING US
In
the event of any query or complaint in connection with the information we hold
about you, please email support@9BFT.EU