PRIVACY POLICY – BELLE VIE TV LIMITED

Scope

This Privacy Policy describes how Belle Vie TV collects and uses your personal data. Our data processing is carried out in accordance with our obligations under the EU General Data Protection Regulation (GDPR) and the Data Protection Act 2018.

Who we are

Belle Vie TV Limited (‘we’, ‘us’) are a ‘data controller’ for the purposes of the Data Protection Act 2018 (i.e. we are responsible for, and control the processing of, personal information).

In this policy, you (‘you’, ‘your’) means any individual whose personal data we process, including Belle Vie TV’s clients and client personnel, suppliers and supplier personnel, counterparties and counterparty personnel, and general business contacts.

Information we collect

Data may be collected by us in the form of personal information for insertion in documents, invoices and other paperwork supplied, produced or negotiated by you, us or on your behalf further to the provision of the services by us to you. By way of further examples:

• Personal information you provide to us: we may collect personal information such as your name, email address and postal address in the course of us providing services to you.
• Personal information you provide about third parties: you may give us employee, contractor or associate names, email addresses and postal addresses and the name, address and email address of business contacts in the course of us providing services to you. If you give us information about another person, you confirm that the other person has agreed that you may transfer and process such information to us. We do not collect any sensitive data about you (e.g: details of your race, ethnicity, health) nor any information about criminal convictions or offences. We do not carry out any type of automated decision making or profiling.

How we use the data we collect

As part of ensuring we are providing the right services to you, we may use your information:

• as is reasonably necessary for the performance of a contract to which we and you are subject and to pursue our legitimate interests in a way which would reasonably be expected as part of running our business and supplying our services; and
• for record-keeping and to comply with legal requirements to ensure compliance with our legal and financial obligations, as required by governmental authorities or for the purposes of establishing, pursuing and defending legal claim(s) as responsible business operations; and
• in relation to obtaining professional advice and insurance, as is necessary for our legitimate interests in order to protect and grow our business; and
• in case needed to establish, pursue and defend legal claim(s) as responsible business operations.  

All such use will be done in a way that does not materially impact on your rights, freedom or interests. 

How we store and protect the data we collect

• We are committed to ensuring that your data is kept secure and that there are processes in place to prevent loss, theft or unauthorised access. We will use technological and organisation measures to keep your data secure. However, while we will use all reasonable efforts to secure your personal data, you acknowledge that the use of the internet/ cloud storage/ email communication is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that is transferred from you or to you via the internet. If you have any particular concerns about your information, please contact us using the details below.
• Records kept on electronic equipment: We use a PC (personal computer) and laptop for business and personal purposes. Information is stored on the devices using Dropbox. Dropbox’s privacy policy can be found here: https://www.dropbox.com/privacy . PC and laptop security includes antivirus software and secure password protection.
• Paper records: Any paper records of data (in the form of meeting notes or copies of agreements, for example) are stored securely and will be destroyed when no longer needed or at the end of the legally required retention period if applicable (whichever is the later).
• Email: Our email exchange host is Absolutely PC Limited, unless we have been given an email account by you to use. Absolutely PC’s privacy policy can be found here: https://www.absolutelypc.co.uk/privacy-policy. We will keep your email address(es) in our email records in case needed to enable us to email efficiently, reasonably carry out the services requested by you and/or for administration purposes (for example, to send out an invoice to you). 
• Mobile devices: Our mobile phone provider is Vodafone. We may retain your telephone number in our telephones for ease of communication purposes.

Who your information may be shared with

We may share your information with the following parties:

• Law enforcement agencies in connection with any investigation to help prevent unlawful activity;
• Third party suppliers of administrative, IT, insurance or legal services, solely for the purposes of undertaking administration and/or their services on our behalf;
• Our selected third party suppliers of accountancy services, solely for the purposes of accounting and bookkeeping;
• HMRC and related organisations relevant to finance, accounting and tax obligations and reporting;
•  Statutory or governmental organisations or third parties where we are legally obliged to do so;
• Third parties to whom we sell, transfer or merge parts of our business or our assets.

We use reasonable endeavours to require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law.

International use of data

Further to the provision of the services by us to you we may transfer your data outside the European Economic Area (EEA). We are subject to the General Data Protection Regulation (GDPR) requiring us to protect your personal data. We will use reasonable endeavours to ensure that if we transfer your personal data outside the EEA such data will be dealt with a similar level of security as required under the GDPR.

How long will your data be retained?

Data will be retained as long as is appropriate and necessary to fulfil the purposes for which we collected it, in line with legal and tax authority requirements and/or for reasonably recommended periods (as recommended by our insurance provider for example). Generally, currently we believe that this will mean that we will retain records and data for a period of 6 years after our business relationship has ended. By way of further example and information data may be retained for such a retention period:

• In back-up files (on Dropbox as referred to above) for reference in the event of similar or the same repeat business deals for business reasons or for ease of invoicing;
• In our email system for reference in the event of similar or the repeat business deals or for business contact reasons.

What rights do you have?

You have rights in relation to your personal data such as the right to rectify, request copies and erasure. More information on your rights can be found here: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/. If you wish to exercise any of these rights please email us as the email address stated below. 

Contacting us

If you have any questions about this policy or the information we hold about you, please contact us at ian@bellevietv.com.

Complaints and data breaches

If you wish to raise a complaint about how we have handled your personal data, you can contact us at the email address above and we will investigate the matter for you. If you are not satisfied with our response you can complain or are concerned about a data breach, you can contact the Information Commissioners Office (ICO) here: https://ico.org.uk/make-a-complaint/your-personal-information-concerns/. We will inform you and/or the ICO of any data breach when legally required to do so. More information about the ICO, the register of data controllers and what the ICO does is available at: https://ico.org.uk/about-the-ico/.  

This privacy policy was last updated on 25/05/2018. We may change this policy to reflect changes in the law or our privacy practices. We will alert you of any such changes in the invoice which we send you after such changes have been made. The most up to date version is always available on request. 

COOKIE POLICY – BELLE VIE TV LIMITED

Cookies and how they benefit you

Our website uses cookies, as almost all websites do, to help provide you with the best experience we can. Cookies are small text files that are placed on your computer or mobile phone when you browse websites.

Our cookies help us:

- Make our website work as you'd expect

- Improve the speed/security of the site

We do not use cookies to:

- Collect any personally identifiable information (without your express permission)

- Collect any sensitive information (without your express permission)

- Pass data to advertising networks

- Pass personally identifiable data to third parties

- Pay sales commissions

How to control cookies

You can control and/or delete cookies as you wish – for details, see www.aboutcookies.org. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work.