Privacy Policy

Updated: 26/07/2022

Overview

1. The Company takes the security and privacy of data seriously as is committed to complying with its legal obligations under the EU General Data Protection Regulation (‘GDPR’) in respect of data privacy and security.
2. This Privacy Policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. This Privacy Policy applies if you are using our website to browse, are registering a user account with us, want to buy or sell a watch or require our watch repair service.
3. This Privacy Policy is intended to make you aware of how and why your personal data will be used, namely for the purposes of us carrying out our contractual obligations, and how long it will usually be retained for. We are required to notify you of this information under data protection legislation.
4. We are committed to complying with our data protection obligations, and to being concise, clear and transparent about how we obtain and use personal information or sensitive personal information and how (and when) we delete that information once it is no longer required.
5. Please ensure that you read this notice and any other similar notice we may provide to you from time to time when we collect or process personal information about you. You must read this notice because it explains:
   • how we process your personal information as defined below, how it is used, stored and shared, for what purposes, the steps taken to keep that information secure and for how long it is kept and disposed of;
   • your rights in relation to data protection;
   • where and to whom to complain if you have issues in relation to your privacy.
6. We will review and update this notice regularly in accordance with our data protection obligations. We will circulate any new or modified policies or notice in relation to your data when it is adopted on our website and you should read this notice before you send us any personal information.
7. In addition to this Privacy Policy, please read our Terms of Business, Website Terms of Use and Cookie Policy. This privacy notice supplements the other notices and is not intended to override them.
8. David Dyli is responsible for data protection compliance within the Company. He is the data protection manager and he is the person with overall responsibility for this notice. If you have any questions, comments about the content of this notice, if you need further information or if you have a complaint about how we processed your data you should contact him directly. His contact details are below:
   E: david@bqwatches.com
   T: 01923 85 58 58
   A: 74-76 Wattling Street, Radlett, Herts, WD7 7NP
9. We hope that our data protection manager can resolve any query or concern you raise about our use of your information. If however you feel that we have failed to address your concerns appropriately, you can contact the Information Commissioner at ico.org.uk/concerns/ or telephone: 0303 123 1113 for further information about your rights and how to make a formal complaint.

Who collects the data

1. BQ Watches Ltd (the Company) obtains, keeps and uses personal information and sensitive personal information about clients and suppliers for a number of reasons. The Company is a “ data controller”. This means that we are responsible for deciding how we hold and use personal information about you.
2. BQ Watches Ltd is a data controller whether we receive the details from you directly or from another data controller who you have instructed to send us those details. Another data controller will have own privacy policies in place and you should ensure that you are familiar with those before you ask them to send us your details.
3. This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Alternatively, you can download a pdf version of the policy here [LINK]. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

Data protection principles

1. The Company will comply with the following data protection principles when processing personal information:
   • we will process personal information lawfully, fairly and in a transparent manner;
   • we will collect personal information for specified, explicit and legitimate purposes only, and will not process it in a way that is incompatible with those legitimate purposes;
   • we will only process the personal information that is adequate, relevant and necessary for the relevant purposes;
   • we will keep accurate and up to date personal information, and take reasonable steps to ensure that inaccurate personal information is deleted or corrected without delay;
   • we will keep personal information in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the information is processed; and
   • we will take appropriate technical and organisational measures to ensure that personal information is kept secure and protected against unauthorised or unlawful processing, and against accidental loss, destruction or damage.

The data we collect about you

1. 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). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
   • Identity Data: includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
   • Contact Data: includes billing address, delivery address, email address and telephone numbers.
   • Financial Data: includes bank account and payment card details.
   • Transaction Data: includes details about payments to and from you and other details of services you have purchased from us.
   • Marketing Data: includes your preferences in receiving marketing from us and your communication preferences.
   • Background Data: includes details of your background information that you provide to us when enquiring about our services and communication between us and you.
   • Technical Data: includes internet protocol (IP) address, 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 this website.
   • Usage Data: Includes information about how you use our website ie how long you stay on each page and how long you generally visit our website for.
   • 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 notice.

If you fail to provide personal data

1. 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 data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel our service you have with us but we will notify you if this is the case at the time.

How is your personal data collected?

1. We use different methods to collect data from and about you including through:
   1. Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise.
   2. Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
      • Identity and Contact Data from publicly availably sources such as Companies House
      • Opponents in litigation or other parties in transactions.
      • Other controllers who you submit your information to in accordance to their privacy policy.

How we use your personal data

1. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
   • Where we need to perform the 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. Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service. 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). Where we process your information under this lawful basis, we will specify legitimate interests accordingly.
   • Where we need to comply with a legal or regulatory obligation that we are subject to.
   • Where you have provided us consent. Generally, we do not rely on consent as a legal basis for processing your personal data but may in certain circumstances request your explicit consent to process your data. If we do so, we will advise you on the purpose of that data collection, how we will process it and will request your explicit and clear consent for us to process that data for that purpose. Where we rely on your consent to process your data, you will be able to withdraw your consent at any time.

Purposes for which we will use your personal data

1. We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. 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 the table below.

   Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
   To respond to enquiries	(a) Identity (b) Contact (c) Background	To take necessary steps to enter into a contract with you.
   To register you as a new client	(a) Identity (b) Contact (c) Marketing	(a) To take necessary steps to enter into a contract with you. (b) For legitimate interests to maintain client database and to grow our business.
   To deliver our services including: – Buy watch from you – Sell a watch to you – Repair your watch for you – Manage payments, fees and charges – Collect and recover money owed to us – To conduct litigation, mediations or transactions	(a) Identity (b) Contact (c) Background (d) Financial (e) Transaction (f) Marketing	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to maintain customer records, to be able to quote for the service, to be able to provide estimate for the watch, to grow our business and recover debts due to us)
   To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Background (d) Marketing	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how clients use our products/service)
   To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Marketing (d) Technical (h) Usage (i) Aggregate	Necessary for our legitimate interests (to develop our products/services and grow our business)
   Signing up to newsletter (non-client)	(a) Identity (b) Contact (c) Marketing	Legitimate business interests (to deliver relevant website content and advertisements to you, notify you of our new products and services, and measure or understand the effectiveness of the advertising we serve to you)

Marketing

1. Clients: We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. When you register as a user and make an enquiry about our products or services, we will process your Identity, Contact and Marketing data for the direct marketing purposes. When doing so we will comply with Privacy and Electronic Communications Regulations 2003 (PECRs) and GDPR. We will:
   • obtain this information from you
   • obtain this information for the purpose of notifying you of our products and services and send you our newsletters, to deliver relevant website content and advertisements to you, notify you of our new products and services and measure or understand the effectiveness of the advertising we serve to you;
   • take care of your data and will not sell it to third parties.
   • provide you with facilities to update your preferences at any time
   • provide you with the option to opt out from receiving our communications in every newsletter that we send to you.
   • process your marketing data to comply with our legal obligation and for our legitimate business interests
   We may share your personal information with Zing Cover, a trading name of Covertech Limited, for the purposes of marketing and administration of insurance products, if this is a service requested by you.
2. Subscribers: when you subscribe to our service or publications (i.e. by signing up to receive our newsletter on our website); request marketing to be sent to you; enter a competition, promotion or survey; or give us some feedback we will collect your Identity Data, Contact data and Marketing Data. We will:
   • obtain this information from you;
   • obtain this information for the purpose of notifying you of our products and services and send you our newsletters, to deliver relevant website content and advertisements to you, notify you of our new products and services and measure or understand the effectiveness of the advertising we serve to you;
   • if you are a consumer or obtain this information from your or publicly available sources (i.e. linkedin, Companies House) if you act on behalf of a business or organisation;
   • collect this data as it is necessary for our legitimate interests (to keep in touch with our clients, to study how customers use our services, to develop them and promote them, to grow our business and to improve our marketing strategy).
3. The data collected in accordance to clause 9.1, 9.2 to 9.3 will be share the information we receive with relevant personnel within company, i.e. those responsible for the IT or marketing aspects of the business and third- party service providers responsible for our website maintenance and marketing or software providers, i.e. ConstantContact. You will be able to opt out of receiving any further promotional material from us.

Website Use:

1. When you use our website we may automatically collect Technical Data, User Data and Aggregate data about your equipment, browsing actions and patterns. We collect this data by using cookies, and other similar technologies. We may also receive this data about you if you visit other websites employing our cookies. We will:
   • obtain this information from you or third parties such as analytics providers (eg google), which is based outside the EU;
   • collect this information for the purpose to administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data;
   • collect this data as it is necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise);
   • will share the information we receive with relevant personnel within company, i.e. those responsible for the IT aspect of the business and third-party service providers responsible for our website maintenance;
   • collect this information automatically when you use our website. If you do not wish for this information to be collected, please do not use our website

Change of purpose

1. 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
2. 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.
3. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

1. Your data will be shared routinely with third parties such as:
   • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. 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.
   • Service providers who provide IT and system administration services.
   • Professional advisers including other lawyers, bankers, accountants, auditors and insurers 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.
   • Regulatory bodies.
   • Contractors, employees and consultants.
2. We require third parties to keep your data confidential and secure and to protect it in accordance with the law and our policies. They are only permitted to process your data for the lawful purpose for which it has been shared and in accordance with our instructions.
3. All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
4. We do not send your personal data outside the European Economic Area. If this changes you will be notified of this and the protections, which are in place to protect the security of your data, will be explained.

Disclosure of Customer Data for Advertising Purposes

1. We may share your personal data with third-party service providers, including Google, for the purposes of providing personalised advertising and marketing services on our behalf, as part of our legitimate business interests. This data may be used to match your information with third-party databases to create tailored advertisements and ensure compliance with applicable advertising regulations.
2. Specifically, we share customer data such as email addresses, phone numbers, and other identifying information with Google for use in Customer Match campaigns in accordance with Google's policies. Google acts as a data processor for these services, and your data will only be used to match your information with Google accounts, optimise campaign performance, and comply with Google's advertising policies.
3. We ensure that all third-party service providers treat your personal data securely and in accordance with applicable laws, including the General Data Protection Regulation (GDPR).
4. By completing a transaction with us, you acknowledge that we may process your personal data for these purposes, unless you choose to opt out. If you wish to withdraw your consent or object to this processing, you can do so at any time by contacting us.

Data security

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

Data retention

1. 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.
2. 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.
3. If you would like more information on the data retention periods please contact the data protection manager and request for Data Retention Policy.

Your legal rights

1. Under the legislation you may be entitled to the listed rights in certain circumstances as listed below.
2. Right to be informed. The right to be informed about the collection and use of your personal data.
3. The right to access (Subject Access Request) to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. If you wish to exercise this right:
   1. 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.
   2. 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.
   3. 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.
4. Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected. In certain circumstances we may refuse a request for correction.
5. Request erasure of your personal information. In certain circumstances you have the right to have ask for some but not all of the information we hold and process to be erased (the right to be forgotten). This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
6. Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation, which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
7. Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
8. Request the transfer of your personal information to another party.
9. Rights in relation to automated decision making and profiling: You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
10. If you want to exercise any of the above-mentioned rights please contact Data Protection Manager by telephone or in writing. We will respond to your request within one calendar month.

Automated Decision Making

1. You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.

Cookies

1. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see out Cookie Policy.

Promotions

1. Wheel of Fortune: By providing your email address and accepting this Privacy Policy, you are consenting to having your email address added to our email marketing list. You may unsubscribe from this list at any time by clicking the "unsubscribe" link in any marketing email you have received from us, or by contacting us via any of the contact methods advertised on our site.