Please note that this Site is not intended for children, and Bench City does not knowingly collect data relating to children. If you are a minor (an individual under 18 years of age), you may not register with or use this Site. If you think that we may have unintentionally collected data relating to a child, please contact us using our contact form, or by emailing us at email@example.com.
WHO WE ARE
INFORMATION WE COLLECT
Personal data means any data or information about an individual from which that person can be identified. It does not include data where your identity has been removed (anonymous data).
We may collect, use, store, and transfer different types of personal data about you as follows:
• Identity information, including your first name, last name, title, gender, birth date and job title.
• Contact information, including your postal address, email address(es) and telephone numbers.
• Marketing and communications information, including your preferences in receiving marketing from us, and your communication preferences.
• Profile information, including your username and password, preferences, feedback and survey responses.
• Technical information, including your internet protocol (IP) address, 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 this Site.
• Usage information, including information about the types of service we provide you, your payment history, including manner of payment, amount of payments, dates of payments, credit card and bank account details, and other information about how you use our Site.
We may use the above personal data to form a view on what we think you may want or need, or what may be of interest to you.
You will receive marketing communications from us if you have requested information from us or purchased services from us, or if you have provided us with your details when you entered a survey or registered for an event or a promotion, and, in each case, you have not opted out of receiving that marketing.
Please note that where you opt out of receiving marketing messages, this will not delete other personal data we hold on you.
Financial information is only used to bill you for the products and services you purchase. This information may be forwarded to the financial institution associated with your payment method.
We do not collect personal data about you other than the information which you voluntarily provide to us through this Site to fulfill the purpose of your request such as to subscribe to a newsletter.
We do not collect any Special Categories of Personal Data about you, including 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 or any information about criminal convictions and offences.
HOW WE COLLECT YOUR PERSONAL DATA
We use different methods to collect data from and about you, including:
• Direct interactions. You may give us your Identity, Contact, and Marketing and Communications Data by filling in forms, or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• Fill in a form on this Site.
• Create an account on our Site.
• Subscribe to any publications.
• Request marketing be sent to you.
• When you give us feedback.
Cookies may be used to enable the personalization features of our Site. This is so your browser can recall recently viewed pages, and have information that you have previously provided be filled in automatically, instead of having to fill in registration questionnaires every time. Also, cookies may be used to compile anonymous aggregate data that allow us to determine how visitors use our Site and help us improve our offerings on our Site.
The following links provide information on managing cookies on popular web browsers:
To find out more about cookies in general, visit the following website: http://www.allaboutcookies.org
• Third party analytics providers. We receive technical data (standard internet log information and details of visitor behavior) from Google Analytics about visitors to this Site. This information does not identify anyone. To opt out of being tracked by Google Analytics across all websites, visit the following website: http://tools.google.com/dlpage/gaoptout
HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to, and to understand your needs and provide you with better services. Most commonly, we will use your personal data for the following reasons:
• Internal record keeping.
• Improving our products and services.
• Customizing the website according to your interests.
• Sending promotional emails periodically about new products and services, special offers, or other information we think you may find interesting.
• Contacting you my email, phone, fax, or mail for market research purposes.
• 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.
• Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data, other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us using our contact form, or by emailing us at firstname.lastname@example.org.
Below, we have set out 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. We have also identified what our legitimate interests are where appropriate.
Please 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 utilized to process your personal data where more than one ground has been set out in the following:
Purpose/Activity: To register you as a new customer
Type of data: (a) Identity (b) Contact
Lawful basis for processing and legitimate interest: Performance of a contract with you
Type of data: (a) Identity (b) Contact (c) Profile (d) Marketing and Communications
Lawful basis for processing and legitimate interest: (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 customers use our products/services)
Purpose/Activity: To enable you to complete a survey
Type of data: (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications
Lawful basis for processing and legitimate interest: Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
Purpose/Activity: To administer and protect our business and this Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Type of data: (a) Identity (b) Contact (c) Technical
Lawful basis for processing and legitimate interest: (a) 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 reorganization or group restructuring exercise) (b) Necessary to comply with a legal obligation
Purpose/Activity: To deliver relevant website content to you and measure or understand the effectiveness of the same
Type of data: (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical
Lawful basis for processing and legitimate interest: Necessary for our legitimate interests (to study how customers use our website and/or products/services, to develop them, to grow our business and to inform our marketing strategy)
Purpose/Activity: To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Type of data: (a) Technical (b) Usage
Lawful basis for processing and legitimate interest: Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
Purpose/Activity: To make suggestions and recommendations to you about goods or services that may be of interest to you
Type of data: (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile
Lawful basis for processing and legitimate interest: Necessary for our legitimate interests (to develop our products/services and grow our business)
DISCLOSURES OF YOUR PERSONAL DATA
For the purposes set out in the table above, we may have to share your personal data with the parties set out below:
• Internal third parties as set out in the Glossary.
• External third parties as set out in the Glossary.
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.
Bench City has implemented global privacy practices for processing personal data protected under various data protection laws. Bench City transfers personal data between the countries in which we operate in accordance with the standards and conditions of applicable data privacy laws, including standards and conditions related to security and processing.
If you reside outside of the European Economic Area (EEA) or Switzerland, by providing your personal data, you consent to the sharing of your personal data as described above and any resulting cross-border transfers.
Transferring data between internal third parties or to external third parties may involve transferring your data outside the EEA or Switzerland.
Whenever we transfer your personal data out of the EEA, whether to Bench City or to external third parties, we ensure a similar degree of protection is afforded to it by ensuring at least 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. For further details, see: European Commission: Adequacy of the protection of personal data in non-EU countries
• 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 Europe. For further details, see: European Commission: Model contracts for the transfer of personal data to third countries
Bench City uses technical security measures to prevent the loss, misuse, alternation or unauthorized disclosure of information under our control. Bench City uses security measures including and not limited to: physical, electronic and managerial procedures to safeguard and secure the information we collect online. All sensitive information is collected on a secure server. When we ask customers or users to provide financial information (such as a credit card number) that data is protected using Secure Sockets Layer ("SSL") technology.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized 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 procedures in place 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.
INFORMATION COLLECTED BY THIRD PARTY SITES
Like many other commercial websites, our site contains links to other sites whose information collection practices may be different from ours. Users should consult the other sites’ privacy policies, as we do not have any control over any information that may be submitted to, or collected by, such third parties.
Although we employ security measures to prevent unauthorized access to information we collect online, we cannot guarantee the privacy of personal data you transmit over the web, or that may be collected in transit by third parties, including any consultants that provide services to us.
HOW LONG WE RETAIN YOUR PERSONAL DATA
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 unauthorized 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.
YOUR LEGAL RIGHTS
Under certain circumstances, and depending on your location, you have rights under applicable data protection laws in relation to your personal data. Bench City will respect your rights regardless of from where you are visiting this Site. The following descriptions provide you with more information about these rights if you are a European Union citizen:
• Request access to your personal data. This right enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing such personal data. In order to comply with your request, we may ask you to verify your identity.
• Request correction of your personal data. This right enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data that you provide to us.
• Request erasure of your personal data. This right enables you to ask us to delete or remove personal data where there is no good reason for us to continue processing it or where applicable law requires erasure. Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data. If there is something about your particular circumstance that makes you want to object to processing on this ground as you feel it adversely affects your fundamental rights and freedoms, please contact us. In some instances, we may demonstrate that we have compelling legitimate grounds to process your information, which override your rights and freedoms.
• Request restriction of processing your personal data. This right enables you to ask us to suspend the processing of your personal data in the following scenarios:
• You want us to establish the data’s accuracy.
• Our use of the data is unlawful, but you do not want us to erase it.
• You need us to hold the data even if we no longer require it, as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
• Request transfer of your personal data. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Right to withdraw consent. You have the right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
PROCESS FOR RESPONDING
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.
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.
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.
GLOSSARY OF TERMS
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.
External third parties means:
• Service providers acting as processors who provide IT and system administration services.
• Professional advisers acting as processors or joint controllers, including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• Regulators, including data protection supervisory authorities and other authorities acting as processors or joint controllers based in the United Kingdom and/or EEA who require reporting of processing activities in certain circumstances.
If you are a European Union citizen, you have the right to make a complaint at any time to a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement. In the UK the supervisory authority is the Information Commissioner’s Office (ICO) (http://www.ico.org.uk/). We would, however, appreciate the chance to deal with your concerns before you approach the ICO or your local supervisory authority, so please contact us first.
Last updated: May 9, 2020