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Privacy and cookies

Introduction
BJUI International ("BJUI", "we" and "us") are committed to protecting the privacy of those with whom we interact and we recognise the need to respect and protect information that is collected or disclosed to us (called "Personal Information", explained below).

This Privacy Notice is intended to tell you how we use your Personal Information, and we've tried to explain what we do in enough detail to give you the information you need at a glance, with the option of following a link if you want to find out more. If you still can't find the information you need, you can email us at support@bjuiknowledge.org.

The Privacy Notice applies to BJUI products and websites that refer to or link to the Privacy Notice (collectively, our “Services”) and will apply whether you access our Services using a computer, mobile phone, tablet, TV, or other device.

1. Who are we
We are the data controller of the Personal Information (explained below) that we collect about you. We have a current registration (number Z2302931) in the Data Protection Register and we have appointed a Data Protection Manager who is responsible for overseeing questions in relation to this Privacy Notice. If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact the Data Protection Manager using the details set out below.

Contact details
Our full details are:     
BJU International
A private company limited by guarantee without share capital
Company Number 01793312

Name or title Data Protection Manager: Nicola Quinnen                         
Email address:   nicola.quinnen@bjui.info  
Postal address:  3 Junction Mews, London, W2 1PN

2. What is Personal Information and what Personal Information does BJUI collect about you?
For the purposes of this Privacy Notice "Personal Information" consists of any information that relates to you and/or information from which you can be identified, directly or indirectly. For example, information which identifies you may consist of your name, address, telephone number, photographs, location data, an online identifier (e.g. cookies identifiers and your IP address) or to one or more factors specific to your physical, economic, cultural or social identity. When we combine other information (i.e. information that does not, on its own, identify you) with Personal Information, we treat the combined information as Personal Information.

We may collect use, store and transfer different kinds of Personal Information about you which we have grouped together as follows:

  • Identity Data includes first name, last name and title.
  • Contact Data includes address, email address and telephone number.
  • Technical Data includes internet protocol (IP) addresses, the type of browser used while visiting our website and the numbers of users who visit our website.
  • Usage Data includes usage session dates and duration, page views, and how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

3. How is your Personal Information collected?
BJUI collects information when a user visits our website, when a customer purchases our services and products, and when a customer contacts us whether by the telephone, email or post. We use different methods to collect data from and about you including:

I. Personal Information you provide directly. You may give us your Identity, Contact and Marketing and Communications Data by filling in forms or by corresponding with us by email, phone or otherwise. This includes Personal Information that you provide when you:

  • Purchase any of our services or products,
  • Voluntarily participate in interactive features of our service; or
  • Otherwise interact with us.

II. Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data and Usage Data about your equipment, browsing actions and patterns. We collect this Personal Information by using cookies and other similar technologies. Please see section 10 below.

III. Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources set out below

  • Technical Data from third party analytics providers, such as Google Analytics.
  • Identity and Contact Data from publicly available sources.

4. How do we use your information?
We may use the Personal Information that we collect for the following purposes:

I. Deliver our Products and Services - as well as to administer systems and accounts and allow you to participate in interactive features of our service when you choose to do so;

II. Analysis Purposes - for assessment and analysis of our market, customers, products, and other Services, and to create sales, marketing and promotional plans;

III. Statistical Purposes – for research, statistical and behavioral analysis;

IV. Services and Website Improvement – to enhance our products and services, to ensure content from our website is presented in the most effective manner for you and your computer, to enhance the user experience, and to develop new products;

V. Customer Support Services - to provide customer support services;

VI. Business Purposes - for business monitoring and internal record keeping including maintaining our accounts, complying with good practice and for other administrative, operational and security reasons;

VII. Legal Obligations - to comply with our legal and regulatory obligations;and

VIII. Updates - to communicate with you, including communicating with you about your transactions with us, giving you important information about your products, sending you notices about any material changes to our Privacy Notice, and, where permitted by you and applicable laws, marketing, sending you offers and promotions for our products.

The law allows us to use the Personal Information as set out above on the basis that the processing is necessary for the performance of a contract with you, or we are acting in our "legitimate interests" in the promotion and efficient running of our business.

Marketing communications
BJUI may use your Personal Information to provide you with email notifications and other communications by email, on the basis that we obtain your consent to use your Personal Information for these purposes. For further information on this, see the 'Your Choices' section of this Privacy Notice.

Personal Information
We may combine the Personal Information that we collect from you (including information received from our affiliates) to the extent permitted by applicable law. For example, we may combine various different databases that contain your Personal Information to allow us to provide better support services and more personalised content (such as, marketing).     

5. To whom do we disclose your information?    
We will only use your Personal Information for our internal business purposes, some of which are mentioned above. We may disclose your information to the following entities:

I. BJUI Affiliates
We may need to transfer your Personal Information to other BJUI affiliates (as defined in section 1159 of the Companies Act 2006) to provide the products you require or any other services/assistance you request. All BJUI affiliates are required to follow the privacy practices set forth in this Privacy Notice, or such other privacy notice that they may notify to you.

II. Service Providers
We use third party service providers to help us to administer certain activities and services on our behalf, such as hosting our website and providing software in order for us to deliver our Services, facilitating payments made by you for our Services and analysing usage of our Services. We may share Personal Information about you with such third party service providers solely for the purpose of enabling them to perform services on our behalf and they will operate only in accordance with our instructions. Here are examples of third-party service providers we use:

a. IT Service Provider – our website and subscription system is hosted by Bright Interactive Ltd. Bright Interactive Ltd may transfer Personal Information outside of the EEA but only on our consent and provided that all such transfers are protected by appropriate safeguards in accordance with applicable data protection laws.
b. Software Providers – software providers are used to assist us in providing you with our Services. The software providers we currently use are Brightwave Ltd and Elucidat Ltd. Brightwave host the "Tessello" platform which stores our learning content, tracks your participation in our learning content and enables you to log your CPD activities. Elucidat assist us in analysing your usage of our interactive learning content including when you access a module, your progress through a module and your attempts at and success of final assessments.
c. Payment Provider – we use Braintree Payments, a subsidiary of PayPal, to facilitate payments made by you for our products. All payments processed by Braintree use computer safeguards such as firewalls and data encryption.
d. Analytics Service Providers – analytics providers are used to assist us in understanding the usage of our products/devices and other Services and to enable us to improve our Services. The analytics provider we currently use is Google Analytics. For further information see section 10 below.

III. Anonymous statistics
We prepare and develop anonymous, aggregate or generic data and statistics for various reasons (such as aggregate usage statistics including "page views" on our website, and analysing how users use our content). As this data is anonymous (i.e. you cannot be identified from it) we do not consider this information to be Personal Information. As such, we may share it with any third party (such as our affiliates, partners, advertisers or otherwise).

IV. Third parties when required by Law or to Protect our Services
We will disclose your Personal Information to comply with applicable law or respond to valid legal process, including from our regulators, law enforcement or other government agencies; to protect our customers (e.g. to prevent spam or attempts to defraud users of our products); to operate and maintain the security of our products (e.g. to prevent or stop an attack on our systems or networks); or to protect the rights or property of BJUI, including enforcing any terms or agreements governing the use of our products.

V. Other Parties in Connection with Corporate Transactions
We may disclose your Personal Information to a third party (or other BJUI affiliate) in the event that all or substantially all of our business or assets are or are intended to be sold or otherwise assigned to another entity.

VI. Other Parties At Your Direction
We may share Personal Information about you with third parties when you request such sharing.

6. What do we do to keep your information secure?
We have put in place appropriate physical and technical measures to safeguard the Personal Information that we collect in connection with our products. In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Information on our instructions and they are subject to a duty of confidentiality. However, please note that although we take appropriate steps to protect your Personal Information, no website, product, device, online application or transmission of data, computer system or wireless connection is completely secure and therefore we cannot guarantee the security of your Personal Information.

International Transfer of Data
The Personal Information that we collect from you may be stored and processed in your region, or transferred to, stored at or otherwise processed outside the European Economic Area ("EEA"), including but not limited to the United States of America or in any other country where BJUI or BJUI affiliates or service providers maintain facilities.

By using or participating in any Service and/or providing us with your Personal Information, you acknowledge that we will collect, transfer, store and process your information outside the EEA. We will take all steps reasonably necessary to ensure that your Personal Information is kept secure and treated in accordance with this Privacy Notice and the requirements of applicable law wherever the data is located.

Where we transfer your Personal Information outside the EEA to other third parties, we will ensure that appropriate transfer agreements and mechanisms, such as the EU Standard Contractual Clauses, are in place to help ensure that our third party service providers provide an adequate level of protection to your Personal Information. We will only transfer your Personal Information outside the EEA in accordance with applicable laws or where you have given us your consent to do so.

7. Data Retention - How long we will store/keep your Personal Information
When your subscription (whether an individual subscription or a subscription via your organisation) ends we retain your Personal Information (including your CPD records) for up to six months in order to allow you to renew your subscription effectively if you choose to do so. BJUI retains Personal Information for as long as necessary to fulfil the purposes for which your Personal Information has been collected as outlined in this Privacy Notice unless a longer retention period is required by law. When your Personal Information is no longer required for the purpose it was collected or as required by applicable law, it will be deleted and/or returned to you in accordance with applicable law.

8. Accessing your Personal Information and other rights you have
BJUI will collect, store and process your Personal Information in accordance with your rights under any applicable data protection laws. Under certain circumstances, you have the following rights in relation to your Personal Information:

I. Subject Access - you have the right to request details of the Personal Information which we hold about you and copies of such Personal Information.

II. Right to Withdraw Consent – where you have consented to our processing of your Personal Information, you have the right to withdraw such consent at any time.  In the event you wish to withdraw your consent to processing, please contact us using the details provided in section 13.

III. Data Portability – you may, in certain circumstances, request us to port (i.e. transmit) your Personal Information directly to another organisation.

IV. Rectification – we want to ensure that the Personal Information about you that we hold is accurate and up to date. If you think that any information we have about you is incorrect or incomplete, please let us know. To the extent required by applicable laws, we will rectify or update any incorrect or inaccurate Personal Information about you.

V. Erasure ('right to be forgotten') - you have the right to have your Personal Information 'erased' in certain specified situations.

VI. Restriction of processing – you have the right in certain specified situations to require us to stop processing your Personal Information.

VII.
Object to processing – You have the right to object to specific types of processing of your Personal Information, such as, where we are processing your Personal Information for the purposes of direct marketing.

VII. 
Prevent automated decision-taking – in certain circumstances, you have the right not to be subject to decision being taken solely on the basis of automated processing.

Enforcing your rights
If you wish to enforce any of your rights under applicable data protection laws, then please see section 13 below. We will respond to your request without undue delay and by no later than one month from receipt of any such request, unless a longer period is permitted by applicable data protection laws, and we may charge a reasonable fee for dealing with your request which we will notify to you. Please note that we will only charge a fee where we are permitted to do so by applicable data protection laws.

Complaints
If you are concerned that we have not complied with your legal rights under applicable data protection laws, you may contact the Information Commissioner's Office (www.ico.org.uk) which is the data protection regulator in the UK which is where BJU International is located. Alternatively, if you are based outside the UK, you may contact your local data protection supervisory authority.

9. Third-Party Links and Products on Our Services
Our websites and products may contain links to other third party websites that are not operated by BJUI. These linked sites and applications are not under BJUI's control and as such, we are not responsible for the privacy practices or the content of any linked websites and online applications. If you choose to use any third party websites, any Personal Information collected by the third party’s website will be controlled by the Privacy Notice of that third party. We strongly recommend that you take the time to review the privacy policies of any third parties to which you provide Personal Information.

10. Cookies
What are cookies?
We may use cookies on our website. Cookies are small text files that can be read by a web server in the domain that put the cookie on your hard drive. Cookies are assigned to and stored in a user's internet browser on a temporary (for the duration of the online session only) or persistent basis (cookie stays on the computer after the internet browser or device has been closed). Cookies collect and store information about a user’s preferences, product usage and content viewed which allows for us to provide users with an enhanced and customized experience when engaging with our website.

The website bjuiknowledge.org is provided by our third party suppliers, Brightwave Limited ("Brightwave") and Bright Interactive Limited ("Bright Interactive"). Brightwave and Bright Interactive use several different types of cookies to make bjuiknowledge.org work.

I. Functional Cookies. These cookies are used to enable core site functionality. Brightwave uses functional cookies to track the identity of the user's session, and to automatically log the user back into the bjuiknowledge.org if they choose the "keep me logged in" option on the login screen.

II. Analytic Cookies. Bright Interactive uses these cookies to count page visits and traffic sources (provided by Google Analytics) so we can measure and improve the performance of bjuiknowledge.org.

III. Third Party Cookies. bjuiknowledge.org has functionality provided by YouTube embedded videos. As such when you use pages with these elements you are actually opening a window on the page from YouTube, which may use cookies. YouTube provides information on privacy on its website.

11. Your Choices (e.g. marketing-related emails or otherwise)
When you purchase our products, request information on our website, or otherwise communicate with us, we and other BJUI affiliates may use your Personal Information (such as your contact details (e.g. name, address, email address, telephone number)) to send you marketing-related correspondence by email related to our products. When we process your Personal Information for marketing purposes, we do so on the basis that we have obtained your consent to use your Personal Information for these purposes.

We may also use your Personal Information to personalise and to target more effectively our marketing communications to ensure, to the extent possible, that any marketing-related correspondence is relevant to you.

To opt out of receiving marketing-related correspondence from BJUI, please click "Unsubscribe" from any marketing or promotional email you receive from us.

12. Changes to this Privacy Notice
It also is important that you check back often for updates to the Privacy Notice, as we may change this Privacy Notice from time to time. The “Date last updated” legend at the bottom of this page states when the notice was last updated and any changes will become effective upon our posting of the revised Privacy Notice.

We will provide notice to you if these changes are material and, where required by applicable law, we will seek your consent. We will provide this notice by email or by posting notice of the changes on the BJUI website or through any relevant Services.

13. Contact Us / Further Information
If you have any questions regarding the collection, processing, or use of your Personal Information or if you wish to correct, block, rectify, object, access, revoke your consent to any applicable aspect of this Privacy Notice or delete any of your Personal Information, please contact us:

I. By mail:
Data Protection Manager
BJU International
3 Junction Mews
London
W2 1PN
England

II. By email:
nicola.quinnen@bjui.info 

III. By telephone: +44 (0) 207 706 0178 - 10.00 - 16.00 GMT, Monday to Friday

 

Date last updated: 23 May 2018

© BJUI 2018

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