Data Protection Registration
Bluebox Finance Ltd is registered with the Information Commissioners Office (ICO) Registration no. ZA781644.
Definitions and interpretation
Collectively all personal data or personal information about an individual from which that person can be identified, either directly or indirectly. This data would include details that you submit to Bluebox Finance Ltd via the Website as well as details that we collect through our email marketing activities. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;
Data Protection Laws
Any applicable law relating to the processing of personal Data and the delivery of marketing by email, including but not limited to the Directive 96/46/EC (Data Protection Directive) or the GDPR, and any national implementing laws, regulations and secondary legislation, for as long as the GDPR is effective in the UK;
The Privacy and Electronic Communications (EC Directive) Regulations 2003, also known as "PECR", is the principal law that covers direct marketing by email.
The General Data Protection Regulation (EU) 2016/679 and The Data Protection Act 2018 ;
Bluebox Finance Ltd (we or us)
Bluebox Finance Ltd, a company incorporated in England and Wales with registered number 12788742 whose registered office is at Woodbury House, Green Lane, Exton, Exeter, Devon, EX3 0PW;
User or you
Any third party that accesses the Website and is not either (i) employed by Bluebox Finance Ltd and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Bluebox Finance Ltd and accessing the Website in connection with the provision of such services;
The website that you are currently using, www.blueboxfinance.co.uk, and any sub-domains of this site unless expressly excluded by their own terms and conditions.
a. the singular includes the plural and vice versa;
c. a reference to a person includes firms, companies, government entities, trusts and partnerships;
d. "including" is understood to mean "including without limitation";
e. reference to any statutory provision includes any modification or amendment of it;
For purposes of the applicable Data Protection Laws, Bluebox Finance Ltd is the "data controller". This means that Bluebox Finance Ltd determines the purposes for which, and the manner in which, your Data is processed.
The information you give to us or we obtain from you may include:
How we collect Data
We collect Data in the following ways:
a. data is given to us by you;
b. data is received from other sources; and
c. data is collected automatically.
We may collect the above information from any of the following categories of people:
Data that is given to us by you
Bluebox Finance Ltd will collect your Data in a number of ways, for example:
a. when you contact us through the Website, by telephone, post, e-mail or through any other means;
b. when you elect to receive marketing communications from us;
c. when you use our services;
Data that is received from publicly available third parties sources
We will receive Data about you from the following publicly available third party sources:
Email Marketing and The Corporate Subscriber
In terms of the PECR, the subscriber is the individual or legal entity that is party to a contract with a provider of public electronic communications services. It specifically defines a corporate subscriber as, essentially, an incorporated company. This is different to the usual meaning of “subscriber” when discussing mailing lists. ICO guidance clarifies that this includes public bodies and Scottish partnerships, but not sole traders or members of an ordinary partnership, as they are not incorporated. In terms of email, the subscriber is held to be the individual or organisation for whom the email service is operated. Any of a corporate subscriber's email addresses would be a corporate email address. If a corporate email address contains a person's name or distinctive job title, it is known as a personal corporate email address. This is not the same as a strictly personal email address pertaining only to a private individual.
Why have you not asked for my consent?
Your email address has been identified as pertaining to a “corporate subscriber” within the meaning of PECR Regulation 2. Regulation 22 prohibits the delivery of unsolicited marketing messages by email to “individual subscribers”, with certain exemptions such as for existing customers. However, this does not apply to corporate subscribers. The UK's data protection supervisory authority, the Information Commissioner's Office or ICO, has published guidance clarifying that consent is not required to email business email addresses. Data protection laws still apply to any personal data being stored or used in relation to that address, such as if your email address contains your name, or a job title through which you could be easily identified. Such personal data is lawfully processed under Art. 6(1)(f) of the GDPR, about which more information is provided below.
Categories of Personal Data
Where a name or job title may be used to identify a living human being ("data subject") in relation to a business email address, the following categories of information directly or indirectly identifying that person may be processed: Name, job title and company, work contact details, records of emails opened with images enabled, records of hyperlinks clicked on in emails, IP addresses used to engage with emails, replies sent to emails, content submitted in forms linked to from emails.
Purposes and Basis of Processing
Personal data is processed for the purpose of targeting and personalising marketing messages and delivering them to the data subject in order to prospectively market products and services of the data controller's clients in pursuit of the commercial interests of both the data controller and its client. The personal data listed above is processed in accordance with Article 6(1)(f) of the GDPR, in pursuit of the legitimate interests detailed in this section. The data controller's and its client's legitimate interests are balanced with the fundamental rights and freedoms of data subjects by the provision of compliant transparency and disclosure notices, a clear, simple and effective means of opting out of further marketing messages, and the appointment of a Data Protection Officer who is available to fulfil any lawful request from a data subject.
How do I stop getting emails from Bluebox Finance?
All emails sent as part of a marketing campaign include an unsubscribe link where you can request that the email used is unsubscribed from further such emails.
Data that is collected automatically
To the extent that you access the Website, we will collect your Data automatically, for example:
Our use of Data
Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:
We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed "Your rights" below).
Legal grounds for processing your personal information
Processing is any activity that involves your personal information. It includes obtaining, recording or holding the information, organising, amending, retrieving, using, disclosing, erasing or destroying it.
We can only process your personal information when the law allows it. Most commonly the legal grounds we will rely on are:
Sharing your personal information
We may share your personal information with carefully selected third party organisations which store and process data on our behalf. These third parties may include IT platforms, suppliers of administrative and support services and suppliers of other specialists products needed for the provision of our financial services.
We may also share your information with other third parties in the course of providing financial services to you, or where we are subject to a legal or regulatory requirement to do so. These third parties may include:
Keeping Data secure
We will use technical and organisational measures to safeguard your Data:
If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: email@example.com
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
You have the following rights in relation to your Data:
To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this email address: firstname.lastname@example.org
If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner's Office (ICO). The ICO's contact details can be found on their website at https://ico.org.uk/.
It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.
Links to other websites
Changes of business ownership and control
We may also disclose Data to a prospective purchaser of our business or any part of it.
In the above instances, we will take steps with the aim of ensuring your privacy is protected.
Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.
You may contact Bluebox Finance Ltd by email at email@example.com
Updated 25th January 2021