Privacy Policy

Privacy Policy

Introduction

We respect your privacy and are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website and tell you about your privacy rights and how the law protects you.

Data Controller

CBO Projects is the controller and responsible for your personal data (collectively referred to as “CBO”, “we”, “us” or “our” in this privacy notice).

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please use the contact details set out below.

Contact details

Our full details are:

Full name of legal entity: CBO Projects Limited

Email address: dataprotection@cboprojects.com

Postal address: 5 Smith Street, St Peter Port, Guernsey, GY1 2JN

Telephone number: 01481 729161

You have the right to make a complaint at any time to The Office of the Data Protection Commissioner, the Guernsey supervisory authority for data protection issues (www.odpc.gg). We would, however, appreciate the chance to deal with your concerns before you approach the ODPC so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 25th May 2018.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website does not contain links to third-party websites, plug-ins and applications.

Our principles

We aim to protect any personal data we hold, to manage your personal data in a responsible way and to be transparent in our practices. We are committed to the following principles:

  • You have no obligation to provide any personal data requested by us. However, if you choose not to, we may not be able to provide you with our services.
  • We only collect and process your data for the purposes set out in this Privacy Policy or for specific purposes that we share with you and/or that you have consented to.
  • We aim to collect, process and use the minimum amount of personal data as possible.
  • When we do collect your personal data, we aim to keep it as accurate and up to date as possible.
  • If the personal data we collect is no longer needed for any purposes and we are not required by law to retain it, we will do what we can to delete, destroy or permanently de-identify it through anonymisation or pseudonymisation.
  • Your personal data will not be shared, sold, rented or disclosed other than as described in this Privacy Policy.

What personal data do we collect?

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 when you apply for a role as a prospective candidate and/or engage us for services such as:

  • Identity Data including first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data including billing address, delivery address, email address and telephone numbers.
  • Transaction Data including details about payments to and from you and other details of services you have purchased from us.
  • Technical Data including internet protocol (IP) address, login details, 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. This information is collected and tracked via Google Analytics, not stored on cboprojects.com website.
  • Usage Data includes information about how you use our website.
  • Marketing and Communications Data includes your preferences in receiving marketing from us.

We do not collect any Special Categories of Personal Data about you (this includes 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). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

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 (for example, to provide you with goods or services).

How is your personal data collected?

We use different methods to collect data from and about you including through:

  • 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. This includes personal data you provide when you:
    – engage with us to provide services;
    – submit your details to us to apply for a position; or
    – request marketing to be sent to you;
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns.
  • Third parties or publicly available sources. We may receive personal data about you from analytics providers such as Google based outside the EU.

Why do we collect and use your personal data?

We will only use your personal data when the law allows us to so we can provide you with the best possible service. 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;
  • 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. You have the right to withdraw consent to marketing at any time by contacting us.

When we collect and use your personal data for purposes mentioned above or for other purposes, we will inform you before or at the time of collection.

Purposes for which we will use your personal data

We have set out below 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.

  • To register you as a new customer
  • To process and deliver services to you
  • To manage our relationship with you
  • To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
  • To deliver relevant website content to you and measure or understand the effectiveness of the marketing communications we send to you

Marketing

We aim to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Promotional content from us

You will receive marketing communications from us if you have requested information from us or services from us.

Opting out

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

International transfers

We do not transfer your personal data outside the European Economic Area (EEA).

Data security

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 – How long will you use my personal data for?

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 regulatory, legal, accounting, or reporting requirements.

Your rights

Where we process your personal data, you are entitled to a number of rights and can exercise these rights at any point. We have provided an overview of these rights below together with what this entails for you. You can exercise your rights via our contact page.

The right to access your personal data and correction

You have the right to request access to your personal data (commonly known as a ‘data subject access request’). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. You also have the right to request correction of the personal data we hold about you. This 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 you provide to us. Should you want to exercise your rights, please contact us via our contact page.

The right to data portability

Your personal data is portable. This means it can be moved, copied or transmitted electronically. However, this right only applies where:

  1. the processing is based on your consent;
  2. the processing takes place for the performance of a contract;
  3. the processing takes place by automated means;

If you wish to exercise your right to data portability, please contact us via our contact page.

The right to erasure of your personal data

You have right to request that we erase your data if:

  1. your personal data is no longer necessary in relation to the purposes for which we collected it; or
  2. you withdraw the consent that you had previously given us to process your personal data, and there is no other legal ground to process that personal data; or
  3. you object to us processing your personal data for direct marketing purposes; or
  4. the personal data is not being processed lawfully; or
  5. your personal data needs to be deleted to comply with the law.

If you wish to delete the personal data we hold about you, please let us know and we will take reasonable steps to respond to your request in accordance with legal requirements. 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.

If the personal data we collect is no longer needed for any purposes and we are not required by law to retain it, we will do what we can to delete, destroy or permanently de-identify it.

The right to restriction of processing

You have the right to restrict the processing of your personal data if:

  1. you do not believe the personal data we have about you is accurate; or
  2. the personal data is not being processed lawfully, but instead of deleting the personal data, you would prefer us to restrict processing instead; or
  3. we no longer need your personal data for the purposes we collected it, but you require the data in order to establish, exercise or defend legal claims; or
  4. you have objected to the processing of your personal data and are awaiting verification on whether your interests related to that objection outweigh the legitimate grounds for processing your data.

If you wish to restrict our processing of your personal data, please let us know and we will take reasonable steps to respond to your request in accordance with legal requirements.

The right to object

You have the right to object to the processing of your personal data at any time where we 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

The right to lodge a complaint with a supervisory authority

You have the right to lodge a complaint directly with supervisory authority about how we process personal data.

The right to withdraw consent at any time

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 services to you. We will advise you if this is the case at the time you withdraw your consent.

How to contact us

If you have any questions, comments or complaints regarding this Privacy Policy or the processing of your personal data, please contact us via our contact page.