BEX Bridge Ltd Privacy Policy
Effective date: 14.09.2023
INTRODUCTION
This privacy policy outlines how BEX Bridge Ltd manages the personal data of users engaging with our websites and services. It also educates users on their rights and protections under the law. Every user should review this policy to understand the manner and reasons behind the usage of their data within BEX Bridge Ltd's platform. For any questions or to exercise privacy rights, the instructions within this policy can be followed, and the BEX Bridge Ltd team is at your disposal.
DATA CONTROLLER
Your personal data is managed by BEX Bridge Ltd with its main office located 27C Redcliffe Gardens, SW10 9BH London, England. Reach out to us at: hello@bexbridge.com
STATEMENT ON CHILDREN'S PRIVACY
BEX Bridge Ltd's websites and services are primarily directed towards adults and aren't intended for children under 16 years. We do not intentionally gather data about children.
DATA BEING COLLECTED
BEX Bridge Ltd collects various data categories about its users, either provided directly, through the usage of our services, or from other sources:
Identification Data: Name, platform, username on that platform, and profession. For social media interactions, the username is also collected. If you engage in a contract regarding advertising space and aim to withdraw money, Identification Data might also cover your age (for legal capacity verification) and Tax number (if partnering as a business).
Minors or those without full legal capacity will also need to provide the name and email of their legal guardian for contract validation.
Contact Data: Name, username, and email address. If you're subscribing to newsletters or promotional content, only the subscription form data (name and email) is relevant.
Those entering into advertising space contracts might also need to share their physical address (for taxation). Minors or those lacking full legal capacity also need to share their guardian's contact data.
Image Data: Pictures of individuals who have an agreement with BEX Bridge Ltd for advertising purposes.
Financial Data: Bank account details. For minors or those without full legal capacity, this refers to the bank account specified by their legal guardian.
Technical Data: IP address, browser type and version, time zone settings, browser plugin types and versions, operating system, and other relevant technological data used to access our platform.
User Data: Information related to how the website or services are used.
Tracking Data: Information gathered via cookies and similar technologies about user behavior.
Recruitment Data: Details like name, date of birth, contact information, education, professional skills, and employment history.
BEX Bridge Ltd may also gather and utilize Aggregated Data, which are non-personal statistical or demographic data. However, if these data are combined with identifiable information, they're treated as personal data.
BEX Bridge Ltd does not collect sensitive personal data, such as race, religion, political beliefs, health data, or biometrics. Not providing certain data may limit the services we can offer. While users' consent is significant, BEX Bridge Ltd may also use other legal bases for data processing.
MANNER OF DATA COLLECTION
Direct Interactions: Users provide data directly to BEX when registering, contacting by email, phone or through social media, or during performance of a contract. We collect Identification, Contact, Image, Financial, and Recruitment data in this way.
Automated Activities: Data is collected automatically during interactions with BEX, including via cookies and analytic tools. We gather Technical, User, and Tracking data through this method. Our automated tools include Google Analytics and Hotjar.
From Third Parties: We obtain data from third-party entities, including those offering tracking services, statistical services, and login solutions like Google Sign-In, when they have legal grounds. This often means user consent. We gather Technical, User, Tracking, Financial (from payment operators), Identification, and Contact data through this method. Data can also be acquired via APIs in partner portals.
MANNER OF USE OF DATA
The way BEX uses data is contingent on its purpose:
Fulfillment or initiation of a contract: e.g., user advertising space lease.
BEX's legitimate interests or those of a third party, unless overridden by user interests: e.g., fraud suspicion.
Compliance with legal obligations: e.g., tax settlement.
And more broadly, BEX uses data for:
a. Electronic services delivery and contract performance; b. Other services provision; c. Handling of inquiries, requests, and orders; d. Marketing (of own products); e. Analysis and website improvement; f. Development, repair, or functionality testing; g. Recruitment.
LEGAL BASIS FOR DATA COLLECTION. RETENTION
BEX verifies the data it holds regularly and checks the validity of its processing basis.
Performance of a contract: Data is held for the contract's duration.
Direct marketing: Data retained as long as BEX has a legitimate interest.
Newsletter: Held until the user withdraws consent.
Accounting: Data retained as required by UK accounting regulations.
Inquiry response: Held for the period required to respond.
Claims: Held as defined by the UK's statute of limitations.
Security and fraud prevention: Data held as defined by UK law.
Recruitment: Retained for the recruitment process duration.
THE RIGHTS OF DATA SUBJECTS
Users (data subjects) have rights including:
Access, Rectification, Limitation, Erasure, Portability: Users can request access, rectification, erasure, processing limitation, and data portability.
Consent Withdrawal: If processing is based on consent, it can be withdrawn.
Complaint to Supervisory Authority: Users can lodge complaints with the UK's Information Commissioner's Office.
Right to Object: Users can object to processing based on legitimate interests.
Direct Marketing Objection: Users can object to data processing for direct marketing.
To exercise these rights, contact BEX using the provided contact details.
PROFILING
BEX Bridge Ltd does not perform profiling.
DATA PROVISION
As a rule, data collected by BEX are not shared with third parties. However, BEX may:
a. share data of persons who have concluded a contract with BEX (lease of advertising space) with advertisers at the stage of their deciding about cooperation with BEX, as well as information about the implemented campaigns;
b. share data of persons who have used the services of BEX with entities supporting BEX in the provision of services, such as payment processors or providers of analytic tools (e.g. Google Analytics, Google Workspace);
c. provide data to law enforcement authorities, supervisory bodies, entities performing public tasks or other entities, if the obligation to provide data results from the legal provisions.
The provision of data must always be performed based on the legal provision or the relevant contract (outsourcing of personal data processing).
Data may be shared outside the European Economic Area, whereby BEX ensures that adequate security measures are provided. In particular, BEX concludes the relevant contracts (standard contractual clauses) in order to secure personal data being transmitted, and provides data to those countries for which the European Commission has issued a decision acknowledging the appropriate level of protection.
SOCIAL MEDIA
The liability for collecting and further processing of personal data of the user at social media portals shall be borne by the entity providing the portal. The owner of such a portal shall collect information, including personal data, in relation to the user’s visits to the portal (also visits without registration).
BEX is only the operator of the website or account created as part of the social media portal, and the scope of data collected by BEX in this way is limited. In addition, in the case of some social media portals (for instance, Meta/Facebook), the scope of data to which BEX may gain access is determined by the settings of the account user.
Social media additionally provide BEX with Aggregated Data that are not personal data. All other data obtained by BEX come from direct interactions with BEX (e.g. replying to threads, posting queries) that we describe in this Privacy Policy. Such data are processed in accordance with the relevant legal basis set forth in this Privacy Policy.
The user is not obliged to provide BEX with personal data, but the entity providing a given portal may condition the operation of a specific portal function on the provision of such data (e.g. sending a private message always involves the provision of user data, that is account name).
Within the above-mentioned scope the user has certain rights, as described in this Privacy Policy.
At BEX websites, you can find the so-called social media plugins that direct you to social media portals. Their basic function is to redirect you to the relevant resources of the social media portal (for instance, BEX social media pages page at Linkedin). What is more, such plugins may provide information about visits to the BEX website directly to the entity providing a given social media portal. It only happens when the visitor to the BEX website is also logged in at the portal