PRIVACY POLICY

INTRODUCTION

Bannick LLC is committed to processing your data securely and transparently. This privacy notice sets out the types of data that we collect and hold on you as a contact and/or lead. It also sets out how we use that information, how long we keep it for and other relevant information about your data.

Bannick LLC is aware of its obligations to residents and citizens of the EU under the General Data Protection Regulation (GDPR) and this privacy notice complies with the requirements of GDPR. Bannick LLC is also aware of its obligations to residents and citizens in other jurisdictions including the USA and Canada and this privacy notice complies with the requirements of applicable legislation.

This notice applies to individuals who are:

• Leads – individuals who have inquired regarding our services or individuals who have expressed an interest in Bannick LLC produced content.
• Contacts – individuals who have provided their consent and details to remain in contact with the company e.g. joined our mailing list.

  An individual may be either or both of the above.

DATA PROTECTION PRINCIPLES

In relation to your personal data, we will:

• Process it fairly, lawfully and in a clear, transparent way
• Collect your data only for reasons that we find proper for the course of your enquiry or contact with Bannick LLC in ways that have been explained to you
• Only use it in the way that we have told you about
• Ensure it is correct and up to date
• Keep your data for only as long as we need it
• Process it in a way that ensures it will not be used for anything that you are not aware of or have consented to (as appropriate), lost or destroyed.
  

TYPES OF DATA WE PROCESS

We may hold many types of data about you, including:

• Your personal details including your name, address, e-mail address, phone numbers
•  Job title
•  Job role
• Employer
• Country that you reside in
• Information accessed and downloaded from company websites
• Records of your contact with Bannick LLC

HOW WE COLLECT YOUR DATA

We collect data about you in a variety of ways and we would normally collect the data from you directly. This will usually start when you contact us or talk to us about a business need you or your company has, but can also be when you have provided your details to access and download information from our website, when you have provided your detail to subscribe to receiving e-mails and marketing correspondence from us or shown an interest in specific topics of a marketing campaign. Further information may be collected directly from you as our relationship and correspondence increases.

In addition, data about you may be obtained from other sources including from your colleagues as the person to speak to regarding a business opportunity or need, from publicly available sources or third parties such as LinkedIn, etc. Where this is the case, data that we hold will be limited in nature.

WHY WE PROCESS YOUR DATA

The law on data protection allows us to process your data. For those in the EU, GDPR allows us to process your data for certain reasons which are detailed below. The same reasons are applicable globally:

• Where we have your consent to do so
• In order to perform the contracts that we are party to
• In order for us to carry out our legitimate interests
• In order to carry out legally required duties
• To protect your interests and
• Where something is done in the public interest.

All of the processing carried out by us falls into one or more of the permitted reasons. Generally, we will rely on consent and legitimate interests to process your data.

With your consent, we need to collect your personal data to be able to include you on regular company e-mails and marketing correspondence.

We also collect data so that we can carry out activities which are in the legitimate interests of the Company. We have set these out below:

• Discuss and secure future business opportunities
• Making decisions regarding marketing activities
• Analyze the effectiveness of marketing activities
• Maintaining effective correspondence and relationships
• Ensuring effective business administration

IF YOU DO NOT PROVIDE YOUR DATA TO US

There are no consequences if you do not provide your data to us, other than not being able to contact you if you wish us to do so.

SHARING YOUR DATA

Your data will be shared with colleagues within Bannick LLC where it is necessary for them to undertake their duties. This includes, but not limited to, Business Development who may contact and build relationships with you, Marketing to correspond with you on latest news and thought leadership, Bannick LLC management and administration to oversee company operations.

We may also share your personal data with the below third parties, where they have agreed to process your personal data in line with the GDPR:

• Our professional advisors such as company accountants
• Our suppliers, business partners and sub-contractors; and/or
• With governmental authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if needed for the legal protection of our legitimate interests in compliance with applicable laws.

PROTECTING YOUR DATA

We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such. E.g. backing up our servers, firewalls, access control for personal information, using password protected documents and encryption when transferring sensitive data, hard drive encryption on all laptops, ensuring our IT systems that process personal information are secure to GDPR and other applicable data protection standards.

Where we share your data with third party suppliers, we ensure that the contracts between Bannick LLC and the third party provider that your data will be held securely and in line with GDPR and other data protection requirements. Third parties must implement appropriate technical and organizational measures to ensure the security of your data. Where needed, a separate Non Disclosure Agreement (NDA) is also signed.

HOW LONG WE KEEP YOUR DATA FOR

For all Contacts, we obtain your consent to hold your data and will retain your data indefinitely until you inform us that you no longer wish us to do so (by opting out or unsubscribing), or we become aware that the data has changed and is inaccurate.

For leads, we will retain your data as a legitimate business interest in order to contact you to discuss your needs, if any. If we discuss your needs and there is an opportunity for us to talk further, you will be converted to a potential client depending upon the outcome of the contact with you. If there is no opportunity you will remain as a lead. For residents and citizens of the EU, under GDPR, we will keep your data for 6 months before it is deleted. For leads who are not in the EU, your details will be held indefinitely.

YOUR RIGHTS IN RELATION TO YOUR DATA

GDPR gives EU citizens and residents certain rights in relation to the data we hold. Although not a right for non EU citizens and residents, we extend these privileges to all. These are:

• The right to be informed. This means that we must tell you how we use your data, and this is the purpose of this privacy notice
• The right of access. You have the right to access the data that we hold on you. To do so, you should make a subject access request.
• The right for any inaccuracies to be corrected. If any data that we hold about you is incomplete or inaccurate, you are able to require us to correct it
• The right to have information deleted. If you would like us to stop processing your data, you have the right to ask us to delete it from our systems where you believe there is no reason for us to continue processing it
• The right to restrict the processing of the data. For example, if you believe the data we hold is incorrect, we will stop processing the data (whilst still holding it) until we have ensured that the data is correct
• The right to portability. You may transfer the data that we hold on you for your own purposes
• The right to object to the inclusion of any information. You have the right to object to the way we use your data where we are using it for our legitimate interests
• The right to regulate any automated decision-making and profiling of personal data. You have a right not to be subject to automated decision making in way that adversely affects your legal rights.

Where you have provided consent to our use of your data, you also have the unrestricted right to withdraw that consent at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate reason for doing so.

If you wish to exercise any of the rights explained above, please contact the Data Protection Officers listed above.

MAKING A COMPLAINT

If you think your data protection rights have been breached in any way by us, you should contact our Data Protection Officer at jim.webb@bannickprimary.com. If you think your data protection rights under GDPR have been breached in any way by us, you are able to make a complaint to a supervisory authority.

CHANGES TO THE RULES ON PRIVACY