Privacy Policy

Bespin Labs Limited hold the privacy of your personal information in the highest regard. We recognise the importance of protecting your privacy and our policy is designed to assist you in understanding how we collect, use and safeguard the personal information you provide to us and to assist you in making informed decisions when using our site. This policy will be continuously assessed against new technologies, business practices and our customers’ needs.

This privacy policy will inform you of:
• Your privacy rights;
• How the law protects you; and
• How we look after your personal data, why we hold it and what we do with it.

Our core beliefs regarding user privacy and data protection:

• User privacy and data protection are human rights.
• Bespin Labs Limited (BESPIN LABS) have a duty of care to the people within our data.
• Data is a liability, it should only be collected and processed when necessary.
• BESPIN LABS will never sell, rent or otherwise distribute or make public your personal information outside the company.
• BESPIN LABS takes its security obligations seriously in respect of your personal data under the EU General Data Protection Regulation (GDPR).

By contacting us through our contact forms and white paper requesting forms on our websites, through a 3rd party website that forwards your information upon your request to us, or through any other form through which your personal information is provided to us, or by visiting our website, you are agreeing to this policy and the procedures stated within.

If you are or thinking about receiving any services from BESPIN LABS, an additional Privacy Policy Document can be made available to you upon request that includes additional detailed internal policies on how we keep your data safe within our company.

Our services are not intended to involve the personal data of children and we do not knowingly collect data relating to children. If you are under 16 years of age you must obtain parental consent before contacting us.

1. WORLDWIDE COMPANY ADDRESS AND REGISTRATION DETAILS

Global Head Office for Bespin Labs Limited (BESPIN LABS):
Bespin Labs
Bates Mill, Colne Road, Huddersfield, HD1 3AG
Tel.: +44(0) 20 3920 0515

Bespin Labs Limited is one legal entity trading as:

• Bespin Labs

This privacy notice is issued on behalf of the Bespin Labs Limited so when we mention Bespin Labs Limited (BESPIN LABS), “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the group responsible for processing your data.

We will let you know which entity will be the controller for your data when required.

2. DISCLAIMER

2.1 Liability for Content

We make every effort to keep the information on our website current but accept no liability whatsoever for the content provided. The law limits our responsibility as a service provider to our own content on these webpages.

We are not obligated to monitor third party information provided or stored on our website. However, we shall promptly remove any content upon becoming aware that it violates the law. Our liability in such an instance shall commence at the time we become aware of the respective violation.

2.2 Liability for Links

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information that you provide while visiting such sites and such sites are not governed by this privacy statement. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party. You should exercise caution and look at the privacy statement applicable to the website in question.

At the time any third-party websites were linked to, we found no grounds whatsoever of any likely contravention of the law. We shall promptly delete such links upon becoming aware that any of them violate the law.

2.3 Copyrights

The content and works provided on these Web pages are governed by the copyright laws of the United Kingdom. Duplication, processing, distribution, or any form of commercialization of such material beyond the scope of the copyright law shall require the prior written consent of its respective author or creator.

3. INFORMATION WE COLLECT:

When you visit this website, use our products or where we carry out related activity you may knowingly provide us with personal information or we may collect personal information about you.

Personal data, or personal information, means any information about an individual from which that person can be identified.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

Identity Data – includes first name, last name, username or similar identifier, title, date of birth and gender.
Contact Data – includes email address and telephone numbers.
Financial Data – includes bank account and payment details.
Technical Data – includes internet protocol (IP) address, your login data, 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].

Usage Data – includes information about how you use our website, products and services.
Marketing and Communications Data – includes your preferences in receiving marketing from us and your communication preferences.

4. PERSONAL INFORMATION YOU CHOOSE TO PROVIDE:

Registration Information
When you register for any of our products, services or newsletters you will provide us information about yourself.

Credit Card Information
If you choose to purchase our products or services, you may need to give personal information and authorisation to obtain information from various credit services. For example, you may need to provide the following information:

Name
Mailing address
Email address
Credit card number
Name on credit card
Credit card billing address
Business phone number
Email Information

If you choose to correspond with us through email, we may retain the content of your email messages together with your email address and our responses. We provide the same protections for these electronic communications that we employ in the maintenance of information received by mail and telephone.

5. ENFORCEMENT OF PRIVACY POLICY

This website is designed to comply with the following national and international legislation with regards to data protection and user privacy:
EU General Data Protection Regulation 2018 (GDPR)

This site’s compliance with the above legislation means that this site is likely compliant with the data protection and user privacy legislation set out by many other countries and territories as well. If you are unsure about whether this site is compliant with your own country of residences’ specific data protection and user privacy legislation you should contact us (details can be found in section 11) for clarification.

6. HOW DO WE USE THE COLLECTED INFORMATION?

Again, we take your privacy very seriously and are committed to keeping your information safe and secure. We do not sell, license, lease or otherwise disclose your personal information to any third party outside the BESPIN LABS Network for any reason except as noted earlier and as described below:
Internal Third Parties – Other companies in our Group acting as joint controllers or processors who are based in the UK.
External Third Parties –
– Service providers acting as processors including Google which may not be located within the EEA and provide IT and system administration services.
– Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

Although GA records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us. GA also records your computer’s IP address which could be used to personally identify you, but Google does not grant us access to this. We consider Google to be a 3rd party data processor.

GA makes use of cookies, details of which can be found on Google’s developer guides. FYI our website uses the analytics.js implementation of GA.
Disabling cookies on your internet browser will stop GA from tracking any part of your visit to pages within this website.

7 Google AdWords Remarketing

At Bespin Labs, our website makes use of a variety of advertising technologies including Google AdWords Remarketing.

This technology is used to trigger tailored advertising across the internet to individuals who have shown interest in our business and visited our website. Google AdWords Remarketing functions by serving relevant ads that are tailored to you based upon the specific pages you have visited whilst on the BESPIN LABS website, by placing a cookie onto your computer or device.

This cookie will not give us any type of access or control of your computer or device, nor will it provide us with any personally identifiable information.

These cookies are used by Google AdWords Remarketing to tag an individual who has visited a specific page on our website and to display ads on third party websites (including Google) related to that page, the purpose being to help us deliver a tailored experience and related marketing materials to more accurately fit your needs, essentially ensuring you only see ads that are relevant to you.

These ads can appear in places such as Google search results, or a site that’s part of the Google Display Network. Any data collected will be done so in line with our own privacy policy.

If you do not want to have a tailored experience and would prefer not to receive these ads from us, you can opt out. In order to opt out you will need to visit Google’s Ads Preferences Manager here. You can also choose to opt out of any third party use of cookies here.

7.1 Enquiries through the website or to an individual within the BESPIN LABS Network

Should you choose to contact us using the contact form or by requesting for white papers or case studies to be sent to you, or by sending an email directly to one of our employees’ emails that are stated on the website, none of the data that you supply will be stored by this website or passed to / be processed by any of the third party data processors defined in section 6.

Instead the data will be collated into an email and sent over the Simple Mail Transfer Protocol (SMTP). Our SMTP servers are protected by TLS (sometimes known as SSL) meaning that the email content is encrypted using SHA-2, 256-bit cryptography before being sent across the internet. The email content is then decrypted by our local computers and devices.

Our hosting provider Cloudways setup the server to use the Elastic Email service to send emails securely and reliably. More information on their security practices can be found here.

7.2 Email newsletter

If you contact us, you consent to receive specific marketing emails from us that fit to your enquiry. The email address and information that you submit to us will be forwarded to contracted 3rd parties, who provide us with marketing and software services.

You can opt-out of receiving automated emails from us by clicking on “unsubscribe” on the bottom of one of the emails.

We consider these providers to be 3rd party data processors (see section 6 above). The email address and further information that you submit will not be stored within this website’s own database.

Your data will remain within these parties’ database for as long as we continue to use their services or until you specifically request removal. You can do this by requesting removal via email. When requesting removal via email, please send your email to the person who contacted you and using the email account that you have contacted us through.

7.3 LinkedIn Conversion Tracking and Insight Tag

The BESPIN LABS website makes use of the LinkedIn Conversion Tracking tool and Insight Tag. These tools are part of an analytics service provided by LinkedIn Corporation that connects data from the LinkedIn advertising network with actions performed on this website. These features track visitor data through the use of cookies by collecting data regarding LinkedIn members’ visits to our website, including the URL, referrer, IP address, device and browser characteristics, timestamp, and page views.

This data is encrypted, then de-identified within seven days, and the de-identified data is deleted within ninety (90) days. LinkedIn does not share the personal data with BESPIN LABS, it only provides aggregated reports about the website audience and ad performance. LinkedIn also provides retargeting for website visitors, enabling the website owner to show personalized ads off its website by using this data, but without identifying the member.

Simply put, none of the information gathered is personally identifiable and is used for the specific purpose of providing more personalised ad content.

LinkedIn members can control the use of their personal data for advertising purposes through their account settings.

7.4 Twitter Ads Conversion Tracking and Tailored Audiences (Twitter, Inc.)

The BESPIN LABS website utilises Twitter Ads Conversion Tracking in order to provide anonymised performance data analysis and to deliver personalised advertising to users who have shown interest in our website by visiting before.

Twitter Ads conversion tracking is an analytics service provided by Twitter, Inc. that connects data from the Twitter advertising network with actions performed on this website.

None of the information gathered is personally identifiable and is used for the specific purpose of providing more personalised ad content.

The specific details of Twitter’s privacy policy and how you can control the data you share in relation to tracking and tailored advertising can be found here.

8. ABOUT THIS WEBSITE’S SERVER

The Webmaster of this Website is Enigma.

The website is hosted by Cloudways.

Cloudways uses Digital Ocean as an infrastructure provider and information on their security can be found here.

BESPIN LABS is represented worldwide and in order to provide the best performance, this website is hosted in several data-centres. You are accessing the website through Cloudways data centre nearest to your location.
More information is available here.

All traffic (transferal of files) between this website and your browser is encrypted and delivered over HTTPS.

The people with direct access to the data on the server will be BESPIN LABS, Enigma and Cloudways. No personal data of yours is stored on these servers.

9. YOUR RIGHT AS A DATA SUBJECT

As a data subject whose personal information is hold by any member of the BESPIN LABS Network, you have certain rights.

If you wish to exercise any of these rights, please email privacy@bespinlabs.com or use the information supplied you by BESPIN LABS.

In order to process your request, we will ask you to provide valid forms of identification for verification purposes.

Your rights are as follows:

9.1 The right to be informed

You may request a copy of the personal data we hold about you free of charge. Once we have verified your identity and, if relevant, the authority of any third-party requestor, we will provide access to the personal data we hold about you as well as the following information:
a) The purposes of the processing
b) The categories of personal data concerned
c) The recipients to whom the personal data has been disclosed
d) The retention period or envisioned retention period for that personal data
e) When personal data has been collected from a third party, the source of the personal data
If there are exceptional circumstances that mean we can refuse to provide the information, we will explain them. If requests are frivolous or vexatious, we reserve the right to refuse them. If answering requests is likely to require additional time or occasions unreasonable expense (which you may have to meet), we will inform you.

9.3 The right to rectification

When you believe we hold inaccurate or incomplete personal information about you, you may exercise your right to correct or complete this data. This may be used with the right to restrict processing to make sure that incorrect/incomplete information is not processed until it is corrected

9.4 The right to erasure (the ‘right to be forgotten’)

Where no overriding legal basis or legitimate reason continues to exist for processing personal data, you may request that we delete the personal data. This includes personal data that may have been unlawfully processed. We will take all reasonable steps to ensure erasure.

9.5 The right to restrict processing

You may ask us to stop processing your personal data. We will still hold the data but will not process it any further. This right is an alternative to the right to erasure. If one of the following conditions applies you may exercise the right to restrict processing:
a) The accuracy of the personal data is contested
b) Processing of the personal data is unlawful
c) We no longer need the personal data for processing, but the personal data is required for part of a legal process
d) The right to object has been exercised and processing is restricted pending a decision on the status of the processing

9.6 The right to data portability

You may request your set of personal data be transferred to another controller or processor, provided in a commonly used and machine-readable format. This right is only available if the original processing was on the basis of consent, the processing is by automated means and if the processing is based on the fulfilment of a contractual obligation.

9.7 The right to object

You have the right to object to our processing of your data where
• Processing is based on legitimate interest;
• Processing is for the purpose of direct marketing;
• Processing is for the purposes of scientific or historic research;
• Processing involves automated decision-making and profiling.

10. DATA CONTROLLER

The data controller of this website is Bespin Labs Limited, a UK Private Limited Company with company number 11068628.
Registered and operating office is:
Bespin Labs, Bates Mill,
Colne Road, Huddersfield,
HD1 3AG, United Kingdom

11. DATA PROTECTION OFFICER & CONTACT

We are not a public authority and our core activities do not;

require large scale, regular and systematic monitoring of individuals (for example, online behaviour tracking); or
consist of large-scale processing of special categories of data or data relating to criminal convictions and offences,
and therefore, are not obligated to appoint a Data Protection Officer (DPO).

If you have questions about our data privacy or your personal data, you can contact us here: privacy@bespinlabs.com

12. PATRONUM APP API USAGE

Patronum App’s use and transfer of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

13. CHANGES TO OUR POLICIES

We will only reach out to you and inform you about changes to this privacy policy if the changes are significant.

Specific policy changes and updates are mentioned in the change log below.

13.1 Change-Log

06/04/2020 – First version released.