Welcome to Biscuit Tin Limited’s privacy policy. Biscuit Tin respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website www.biscuittin.co.uk and access our software platform (the “Site”) (regardless of where you visit it from), and when you sign up for our Services. It also tells you about your privacy rights and how the law protects you.
Important information and who we are
We are Biscuit Tin Limited (“Biscuit Tin”, “We”, “Our”, “Us”). We are incorporated in Scotland with company number SC781699. Our registered office is it Suite 2, Ground Floor, Orchard Brae House, 30 Queensferry Road, Edinburgh, Scotland, EH4 2HS.
If you have any queries about this privacy policy or our privacy practices, please contact us as follows:
We have a Data Protection Manager (“DPO”) who is responsible for matters relating to privacy and data protection. This Data Protection Officer is [insert name] and they can be reached at:
Kenny Baxter
VP of Engineering,
Biscuit Tin
Suite 2, Ground Floor,
Orchard Brae House,
30 Queensferry Road,
Edinburgh,
Scotland, EH4 2HS
customer.services@Biscuittin.co.uk
If you are a data subject based in the EU and we are processing your data under the terms of this privacy policy you can contact us as set out above or you can contact our EU Representative with any queries or to exercise your rights under EU data protection legislation as follows:
Kenny Baxter
VP of Engineering,
Biscuit Tin
Suite 2, Ground Floor,
Orchard Brae House,
30 Queensferry Road,
Edinburgh,
Scotland, EH4 2HS
customer.services@Biscuittin.co.uk
Purpose of this privacy policy
This privacy policy aims to give you information on how we collect and process your personal data through your use of our Site, including any data provided by or about you in connection with accessing the Services we offer through our Site.
It is important that you read this privacy policy carefully so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
We will use the following terms in this policy to cover the different categories of individuals who interact with our Site and use our services or products:
Business User means an individual employee, consultant or agent of an entity we sell products or services to;
User means an individual customer who is using our Biscuit Tin digital vault and other services;
Nominee means an individual who is linked to a Biscuit Tin by a User;
Supplier Contact means an individual employee, consultant or agent of any third party supplier that we engage with for goods and/or services;
Visitor means any person accessing or browsing our Site.
Controller
Biscuit Tin is the Controller and responsible for your personal data where we are collecting data and determining how it will be used as set out in this Privacy Policy.
If you choose to upload additional categories of personal data and/or personal data of third parties to our Site in connection with the provision of Services we will be the processor of such information on your behalf. Further details are provided in our Terms and Conditions of Service.
Words and expressions used in the Data Protection Act 2018, UK General Data Protection Regulation (UK GDPR) and EU GDPR will have the same meaning where used in this privacy policy.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. 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.
The data we collect about you when you access our Site or subscribe for a Service
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 which we have grouped together as follows:
• Identity Data: includes first name, maiden name, last name, username or similar identifier, marital status, national insurance number, title, date of birth and gender and if you choose to provide it NHS registration number.
• Contact Data: includes billing address, delivery address, email address and telephone numbers.
• Financial Data: includes bank account and payment card details.
• Transaction Data: includes details about payments to and from you and other details of services you have purchased from us.
• 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.
• Profile Data: includes your username and password, purchases or orders made by you.
• 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 our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example we may aggregate Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
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). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
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, email or otherwise. This includes the personal data you provide when you:
• Apply for services;
• Register with us and create an account;
• Register as a Nominee;
• Subscribe for Services;
• Request marketing to be sent to you; or
• Give us feedback or contact us.
Automated technologies or interactions.
As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. Please see our cookie policy for further details.
Third parties. We will receive personal data about you from various third parties or public sources as set out below:-
• Technical data from analytics providers such as Google based outside the EU ;
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services;
• Identity and Contact Data from data brokers or aggregators;
• Identity and Contact Data from publicly available sources such as the Electoral Register.
How we use your personal data
We will only use your personal data when the law allows us to. 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 obligation.
• Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, 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.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
We may share your personal data with internal third parties and with our external service providers, advisers, insurers and regulators, HMRC and other authorities in connection with the purposes set out below. We may also share personal data with any third party investors or acquirers of our business. In all cases, we will put in place measures to ensure the security and confidentiality of your personal data.
PURPOSE/ACTIVITY TYPE OF DATA LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST
To register or liaise with you as a new User, Business User or Supplier Contact (a) Identity (b) Contact Performance of a contract with you
To register you as a Nominee (a) Identity (b) Contact Performance of a contract with you
To process and deliver the Services including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey (a) Identity (b) Contact (c) Profile (d) Marketing and Communications (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity (b) Contact (c) Technical (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical (b) Usage Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications Necessary for our legitimate interests (to develop our products/services and grow our business
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us and you have expressly opted into receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by logging into your account and checking or unchecking relevant boxes to adjust your marketing preference. Where you do not have an account you can do this by contacting us at customer.services@biscuittin.co.uk or you can click the unsubscribe link in any email we send you.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your Personal Data
We may share your personal data with some third parties , such as our own service providers such as those listed below, for the purposes set out in the table above:
• Professional advisors (including lawyers, auditors and insurers);
• IT Service Provider, Bad Dinosaur; and
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your data for specified purposes and in accordance with our instructions.
Cookies
Cookies enable our servers to recognise your web browser and tell us how and when you visit our Site or otherwise use our Services. Cookies are small pieces of data that are stored on your computer through your web browser when you access a website. You can set your browser to refuse some or all browser cookies, or to alert you when websites set or access cookies. For more information on the cookies we use on our Site, please see our Cookie Policy. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
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 reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law, we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your query to speed up our response
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.
Request correction of the personal data that 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.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. 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.
Object to processing of your personal data where we are 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.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
• If you want us to establish the data’s accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
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 products or services to you. We will advise you if this is the case at the time you withdraw your consent
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Contact details
If you have any questions about this privacy policy or our privacy practices, please contact us: Email address: customer.services@biscuittin.co.uk. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), which is the UK supervisory authority for data protection issues (www.ico.org.uk) or the relevant supervisory authority in the country where you are based. If you are in the EEA you can also contact the EU Representative whose details are set out at the start of this policy. We would, however, appreciate the chance to deal with your concerns before you approach the ICO or other supervisory authority so please contact us in the first instance.