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Privacy Notice

Welcome to the Brave Bison privacy notice.

Brave Bison respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit this website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.


Purpose of the privacy notice

This privacy notice (together with our Terms of Use and Cookie Policy) sets out the basis on which we collect information from or about you, or that you provide to us, and how this information will be processed by us through your use of this website and our services. Please read the following privacy notice carefully to understand our views and practices regarding your information and how we will treat it.


Controller

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

This privacy notice is issued on behalf of the Brave Bison group of companies so when we mention “Brave Bison”, "we", "us" or "our" in this privacy notice, we are referring to Brave Bison Limited for personal data collected and processed through this website and the relevant trader in the Brave Bison group responsible for processing your personal data for the purposes of our services. For information purposes, Brave Bison trades through Brave Bison Limited (07634543), Greenlight Digital Limited (03314461), Greenlight Commerce Limited (09690841) and Best Response Media Limited (06973196). Brave Bison is the controller and responsible for this website.

We have appointed a Data Protection Co-Ordinator who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Data Protection Co-Ordinator using the details set out below.


Contact Details

If you have any questions about this privacy notice or our privacy practices, please contact our Data Protection Co-Ordinator in the following ways:

Full name of legal entity: Brave Bison Limited

Name of Data Protection Co-Ordinator: Philippa Norridge, CFO

Email address: privacy@bravebison.io

Postal address: The Varnish Works, 3 Bravingtons Walk, London, United Kingdom, N1 9AJ

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.


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

We keep our privacy notice under regular review. This version was last updated [DATE]. Previous versions of the privacy notice can be obtained by contacting us.

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

Our website may, from time to time, may contain links to and from the websites and applications of our advertisers, affiliates, partner networks and other service providers such as YouTube, Facebook, Twitter, TikTok and Snapchat. If you follow a link to any of these websites, please note that these websites may collect or share personal data about you and have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these privacy policies before you submit any information to these websites.


Information 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 which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

  • 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 products and 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 purchases or orders made by you, your interests, preferences, feedback and survey responses.

  • 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 your 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 notice.

We may collect some Special Categories of Personal Data about you if you give us your details relating to religious or philosophical beliefs, sexual orientation, and information about your health by corresponding with us. We do not collect any Special Categories of Personal Data without processing it fairly, lawfully and transparently and without your explicit consent

We do not 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). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

Information you provide to us

We will not ask you to provide any Special Categories of Personal Data. Any Special Categories of Personal Data collected will only be collected when you volunteer it. Should you decide you want to disclose Special Categories of Personal Data relating to you, you must provide us with explicit consent.

You have the right to withdraw this consent at any time. Should you decide to withdraw this consent, please contact the Data Protection Co-Ordinator.


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:

  • apply for our products or services;

  • completing contact forms;

  • attend our events;

  • subscribe to our service or publications;

  • request marketing to be sent to you;

  • enter a competition, promotion or survey;

  • enter into discussions or correspondence with us in relation to our services;

  • enter into a contract with us;

  • interact with other services we offer now and in the future;

  • send us your content for us to upload to our YouTube channel(s); or

  • give us feedback or contact us.

Automated technologies or interactions. This is information we collect about you if you use any of the other websites we operate or other services we provide. In this case we will have informed you when we collected that data if we intend to share that data internally and combine it with data collected on this site. We will also have told you for what purpose we will share and combine your data. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies).

Third parties or publicly available sources. We will combine this information with information you give to us and information we receive about you from other sources. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

Third Party

Data





  1. Technical Data from the following parties:

  • analytics providers such as Google based outside the UK;

  • advertising networks such as Google, LinkedIn, Meta and Digital Advertising Network who are based inside and outside the UK; and

  • search information providers such as Google Analytics based outside the UK

  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services;

Technical Services includes Google Chrome who are based outside the UK;

Payment Services includes Financial Force and Xero to deliver payment services who are based inside and outside the UK;

E-commerce includes contracted freelancers to deliver e-commerce services and who are based outside the UK.

Identity and Contact Data from data brokers or aggregators; and

Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.

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; and

  • where we need to comply with a legal obligation.

Generally, we do not rely on consent as a lawful 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 basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific lawful basis we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new client

(a) Identity
(b) Contact

Performance of a contract with you

To process and deliver services to you including:
(a) Managing payments, fees and charges
(b) Administering your account with us

(c) Collect and recover money owed

(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications

(f) Technical

(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 enable you to partake in a prize draw, competition or complete a survey

(a) Identity 

(b) Contact 

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business, websites and applications (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 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 websites, applications, 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)

To upload your content onto our YouTube channels

Identity

Usage

Necessary for our legitimate interests (to develop our networks and grow our business)

Consent

Marketing

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

when signing up to our publications, you will be given the option to unsubscribe on each publications;

when you complete a contact form or send an email to hello@bravebison.com, you will be given the option to opt in/out of our marketing and advertising before submitting a personal account.


Promotional offers from us

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/used our services from us and you have not opted out of receiving that marketing.


Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the Brave Bison group of companies for marketing purposes.


Opting out

You can ask us or third parties 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.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, service experience or other transactions.


Cookies

Our websites uses cookies to distinguish you from other users of our site. This helps us to provide you with the best experience when you browse our website and also allows us to improve our site. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy [INSERT LINK].

Please note that third parties may also use cookies, over which we have no control. These third party cookies are likely to be analytical cookies or performance cookies or targeting cookies.


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 lawful 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 third parties if they have a need to know the information for the purposes of providing the contracted services. Set out below are some of the third parties we engage with for the purposes set out in the table Purposes for which we will use your personal data above.

  • Internal Third Parties include other companies in the Brave Bison group acting as joint controllers or processors and who are based in England and Wales and provide IT and system administration services and undertake leadership reporting. Internal third parties include the Brave Bison Limited, Greenlight Digital Limited, Greenlight Commerce Limited and Best Response Media Limited.

  • External Third Parties include:

    • Service providers acting as processors based in the UK, Republic of Ireland, Singapore and USA who provide IT and system administration services and online media services.

    • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK, Singapore and USA who provide consultancy, banking, legal, insurance and accounting services.

    • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

    • Service providers acting as processors based in the UK who provide credit check services.

  • Specific third parties such as Atlassian who provide project development services, Done Done who provide web design and ticket management services, Financial Force and Sales Force who provide management services for customers and suppliers.

  • 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 notice.

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 personal data for specified purposes and in accordance with our instructions.


International transfers

We may share your personal data within the Brave Bison group. This will involve transferring your data outside the UK.

We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. These rules are called "binding corporate rules".

Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data. For further details, see the ICO website here and the Department for Digital, Culture, Media & Sport’s (DCMS) website here.

  • Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK. For further details, see the ICO website here.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.


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.

We may process personal data on behalf of our customers during the provision of our services and such personal data shall be processed in accordance with the terms of our Data Processing Agreement.


Data retention

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 your legal rights below for further information.

In some circumstances we may 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. Please click on the links below to find out more about these rights:

If you wish to exercise any of the rights set out above, please contact us.


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.


What we may need from you

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 request to speed up our response.


Time 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.


Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

YOUR LEGAL RIGHTS

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.

[Last updated 15th January 2023. If you require our privacy policy before this date, please contact us].