RBC 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 our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
Please use the Glossary to understand the meaning of some of the terms used in this privacy notice.
IMPORTANT INFORMATION AND WHO WE ARE
1.1 PURPOSE OF THIS PRIVACY NOTICE
(a) This privacy notice aims to give you information on how RBC collects and processes your personal data through your use of this website, including
any data you may provide through this website.
(b) This website is not intended for children and we do not knowingly collect data relating to children.
(c) It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
1.2 CONTROLLER
(a) This privacy notice is issued on behalf of the RBC Group so when we
mention “RBC”, “we”, “us” or “our” in this privacy notice, we are referring to
the relevant company in the RBC Group responsible for processing your
data. RBC Commercial Ltd & RBC Contracting Ltd are the controllers and
responsible for this website.
(b) We have appointed a Data Compliance Manager 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 Compliance Manager using the details
set out below.
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1.3 CONTACT DETAILS
(a) Our full details are:
(i) Full name of legal entity: Roveen BC Ltd
(ii) Data Compliance Manager: Contractor Care Manager
(iii) Email address: admin@roveen-bcltd.co.uk
(iv) Postal address: 169 Manchester Road, Tyldesley, Manchester,
England, M29 8WT
(v) Telephone number: 01617062890
(b) You have the right to make a complaint at any time to the Information
Commissioner’s Office (ICO), the UK supervisory authority 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.
1.4 CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF
CHANGES
(a) This version was last updated in May 2018 and historic versions can be
obtained by contacting us.
(b) The data protection law in the UK will change on 25th May 2018. Although
this privacy notice sets out most of your rights under the new laws, we may
not yet be able to respond to some of your requests (for example, a request
for the transfer of your personal data) until May 2018 as we are still working
towards getting our systems ready for some of these changes.
(c) 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.
1.5 THIRD-PARTY LINKS
(a) This website may include links to third-party websites, plug-ins and
applications. Clicking on those links or enabling those connections may
allow third parties to collect or share data about you. We do not control
these thirdparty websites and are not responsible for their privacy
statements. When you leave our website, we encourage you to read the
privacy notice of every website you visit.
THE DATA WE COLLECT ABOUT YOU
2.1 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).
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2.2 We may collect, use, store and transfer different kinds of personal data about you which
we have grouped together as follows:
(a) Identity Data includes first name, maiden name, last name, username or
similar identifier, marital status, title, date of birth and gender.
(b) Contact Data includes residential address, email address and telephone
numbers.
(c) Financial Data includes bank account.
(d) Transaction Data includes details about payments to and from you.
(e) 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.
(f) Profile Data includes your username and password, feedback and survey
responses.
(g) Usage Data includes information about how you use our website, products
and services.
(h) Marketing and Communications Data includes your preferences in
receiving marketing from us and our third parties and your communication
preferences.
(i) We also collect, use and share Aggregated Data such as statistical or
demographic data for any purpose. Aggregated Data may be derived from
your personal data but is not considered personal data in law as this data
does 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.
(j) We do not collect any Special Categories of Personal Data about you (this
includes details about your race or ethnicity, religious or philosophical
beliefs, sex life, sexual orientation, political opinions, trade union
membership, information about your health and genetic and biometric data).
Nor do we collect any information about criminal convictions and offences.
2.3 IF YOU FAIL TO PROVIDE PERSONAL DATA
(a) 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.
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HOW IS YOUR PERSONAL DATA COLLECTED?
3.1 We use different methods to collect data from and about you including through:
(a) 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:
(i) apply for our products or services;
(ii) create an account on our website;
(iii) subscribe to our service or publications;
(iv) request marketing to be sent to you; (v) enter a competition,
promotion or survey; or (vi) give us some feedback.
(b) Automated technologies or interactions. As you interact with our website,
we may automatically collect Technical Data about your equipment,
browsing actions and patterns. We collect this personal data by using
cookies, server logs and other similar technologies. We may also receive
Technical Data about you if you visit other websites employing our cookies.
(c) Third parties or publicly available sources. We may receive personal
data about you from various third parties and public sources as set out
below:
(i) Technical Data from the following parties:
(A) analytics providers such as Google based outside the EU;
(B) advertising networks; and
(C) search information providers.
(ii) Contact, Financial and Transaction Data from providers of technical,
payment and delivery services.
(iii) Identity and Contact Data from publicly availably sources such as
Companies House and the Electoral Register based inside the EU.
HOW WE USE YOUR PERSONAL DATA
4.1 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:
(a) Where we need to perform the contract we are about to enter into or have
entered into with you.
(b) 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.
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(c) Where we need to comply with a legal or regulatory obligation.
4.2 See the table below to find out more about the types of lawful basis that we will rely
on to process your personal data.
4.3 Generally we do not rely on consent as a legal basis for processing your personal
data other than in relation to 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.
4.4 PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
(a) 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.
(b) 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.
Purpose/Activity
Type of data
Lawful basis for processing
including basis of legitimate interest
To register you as a new
customer
(a) Identity
(b) Contact
Performance of a contract with you
To process and deliver your
order including:
(a) Manage payments, fees
and charges
(a)
Identity
(b)
Contact
(c)
Financial
(a) Performance of a contract with you
(b) Necessary for our legitimate
interests
(to recover debts due to us)
(b) Collect and recover
money owed to us
(d) Transaction
(e) Marketing
and
Communications
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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 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
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)
(e) Marketing
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and
Communications
(f) Technical
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
Necessary for our legitimate interests
(to develop our products/services and
grow our business)
4.5 MARKETING
(a) 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:
4.6 PROMOTIONAL OFFERS FROM US
(a) 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).
(b) You will receive marketing communications from us if you have requested
information from us and you have not opted out of receiving that marketing.
4.7 THIRD-PARTY MARKETING
(a) We will get your express opt-in consent before we share your personal data
with any company outside the RBC group of companies for marketing
purposes.
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4.8 OPTING OUT
(a) 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.
4.9 COOKIES
(a) 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.
4.10 CHANGE OF PURPOSE
(a) 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.
(b) 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.
(c) 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
5.1 We may have to share your personal data with the parties set out below for the purposes
set out in the table above.
(a) Internal Third Parties as set out in the Glossary.
(b) External Third Parties as set out in the Glossary.
(c) Specific third parties listed in the table in paragraph 4 above.
(d) 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.
5.2 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.
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INTERNATIONAL TRANSFERS
6.1 We do not transfer your personal data outside the European Economic Area (EEA).
DATA SECURITY
7.1 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.
7.2 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
8.1 HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
(a) We will only retain your personal data for as long as necessary to fulfil the
purposes we collected it for, including for the purposes of satisfying any
legal, accounting, or reporting requirements.
(b) 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
requirements.
(c) Details of retention periods for different aspects of your personal data are
available in our retention policy which you can request by contacting us.
YOUR LEGAL RIGHTS
9.1 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:
(a) Request access to your personal data.
(b) Request correction of your personal data.
(c) Request erasure of your personal data.
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(d) Object to processing of your personal data.
(e) Request restriction of processing your personal data.
(f) Request transfer of your personal data.
(g) Right to withdraw consent.
9.2 If you wish to exercise any of the rights set out above, please contact us.
9.3 NO FEE USUALLY REQUIRED
(a) 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 may
refuse to comply with your request in these circumstances.
9.4 WHAT WE MAY NEED FROM YOU
(a) 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.
9.5 TIME LIMIT TO RESPOND
(a) We try to respond to all legitimate requests within one month. Occasionally it
may 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
10.1 LAWFUL BASIS
(a) 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.
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(b) 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.
(c) Comply with a legal or regulatory obligation means processing your
personal data where it is necessary for compliance with a legal or regulatory
obligation that we are subject to.
10.2 THIRD PARTIES
(a) INTERNAL THIRD PARTIES
(i) Other companies in the RBC Group acting as joint controllers or
processors and who are based in the UK and provide IT and system
administration services and undertake leadership reporting.
(b) EXTERNAL THIRD PARTIES
(i) Service providers acting as processors based in the UK who provide
IT and system administration services.
(ii) Professional advisers acting as processors or joint controllers
including lawyers, bankers, auditors and insurers based in the UK
who provide consultancy, banking, legal, insurance and accounting
services.
(iii) HM Revenue & Customs, regulators and other authorities acting as
processors or joint controllers based in the UK who require reporting
of processing activities in certain circumstances.
10.3 YOUR LEGAL RIGHTS
(a) You have the right to:
(i) 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.
(ii) 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.
(iii) 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,
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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.
(iv) 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.
(v) 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: (a) if you want us to establish the
data’s accuracy; (b) where our use of the data is unlawful but you do
not want us to erase it; (c) 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; or (d) you have objected to our use of your data
but we need to verify whether we have overriding legitimate grounds
to use it.
(vi) 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.
(vii) 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.