This privacy notice provides you with details of how we collect and process your personal data through use of the TBVA website www.tbva.co.uk and the support services provided by TBVA for individual clients on a contractual basis.
Thurl Broux is the data controller and is responsible for your personal data (referred to as “we”, “us” or “our”) in this privacy notice.
Full name of legal entity: Thurl Broux trading as TBVA
Email Address: [email protected]
Postal Address: Cadmore House, 30 Earlsfield, Holyport, Berkshire, SL6 2LZ
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at [email protected]
2. WHAT DATA DO WE COLLECT ABOUT YOU; PURPOSES OF COLLECTION; AND LAWFUL BASIS OF PROCESSING
Personal data means any information capable of identifying an individual. It does not include anonymised data.
- Your personal information is not required to visit our website.
- Any personal information collected is knowingly provided by you and only required when
you use the form on the “Contact” page to send TBVA a message. No personal data collected from this form is stored on our website.
- We do not allow ‘comments’ on this website blocking this feature sitewide, therefore no personal data is stored on our website.
- We do not allow visitors to ‘register’ as a ‘user’ on this website, therefore no personal data is stored on our website.
We may process the following categories of personal data about you:
- Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication you send us. We process this data for the purposes of communicating with you, for record-keeping, and for the establishment, pursuance, or defense of legal claims. Our lawful grounds for this processing is our legitimate interests, which in this case are to reply to a communication sent to us, to keep records, and to establish, pursue or defend legal claims.
- Customer Data includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address, email address, phone number, contact details, purchase details, and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
- Technical Data (site visitation tracking) – like most websites, our site uses Google Analytics (GA) to track user interaction. We use this data to determine the number of people using our site, to better understand how they find and use our web pages, and to see their journey through the website.
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 third-party data processor.
- Your IP address is a numeric address assigned to your computer, assigned by your Internet service provider. We automatically collect your IP address as traffic data so that we can send information back to you when requested. This is not used to identify your personal information.
- Referrers are references to the web address you linked from and are automatically passed along by your web browser. We collect referrers your browser sends as part of traffic data. This is not attached to personally identifiable information.
- System information such as your operating system/platform, and the type of web browser you use. This is not attached to personally identifiable information.
- Sensitive Data – where we are required to collect personal data by law or under the terms of the contract between us. If you do not provide us with that data when requested, we may not be able to perform the contract (e.g. to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered, but if we do, we will notify you at the time.
We only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information please contact [email protected] In case we need to use your details for an unrelated new purpose we let you know beforehand and explain the legal grounds for processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
3. LINKS TO THIRD PARTY DATA PROCESSORS / WEBSITES
TBVA includes links to other websites whose privacy practices may differ from those of TBVA. If you submit personal information to any of those sites, your information is governed by their privacy statements. It is our suggestion that you carefully read the privacy statement of any website you visit.
4. INFORMATION USE
- Your information is maintained on a secure web server in what we believe to be a well-protected environment.
- TBVA does not share personal information collected with any other third-party company for any purpose, under any circumstance without your written consent to do so.
- TBVA makes every effort to preserve your privacy, personal information may be disclosed when required by law where we have a good-faith belief that such action is necessary to comply with a judicial proceeding, court order or legal process.
5. CHILDREN’S PRIVACY
Services we supply are intended for general audiences and not for children under the age of 13. We do not knowingly process data of EU residents under the age of 13 without parental consent. If we become aware that we have collected data from an EU resident under the age of 13 without parental consent, we will take reasonable steps to delete it as soon as possible.
Our website takes every precaution to protect visitor’s information. When visitors submit personal information via OUR website, their information is protected both online and offline.
Our website uses specialist security software (Cerber Security) to ensure data breaches do not occur. Cerber Security protects and monitors web traffic and web server logs, Cerber Security blocks potential hacks.
Should our website be hacked, no personal data can be compromised, no personal data is stored on our website, either by contact forms, user registration, or comments.
We do everything in our power to protect user-information offline. All of our client information, not just the personal information, is restricted in our office, our computers are password protected and only the director of the company has access to this data. The servers that store personally identifiable information online are in a secure data centre environment, protected by SSL and login requires two-factor authentication.
7. ENCRYPTED EMAIL
TBVA use Mailprotector Bracket – Email Encryption to send any emails containing personal information, passwords, and account details, credit card payment, and any other emails that are deemed as private and confidential, this ensures client data is fully encrypted and protected from being read by other entities than the intended recipient.
8. YOUR RIGHTS AND CHOICES
Your rights regarding the sensitive/ personal information we maintain about you enable you to exercise choices about what personal information we collect from you, how we use that information, and how we communicate with you.
At any point whilst TBVA is in possession of, or processing your personal data, all Data subjects have the following rights;
i. Right of access – you have the right to request a copy of the information that we hold about you.
ii. Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete
iii. Right to be forgotten – in certain circumstances, you can ask for the data we hold about you to be erased from our records.
iv. Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
v. Right of portability – you have the right to have the data we hold about you transferred to another organisation.
vi. Right to object – you have the right to object to certain types of processing such as direct marketing.
vii. Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.
If TBVA refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge.
TBVA at your request can confirm what information it holds about you and how it is processed.
- You can request the following information;
- Identity and the contact details of the person or organisation (TBVA) that has determined how and why to process your data.
- Contact details of the data protection officer, where applicable.
- The purpose of the processing as well as the legal basis for processing.
- If the processing is based on the legitimate interests of TBVA or a third party such as one of its clients, information about those interests.
- The categories of personal data collected, stored and processed.
- Recipient(s) or categories of recipients that the data is/will be disclosed to.
- How long the data will be stored.
- Details of your rights to correct, erase, restrict or object to such processing.
- Information about your right to withdraw consent at any time.
- How to log a complaint with the supervisory authority (ICO).
- Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
- The source of personal data if it wasn’t collected directly from you.
- Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
9. OUR INVOICE SYSTEM & DATA COLLECTION
TBVA uses Zoho Invoice (www.zoho.com) to generate invoices, estimates, and statements for each of our clients. Personal data such as contact name, company name, postal address, email address and telephone numbers are manually created within this system at the point of creating the first invoice/estimate for each client. This data is stored on www.zoho.com secure servers, which are fully GDPR compliant, please see this document outlining Zoho’s GDPR readiness: https://www.zoho.eu/gdpr.html
We have two-factor authentication set up when logging into Zoho invoice’s secure website, giving an extra layer of security.
As part of Zoho Invoice, emails are sent directly to clients via their system, which includes Invoices, Estimates, Statements, and overdue invoice email reminders.
- Right to Access – TBVA use Zoho Invoice, and any client who has a quotation or invoice with TBVA has full access to their personal data. Upon opening an account with TBVA clients are invited to access Zoho’s Secure Invoice Portal.
- Data Portability – Zoho’s Secure Invoice Portal allows clients to view and amend contact information, view invoices, quotations, credit notes, and statements. All of this personal data can be downloaded directly by the client. If you have any questions regarding Data Portability please email us directly: [email protected]
- Right to be Forgotten – If a client only has quotations with TBVA and no invoice has been created for services/products, we are able to completely delete that client’s details from Zoho Invoice, including all associated quotations. If however, a client requests to be forgotten but has invoices for services/products provided, we are, by UK Tax laws, required to keep these records for 7 years. In the event of this happening, we mark the client as ‘inactive’ within Zoho’s Invoice system.
To request a ‘Right To Be Forgotten’ please email us directly: [email protected]
10. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below:
- Service providers who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers.
- Government bodies that require us to report processing activities.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
We use Mailprotector Bracket – Email Encryption to send any emails containing information, passwords and account details, credit card payment, and other emails that are deemed as private and confidential, this ensures client data is fully encrypted and protected from being read by other entities than the intended recipient.
11. RETENTION OF YOUR INFORMATION
We keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable UK laws.
If we fall short of your expectations in processing your personal information or you wish to make a complaint about our privacy practices, please contact us at the above email or telephone number or at the address below. If you do not get a response within 30 days, you can complain to the ICO.
Information Commissioner’s Office