CBH Europe Ltd Privacy Notice
What is this notice?
CBH Europe Limited 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 and tell you about your privacy rights and how the law protects you. CBH Europe Ltd is the data controller and responsible for your personal data (referred to as “us”, “we” and “our” in this notice).
This privacy notice supplements any other notices we have provided you with on specific occasions in relation to your personal data (for example if you are our client) and is not intended to override them.
What data do we collect about you?
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where a person’s 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:
Types of Data:
Contact data is the information you give us directly when you communicate with us using any contact details available to receive further information regarding our services, i.e.:
- Name, Address, email & telephone details.
- Finance and Income details
- Date of Birth and tax details
- Information from Credit or fraud prevention agencies and other publicly available sources
- We will record your telephone calls, messages, emails and meeting notes
How do we use your data?
- The Legal basis under which we will use your data is as necessary to perform your contract with us for the relevant account or service:
- To take steps at your request to decide whether to enter into the contract
- To manage and perform that contract
- To update your records
- As necessary for our own legitimate interests:
- For governance, accounting and managing and auditing business operations
- Other parts of the CBH Group & Credit agency searches if Credit is requested
- To monitor calls, communications and emails, and account activity
- As Necessary to comply with Legal obligations
- When you exercise your data protection rights
- For compliance and regulatory requirements
- To establish and defend legal rights
- To very identity and make credit, fraud prevention and anti-money laundering checks.
- By Consent
- When you request disclosure of your details to others
- When you process any sensitive data about me at my request
- To send me marketing material that I have requested
You can choose to change your mind about how your data is used and withdraw your consent. We will only use your personal data as the law allows us to.
Who will we disclose your data to?
We may have to disclose your data to the following third parties for the purposes set out under “How do we use your data”:
- Service providers who provide IT and administrative services.
- Professional advisers and regulatory authorities.
- Other entities in our group.
How long will we keep your data for?
We will only store your data for as long as we have a legitimate business interest in doing so or are required to keep it, (but only where our interests do not override your interests and freedoms).
Will we transfer your data outside of the European Economic Area?
Occasionally we may use external third party service providers who are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, 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 by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
How we will keep your information secure?
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.
What are your rights?
You have the following rights in relation to how we use your data. If you’d like to exercise these rights please contact us using the contact details listed below under “Who can you speak to at CBH Europe Ltd about this policy?”.
- Right of access – you have the right to know if we are using your data and, if so, about how we are using it.
- Right of rectification – you have the right to require us to rectify any errors in the information we hold about you.
- Right to erasure – you have the right to require us to delete your data if our continued use of it is not justified.
- Right to restrict processing – in some circumstances you may be entitled to limit the purposes for which we can use your data.
- Right of data portability – you have the right to require us to provide you with a copy of your data in a commonly used machine-readable format or to transfer your data
- directly to another data controller (e.g. a third party offering services competing with ours).
- Right to object to processing – in some circumstances you may be entitled to require us to stop processing your data.
Who can you speak to at CBH Europe Ltd about this policy?
Questions, comments and the exercise of your rights regarding this notice and your information are welcomed and should be addressed to the Data Protection Team by email at firstname.lastname@example.org or by post at CBH Europe Ltd, 18 Savile Row, London, W1S 3PW.
Who is the supervisory authority and how can you contact them?
The Information Commissioner’s Office (“ICO”) is the supervisory authority in the UK responsible for the implementation and enforcement data protection law. You have the right to complain to the ICO about our collection and use of your data.
You can contact the ICO via the ICO website – https://ico.org.uk/concerns/ – or by calling their helpline – 0303 123 1113.
If you have any questions about this policy please contact the Data Protection Team by email at email@example.com or by post at CBH Europe Limited, 18 Savile Row, London, W1S 3PW