Welcome to the L Marks Limited’s (L Marks) privacy notice.
L Marks 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 also use the Glossary at the end of this privacy notice to understand the meaning of some of the terms used in this privacy notice.
1. IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how L Marks collects and processes your personal data through your use of this website, including any data you may provide through this website:
- Through your registration for and use of “The Bridge”
- When you contact us via the contact form.
- When you sign up to our newsletter.
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.
As each of our programmes is different and participation in a programme will normally involve your information being shared with a corporate sponsor, we publish separate privacy notices for each programme. A link to the privacy notice for the application stage of each programme will be shown on the application form and you should read it carefully before submitting your application.
This privacy notice supplements the other notices and is not intended to override them.
‘L Marks’ is the controller and responsible for your personal data (referred to as L Marks, “we”, “us” or “our” in this privacy notice).
We have appointed a data protection officer (DPO) 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 DPO using the details set out below.
Our full details are:
Full name of legal entity: L Marks Limited
Name of DPO: Daniel Saunders
Email address: email@example.com
Postal address: Headland House, 72 Acton St, WC1X 9NB
Telephone number: 020 8050 5043
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.
CHANGES TO THE PRIVACY NOTICE
We may update this privacy notice from time to time to reflect changes in how we handle your personal data. Any updates will be posted on the L Marks website.
This privacy notice was last updated on 7 February 2019.
YOUR DUTY TO INFORM US OF CHANGES
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.
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 third-party 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.
2. THE DATA 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 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 follows:
- Identity Data includes first name and last name.
- Contact Data includes email address and telephone numbers.
- Usage / Technical Data includes information about how you use our website.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Application Data includes any information you provide about yourself as part of the application process, whether this is general profile information about your background and involvement in the start-up’s business or information which is specific to your application to a particular programme.
- Event Data includes any information which is collected about you at an event that you attend and uploaded to “The Bridge” platform, including any information that you post on the platform or any information that any other attendee posts about you.
We do not intend to 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 information about any information about criminal convictions and offences. If you specifically choose to submit any of this type of information to us then by doing so you consent to us using it in the manner described by this privacy notice.
3. 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 information about yourself by registering on “The Bridge”, completing your profile and filling in an application, by submitting information about an event that you are attending, by contacting us via the contact form or by signing up for our newsletter.
- Information submitted by others. Other users of our website may submit information about you. For example, if you are involved in a start-up and someone else registers that start-up via “The Bridge”, the profile or application may involve information about you. In addition, if you attend an event, other attendees may submit feedback via “The Bridge” which relates to you in some way.
- Third parties or publicly available sources.We may receive technical data from analytics providers such as Google based outside the EU.
4. 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 you have given us your express consent to do so.
- 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 or regulatory obligation.
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.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you on our database and on “The Bridge”||(a) Identity|
(b) Contact(c) Application
|Where you have consented to us doing so.|
|To maintain your account on “The Bridge” and collect and store your profile information||(a) Identity|
|(a) By registering with us and submitting profile information, you have consented to us doing so.|
(b) It is in our legitimate interests to do so (to provide an efficient application process for our programmes).
|To process your application to any programme||(a) Identity|
|You have consented to us doing so.|
|To communicate information about events and collect feedback and other interactions||(a) Identity|
|(a) Where you have submitted that information, you have consented to us using the data in this way.|
(b) Where someone else has submitted that information, it is in our and the sponsor’s legitimate interest to do so (to support the process of assessing the participating start-ups).
|Where you have requested us to do so, to send you our newsletter||(a) Contact|
(b) Marketing and Communications
|You have consented to us doing so.|
|Where you have indicated an interest in us doing so, to reach out to you about opportunities that we feel may be of interest to you||(a) Identity|
(d) Marketing and Communications
|You have consented to us doing so.|
|To respond to any communication that you send us through the “contact us” form||(a) Identity|
|(a) Where you have requested a response, this constitutes your consent for us to contact you in this manner.|
(b) In any other case, we will respond where it is in our legitimate interests to do so (for example to pursue an opportunity with you).
|To manage our relationship with you which will include notifying you about changes to our terms or privacy notice||(a) Identity|
|(a) Necessary to comply with a legal obligation.|
(b) Necessary for our legitimate interests (to keep our records updated).
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity|
(c) Usage / 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).|
to comply with a legal obligation.
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||Usage / Technical||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).|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Please contact us if you would like to change your marketing preferences.
PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact and Usage / Technical 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).
We will get your express opt-in consent before we share your personal data with any company outside L Marks for marketing purposes.
You can ask us to stop sending you marketing messages at any time by contacting us at any time on firstname.lastname@example.org.
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.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:
- Corporate sponsors of our programmes (where the data relates to your participation in one of our programmes – please see the relevant programme privacy notice for more information).
- Providers of outsourced services, such as hosting and IT support or maintenance services (to the extent necessary for the provider to provide those outsourced services to us).
We may also share your personal information with third parties if we are under a duty to share your personal information in order to comply with any legal obligation, or in order to enforce or apply such other terms as apply to our relationship, or to protect the rights, property, or safety of our corporate sponsors, start-ups participating in our programmes, ourselves or others.
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.
6. INTERNATIONAL TRANSFERS
We do not transfer your personal data outside the United Kingdom or European Economic Area (EEA) unless it relates to an L Marks programme located outside of the EEA.
A transfer outside the EEA may be to:
- a country that is considered to have data protection rules that are equivalent to those in the EEA; or
- a country which is not considered to have the same standards of protection for personal data as those in the EEA, in which case we will take all steps required by law to ensure sufficient protections are in place to safeguard your personal information, including where appropriate putting in place contractual terms approved by the relevant regulatory authorities.
7. 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.
8. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for.
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.
In some circumstances you can ask us to delete your data: see request erasure below for further information.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
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 processingof 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.
- Request the transferof 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 timewhere 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.
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 may 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 LIMIT TO RESPOND
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.
- 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 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.