This privacy policy applies between you, the User of this Website and Bluedog Finance Ltd, the owner and provider of this Website. Bluedog Finance Ltd takes the privacy of your information very seriously. This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website.

Please read this privacy policy carefully.

Definitions and interpretation

In this privacy policy, the following definitions are used:

Data               
Collectively all personal data or personal information about an individual from which that person can be identified, either directly or indirectly. This data would include details that you submit to Bluedog Finance Ltd via the Website as well as details that we collect through our email marketing activities. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;

Data Protection Laws
Any applicable law relating to the processing of personal Data and the delivery of marketing by email, including but not limited to the Directive 96/46/EC (Data Protection Directive) or the GDPR, and any national implementing laws, regulations and secondary legislation, for as long as the GDPR is effective in the UK;  

The Privacy and Electronic Communications (EC Directive) Regulations 2003, also known as "PECR", is the principal law that covers direct marketing by email.

GDPR              
The General Data Protection Regulation (EU) 2016/679 and The Data Protection Act 2018 ;

Bluedog Finance Ltd (we or us)
Bluedog Finance Ltd, a company incorporated in England and Wales with registered number 14163573 whose registered office is at Unit 29, Highcroft Industrial Estate, Enterprise Road, Horndean, Waterlooville, Hampshire PO8 0BT;

User or you   
Any third party that accesses the Website and is not either (i) employed by Bluedog Finance Ltd and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Bluedog Finance Ltd and accessing the Website in connection with the provision of such services;

Website         
The website that you are currently using, www.bluedogfinance.co.uk, and any sub-domains of this site unless expressly excluded by their own terms and conditions.

In this privacy policy, unless the context requires a different interpretation:

a.     the singular includes the plural and vice versa;

b.    references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this                 privacy policy;

c.     a reference to a person includes firms, companies, government entities, trusts and partnerships;

d.     "including" is understood to mean "including without limitation";

e.     reference to any statutory provision includes any modification or amendment of it;

f.      the headings and sub-headings do not form part of this privacy policy.

Scope of this privacy policy

This privacy policy applies only to the actions of Bluedog Finance Ltd and Users with this Website. It does not extend to  any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.

For purposes of the applicable Data Protection Laws, Bluedog Finance Ltd is the "data controller". This means that Bluedog Finance Ltd determines the purposes for which, and the manner in which, your Data is processed.

Data collected

The information you give to us or we obtain from you may include:

• your name and title;
• contact information such as postal and email addresses and telephone numbers;
• your date of birth and National Insurance number;
• photographic identification and proof of address documents (to meet anti-money laundering requirements);
• bank account and other financial details;
• professional details such as job title, employment history, qualifications etc. usually included on a CV;
• in certain circumstances special category data which includes details relating to health (including disabilities), ethnicity, race, religious beliefs and trade union membership;
• the content of an enquiry form you submit through our website;
• any other personal information we collect about you in the context or our work for you as clients or in the course of operating our business;
• information collected automatically each time you visit our website (see our Cookies Policy for further information);
  
  in each case, in accordance with this privacy policy.

How we collect Data

We collect Data in the following ways:

             a.     data is given to us by you;
             b.     data is received from other sources; and
             c.     data is collected automatically.

We may collect the above information from any of the following categories of people:

• our clients and their employees or business partners;
• prospective employees or work experience students;
• the nominated emergency contacts for our employees and partners;
• other professionals such as accountants, surveyors or estate agents with whom we work in the context of providing financial services;
• our contractors and suppliers;
• those who submit enquiries through or use contact details on our website;
• any other visitor to our offices;
• other parties involved in legal matters or their solicitors;
• banks, building societies or other lenders;
• publicly available sources such as the Land Registry or Companies House.

Data that is given to us by you

Bluedog Finance Ltd will collect your Data in a number of ways, for example:

            a. when you contact us through the Website, by telephone, post, e-mail or through any other means;

            b. when you elect to receive marketing communications from us;

            c. when you use our services;

            in each case, in accordance with this privacy policy.

Data that is received from publicly available third parties sources

We will receive Data about you from the following publicly available third party sources:

            a.     Facebook
            b.     LinkedIn
            c.     Twitter
            d.     Google


Email Marketing and The Corporate Subscriber

In terms of the PECR, the subscriber is the individual or legal entity that is party to a contract with a provider of public electronic communications services. It specifically defines a corporate subscriber as, essentially, an incorporated company. This is different to the usual meaning of “subscriber” when discussing mailing lists. ICO guidance clarifies that this includes public bodies and Scottish partnerships, but not sole traders or members of an ordinary partnership, as they are not incorporated. In terms of email, the subscriber is held to be the individual or organisation for whom the email service is operated. Any of a corporate subscriber's email addresses would be a corporate email address. If a corporate email address contains a person's name or distinctive job title, it is known as a personal corporate email address. This is not the same as a strictly personal email address pertaining only to a private individual.

Why have you not asked for my consent?
Your email address has been identified as pertaining to a “corporate subscriber” within the meaning of PECR Regulation 2. Regulation 22 prohibits the delivery of unsolicited marketing messages by email to “individual subscribers”, with certain exemptions such as for existing customers. However, this does not apply to corporate subscribers. The UK's data protection supervisory authority, the Information Commissioner's Office or ICO, has published guidance clarifying that consent is not required to email business email addresses. Data protection laws still apply to any personal data being stored or used in relation to that address, such as if your email address contains your name, or a job title through which you could be easily identified. Such personal data is lawfully processed under Art. 6(1)(f) of the GDPR, about which more information is provided below.

Categories of Personal Data
Where a name or job title may be used to identify a living human being ("data subject") in relation to a business email address, the following categories of information directly or indirectly identifying that person may be processed: Name, job title and company, work contact details, records of emails opened with images enabled, records of hyperlinks clicked on in emails, IP addresses used to engage with emails, replies sent to emails, content submitted in forms linked to from emails.

Purposes and Basis of Processing
Personal data is processed for the purpose of targeting and personalising marketing messages and delivering them to the data subject in order to prospectively market products and services of the data controller's clients in pursuit of the commercial interests of both the data controller and its client. The personal data listed above is processed in accordance with Article 6(1)(f) of the GDPR, in pursuit of the legitimate interests detailed in this section. The data controller's and its client's legitimate interests are balanced with the fundamental rights and freedoms of data subjects by the provision of compliant transparency and disclosure notices, a clear, simple and effective means of opting out of further marketing messages, and the appointment of a Data Protection Officer who is available to fulfil any lawful request from a data subject.

How do I stop getting emails from Bluedog Finance?
All emails sent as part of a marketing campaign include an unsubscribe link where you can request that the email used is unsubscribed from further such emails.
 
Data that is collected automatically

To the extent that you access the Website, we will collect your Data automatically, for example:

• we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.

Our use of Data

Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:

• internal record keeping;
• transmission by email of marketing materials that may be of interest to you;
• to respond to any query you may submit to us;
• to carry out conflict checks (a regulatory requirement);
• to comply with our contractual obligation to clients to carry out the financial services as described in our engagement letters and terms of business;
• to verify your identity for anti-money laundering purposes, to include using a third party electronic verification provider (this will not affect your credit rating);
• to establish the source of funding in a transaction;
• to comply with any other professional, statutory and regulatory obligations we have;
• for administration or accounting purposes to manage our business;
• to administer our website;
• to process a job application you submit or is submitted on your behalf;
• to deal with your feedback on our services;
• to deal with a complaint;
• to provide you with updates on relevant areas of law;
• to invite you to a hospitality event;
• to contact you about other activities and events that we may organise.
  
  in each case, in accordance with this privacy policy.

We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed "Your rights" below).

Legal grounds for processing your personal information

Processing is any activity that involves your personal information. It includes obtaining, recording or holding the information, organising, amending, retrieving, using, disclosing, erasing or destroying it.

We can only process your personal information when the law allows it. Most commonly the legal grounds we will rely on are:

• to perform the contract we are about to enter into or have entered into with you;
• to comply with a legal or regulatory obligation to which we are subject such as checking your identity for anti-money laundering purposes;
• we have a legitimate interest in doing so as a financial broker which will include managing relationships with prospective and current clients, prospective and current employees, our contractors and suppliers, but only where our legitimate interests are not overridden by your fundamental rights or freedoms;
• to protect your vital interests such as if you were to fall ill or have an accident on our premises;
• where processing of special category personal data is necessary in the context of the establishment, exercise or defence of a legal claim.

Sharing your personal information

We may share your personal information with carefully selected third party organisations which store and process data on our behalf.  These third parties may include IT platforms, suppliers of administrative and support services and suppliers of other specialists products needed for the provision of our financial services.

We may also share your information with other third parties in the course of providing financial services to you, or where we are subject to a legal or regulatory requirement to do so. These third parties may include:

• the other parties involved in your financial affairs;
• counsel, accountants or other experts to assist or advise on your matter;
• a court or tribunal if we act for you in a litigated dispute;
• government bodies such as HMRC or HM Land Registry;
• insurance brokers or providers where you may need to take out an insurance policy as part of a transaction:
• a bank, building society or other lender providing finance in a transaction;
• We will not share your personal information with third parties for marketing purposes.

Keeping Data secure

We will use technical and organisational measures to safeguard your Data:

• We have put in place appropriate security measure to use our best endeavours to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
• In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know.  They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
• We will also ensure that if we need to send your personal information to a country outside of the EEA, we will comply with the relevant laws and regulations governing such transfers.
• We have procedures in place to deal with any suspected personal information breach and will notify you and our regulators where we are legally obliged to do so

If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: hello@bluedogfinance.co.uk

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

Data retention

Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this privacy policy or until you request that the Data be deleted.

Your rights

You have the following rights in relation to your Data:

• Right to access - the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify,   update or delete such information. If we provide you with access to the information we hold about you, we will not           charge you for this, unless your request is "manifestly unfounded or excessive." Where we are legally permitted to do       so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
   
• Right to correct - the right to have your Data rectified if it is inaccurate or incomplete.
   
• Right to erase - the right to request that we delete or remove your Data from our systems.
   
• Right to restrict our use of your Data - the right to "block" us from using your Data or limit the way in which we can         use it.
   
• Right to data portability - the right to request that we move, copy or transfer your Data.
   
• Right to object - the right to object to our use of your Data including where we use it for our legitimate interests.

To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this email address: hello@bluedogfinance.co.uk

If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner's Office (ICO). The ICO's contact details can be found on their website at https://ico.org.uk/.

It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

Links to other websites

This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.

Changes of business ownership and control

Bluedog Finance Ltd may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Bluedog Finance Ltd. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us.

We may also disclose Data to a prospective purchaser of our business or any part of it.

In the above instances, we will take steps with the aim of ensuring your privacy is protected.

General

You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.

If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforce-ability of the other provisions of this privacy policy will not be affected.

Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.

Changes to this privacy policy

Bluedog Finance Ltd reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations. 

You may contact Bluedog Finance Ltd by email at hello@bluedogfinance.co.uk

Updated 19th July 2022