The purpose of this policy is to explain how BLACK SWAN collects, protects, and uses personal data. BLACK SWAN is committed to ensuring that any personal data supplied by its Clients or is otherwise generated by its business activities is collected and processed fairly and lawfully.
Our promise to you
We hope you'll find it clear and simple but if you have any concerns or questions please feel free to contact us either using contact form or a letter to Black Swan at 21 Loughborough Road, Shepshed, Leicestershire LE12 9DL
Who's in control of your information?
We never lose sight of the fact that it is your personal information and you own it and can choose who has access to it and how its processed.
For the purposes of the UK data protection legislation, including Data Protection Act 1998 and General Data Protection Regulations(GDPR) 2016, we are registered as 'Data Controllers' with the Information Commissioner's Office (ICO). Details are published on a register on the ICO website where you can also find lots of useful information about Data Protection, what it means to you as an individual and how it applies to companies like BLACK SWAN.
The law within the European Economic Area gives those whose personal data is held by BLACK SWAN specific rights to access and rectify personal data held about them.
These include the right to:
• to obtain from BLACK SWAN, confirmation that personal data is held, as well as a written description of such personal data, the purpose(s) for which it is being used, the source(s) of the personal data and details of any recipients
• request rectification of personal data which is inaccurate
• request deletion of data where there is no need for BLACK SWAN to keep it
• request BLACK SWAN stops processing associated your personal data
• request we provide you the personal data you have provided us in an electronic format
• object to any unsolicited information sent by BLACK SWAN regarding promotions or new products and services.
If any individual wishes to contact BLACK SWAN regarding the personal data held about them or has any other question about BLACK SWAN’ data privacy procedures, they should direct a letter to Black Swan at 21 Loughborough Road, Shepshed, Leicestershire LE12 9DL
Where we decide not to take action in response to a request, we will explain why we are not going to take action. If you wish to complain about our decision we request in the first place you let us know. You also have the right to complain to the Information Commissioners Office – link to how to report a concern https://ico.org.uk/concerns/ and to a judicial remedy.
How Does BLACK SWAN Obtain Personal Data
BLACK SWAN obtains personal data in a number of ways including
• from orders placed by Clients (whether by telephone, or email or by application form)
• from enquiries made by existing Clients and potential Clients, (including information gathered at marketing events and via the BLACK SWAN website)
• from networking events where business cards are shared
• from existing contacts who make referrals passing on personal data to Black Swan.
What Types of Personal Data Does BLACK SWAN Collect? Data
Collecting information about you
In general, you can visit this website without providing any information about yourself, we may collect domain information from your visit to customise and improve your experience on our website.
BLACK SWAN, and third parties we use to provide services, needs certain personal data to enable it to provide its products and services to our Clients. We collect personal information about you, usually within a business context, when you sign up for newsletters with us or use our services.
Black Swan will be what’s known as the ‘Controller’ of the personal data you provide to us, this means we control what happens to the data in our possession.
The personal data collected will generally include:
• contact names (first and last name) and contact details (company name, postal address, telephone and e-mail addresses) for delivery, support and billing.
• In certain circumstances BLACK SWAN may collect financial information about BLACK SWAN Clients and end users from third parties to enable BLACK SWAN to assess its risks in granting credit terms.
Information we collect online: Cookies
Data relating to providing Newsletters
BLACK SWAN needs the following in order to provide you the newsletters you have requested
• contact names (first) and contact details (e-mail addresses) for delivery.
How Does BLACK SWAN Use the Personal Data it Holds?
Providing the BLACK SWAN Services
Most of BLACK SWAN use of personal data is necessary to enable it to provide a service to its Clients, including order processing, delivery of service be and for invoicing and to answer general enquiries.
Direct Marketing & Newsletters
BLACK SWAN may from time to time inform its Clients, end users and potential Clients about BLACK SWAN products and services and other information BLACK SWAN feels may be of interest.
Clients and other recipients of information from BLACK SWAN may indicate at the time they first place an order or share contact details with BLACK SWAN whether or not they wish to receive such information or at any later time by simply contacting BLACK SWAN, as indicated below.
What Processing of Personal Data is done?
This section describes the processing of personal data that BLACK SWAN caries out associated with each of the services it supplies. We have no processing which relates to automated decision making.
Direct Marketing & Newsletters
1. Data collected when a client signs up to receive a regular newsletter / bulletin – data will be processed by BLACK SWAN. The data will only be used to send out the newsletter and the client will be able to unsubscribe at any time. Data will be deleted within 6 months when users unsubscribe.
To Whom Does BLACK SWAN Disclose Personal Data?
As a general rule, BLACK SWAN does not disclose personal data to unaffiliated third parties except where Client consent has been obtained.
All the personal data we process is processed by us, or our suppliers as identified below and in the EU.
No 3rd parties other than those listed below have access to your personal data unless you specifically agree to engage in publicity or the law allows them to do so.
We have a Data Protection regime in place to oversee the effective and secure processing of your personal data.
Direct Marketing & Newsletters
Clients who sign up to receive newsletters and marketing emails will have name and email contract information
• passed to our office, which is based in the EU.
Where you have agreed to a personal electronic to an individual where we believe that the mutual benefit for you to meet specific named individuals to further the aims of each of your businesses, we may share your personal information with the specific named individuals.
How long does BLACK SWAN retain the Personal Data it Holds?
BLACK SWAN will not keep personal data longer than is necessary, retention periods are defined by policy. The policy is reviewed from time to time to determine whether it is being complied with and is effective.
• Data associated with invoicing is retained for indefinitely
• Contact data is retained for up to 6 years after last client interaction or agreed date for follow-up.
Does BLACK SWAN Transfer Personal Data Overseas?
BLACK SWAN and its 3rd Parties do not transfer personal data outside the EU.
BLACK SWAN Data is located on devices and servers within the UK or EU.
How Does BLACK SWAN Protect the Personal Data it Holds?
BLACK SWAN takes Client confidentiality and security very seriously. BLACK SWAN has implemented appropriate internal security procedures that restrict access to and disclosure of personal data within BLACK SWAN. These procedures will be reviewed from time to time to determine whether they are being complied with and are effective. Where data is shared by 3rd parties they are bound by contract to do the same.
As part of BLACK SWAN’s commitment to compliance with data privacy requirements, and to reflect changes in BLACK SWAN's operating procedures, BLACK SWAN may update the terms of this policy from time to time
21 Loughborough Road, Shepshed, Leicestershire LE12 9DL
T: 01509 506222
Opening Times: 4pm - Midnight (Mon- Thurs), 12 noon - 1am (Fri, Sat & Sun)