1. Introduction

High Wycombe Business Improvement District (HWBIDCo) Company Ltd, respects the privacy of our Levy Payers and is strongly committed to safeguarding your privacy. This Privacy Policy is designed to give you peace of mind when interacting with us. The purpose of this Privacy Policy is to provide, you, the user, with details of how High Wycombe BID Company Ltd will collect, store and use the personal data legitimately, that you supply us. Personal data is information which relates to identifiable living individuals.

We reserve the right to make changes to this Privacy Policy at any time. Your continued use of our services and websites that are subject to this Policy will signify your acceptance of any and all changes to this Policy made by us from time to time.

High Wycombe BID Company Ltd is the data controller in connection with any personal information collected or received by us arising from your use of any of the HWBIDCo services, websites and support services.

2. How we use your personal data

We will process your personal data in accordance with the [United Kingdom’s Data Protection Legislation]. We maintain strict security standards and procedures with a view to preventing unauthorised access to your data. We use leading technologies such as (but not limited to) data encryption, firewalls and server authentication to protect the security of your personal data. For all High Wycombe BID Company Ltd companies, all of our staff and whenever we hire third parties to provide support services, we will require them to observe our privacy standards and to allow us to audit them for compliance.

2.1 HWBIDCO Communications

We may process information that you provide to us for the purpose of forwarding you legitimate information relating to the operation of High Wycombe Business Improvement District. These communications could take the form of email, letter and/or social media channels as appropriate.

2.2 HWBIDCO Destination Marketing

We may process information that you provide to us for the purpose of reviewing your business advert on the official Destination Website and/or preparing the Official Destination Guide.

2.3 Social Media

If you use any of our social network pages or applications or you use one of our products or services that allow interaction with social networks, we may receive information relating to your social network accounts. For instance:

• If you click on a ‘like’, ‘+1’ or ‘tweet’ or similar button in one of our websites or services, we may record the fact that you have done so. In addition, the content that you are viewing may be posted to your social network profile or feed. We may receive information about further interactions with this posted content (for example, if your contacts click on a link in the posted content), which we may associate with the details that we store about you
• If you ‘like’, ‘+1’ or similar one of our pages on a social network site, we may receive information about your social network profile, depending on your social network account privacy settings.

2.4 Reviews, comments and content

Where you have uploaded product reviews, comments or content to our websites or services and made them publicly visible, we may link to, publish or publicise these materials elsewhere including in our own advertisements.

2.5 Legal Obligation

In addition to the specific purposes for which we may process your personal data set out in this section, we may also process any of your personal data where such processing is necessary for compliance with regulatory and legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

3. Providing your personal data to others

We may use other third-party service providers to provide certain data legitimate processing services for us (acting as our authorised data processors). Examples of authorised data processors could include billing and fulfilment partners, IT solution providers, data analytics providers who process information on our behalf for the purposes outlined above. For example, we may use the services of third parties to personalise content, fulfil orders, deliver packages, send postal mail and emails, send text messages (SMS), provide marketing assistance, process credit card payments, provide fraud checking services and provide customer services.

When acting as our authorised data processors, our service providers are required to only process data in accordance with our instructions, in line with this Policy, and are subject to appropriate confidentiality and security obligations.

In addition to the specific disclosures of personal data set out in this section, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

4. Cookies

A cookie is a small text file containing a unique identification number that is transferred (through your browser) from a website to the hard drive of your computer. The cookie identifies your browser but will not let a website know any personal data about you, such as your name and/or address. These files are then used by websites to identify when users revisit that website.

We use Google Analytics to monitor how the HWBIDCO website is used. Google Analytics collects information anonymously and generates reports detailing information such as the number of visits to the site, where visitors generally came from, how long they stayed and which pages they visited. Google Analytics places several persistent cookies on your computer’s hard drive. These do not collect any personal data. If you do not agree to this you can disable persistent cookies in your browser. This will prevent Google Analytics from logging your visits.

5. International transfers of your personal data 

We store your data on our secure servers in the United Kingdom and retain it for a reasonable period or as long as the law requires. However, your data may be transferred to, stored at, and processed at a destination inside or outside the European Economic Area by our partners or service providers. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Notice.

6. Retaining and deleting personal data

This Section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

• Personal data that we process shall not be kept for longer than is necessary for that purpose or those purposes.
• Your personal data will be retained for 5 years following the date you cease to be a client, or longer as required to meet our regulatory obligations.
• Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests.

7. Links to third party sites

Some of our websites may contain links to other third-party websites that are not operated by us. While we try to link only to sites that share our high standards and respect for privacy, we are not responsible for the content, security or privacy practices of those third-party websites. We strongly encourage you to view the privacy and cookie policies displayed on those third-party websites to find out how your personal information may be used.

8. Amendments

• We may update this policy from time to time by publishing a new version on our website.
• You should check this page occasionally to ensure you are happy with any changes to this policy.
• We may notify you of changes to this policy by email or through private messaging system or via our website.

9. Your Rights

In this Section we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries.  Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

Your principal rights under data protection law are:

(a)    the right to access;

(b)    the right to rectification;

(c)    the right to erasure;

(d)    the right to restrict processing;

(e)    the right to object to processing;

(f)    the right to data portability;

(g)    the right to complain to a supervisory authority; and

(h)    the right to withdraw consent.

You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to the supply of appropriate evidence of your identity. For this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address.

10. About Us

High Wycombe BID Company Ltd is registered in England and Wales. Our registered office is at Little Market House, Church Square, High Wycombe, HP11 2BN. Telephone: 01494 452705. Email: info@hwbidco.co.uk.

11. Updates to our privacy notice

Any changes we may make to our privacy policy in the future will be posted on this page. You should check this page from time to time to ensure that you are happy with any changes.

Privacy Policy last updated on 4^th April 2021.