How your personal information is used by BHMA Limited
Last updated March 2018.
More information on BHMA Limited can be found at Companies House here https://www.gov.uk/get-information-about-a-company.
How we use your personal information
This is our privacy notice to let you know how we look after your personal information. This includes what you tell us about yourself, what we learn by having you as a customer, and the choices you give us about what marketing and general information you want us to send you. This notice explains how we do this and tells you about your privacy rights and how the law protects you.
Our Privacy Promise
We promise: To keep your data safe and private. Not to sell your data. To give you ways to manage and review your marketing choices at any time you choose.
Data Protection law will change on 25 May 2018
This notice sets out most of your rights under the new laws. We’ll update it again after 25 May 2018 when changes come into effect.
Who we are
BHMA Limited is a company registered with Companies House number 02662130. There are two directors Patrick Huggins & Nicola Slade. The company trades on recommendation, with regular customers and on the two websites mentioned above.
How the law protects you
As well as our Privacy Promise, your privacy is protected by law. This section explains how that works.
Data Protection law says that we are allowed to use personal information only if we have a proper reason to do so. This includes sharing it outside BHMA Limited. The law says we must have one or more of these reasons:
- To fulfil a contract we have with you, or
- When it is our legal duty, or
- When it is in our legitimate interest, or
- When you consent to it.
A legitimate interest is when we have a business or commercial reason to use your information. But even then, it must not unfairly go against what is right and best for you. If we rely on our legitimate interest, we will tell you what that is.
Here is a list of all the ways that we may use your personal information, and which of the reasons we rely on to do so. This is also where we tell you what our legitimate interests are.
What we use your personal information for
Our legitimate interests
• To manage our relationship with you or your business.
• Your consent.
• Keeping our records up to date, working out which of our products and services may interest you and telling you about them.
• To develop and manage our brands, products and services.
• Fulfilling contracts.
• Developing products and services, and what we charge for them.
• To deliver our products and services.
• Fulfilling contracts.
• Being efficient about how we fulfil our legal and contractual duties.
• To detect, investigate, report, and seek to prevent financial crime.
• Fulfilling contracts.
• Developing and improving how we deal with financial crime, as well as doing our legal duties in this respect .
• To run our business in an efficient and proper way. This includes managing our financial position, business capability, planning, communications, corporate governance, and audit.
• Our legitimate interests.
• Complying with regulations that apply to us.
• To exercise our rights set out in agreements or contracts with customers or suppliers who may serve you directly.
• Fulfilling contracts.
•Being efficient about how we fulfil our legal and contractual duties.
Groups of Personal Information
We use many different kinds of personal information, and group them together like this.
Type of personal information
Your financial position, status and history, which may have been obtained in a ‘credit check’ of you as an individual, or your company.
Where you live and how to contact you.
This includes details about your work or profession, nationality, education and where you fit into general social or income groupings.
Details about payments to and from your accounts with us, and any insurance claims you may make for faulty or damaged goods.
Details about the products or services we provide to you.
Data we get about where you are, such as may come from your mobile phone, Live Chat, the address where you connect a computer to the internet.
Details about how you use our products and services and navigate our websites.
Details on the devices and technology you use, such as browsers or operating systems.
What we learn about you from letters, emails, and conversations between us.
Your family, friends, and other relationships, where this information is offered. Example: Please mark this parcel for my son to receive, and a name is given.
Open Data and Public Records
Details about you that are in public records such as the Electoral Register, Linked In, Facebook and other social media, and information about you that is openly available on the internet in a search of your name or company name.
Other data about how you use our products and services.
Details about you, stored in documents in different formats, or copies of them. This could include things like your passport, drivers licence, or birth certificate, if the sale of a product or service required the confirmation of age, such corrosive and dangerous substances.
Special types of data
The law and other regulations treat some types of personal information as special. We will only collect and use these types of data if the law allows us to do so:
Racial or ethnic origin
Religious or philosophical beliefs
Trade union membership
Genetic and bio-metric data
Health data including gender
Criminal convictions and offences
Any permissions, consents, or preferences that you give us. This includes things like how you want us to contact you, whether you get paper invoices or statements, digital invoices or statements or your preference for large-print formats.
A number or code given to you by a government to identify who you are, such as a National Insurance number.
Where we collect personal information from
We may collect personal information about you (or your business) from various areas of BHMA Limited, from the data you give us and from these sources to:
When you purchase a product and/or service
When you talk to us on the phone or on Live Chat
When you use other trading platforms we advertise on such as Amazon, Ebay, Etsy (this list is not intended to be exhaustive)
In emails and letters
In insurance claims for faulty or damaged products
In financial reviews
In customer surveys
If you take part in our competitions or promotions.
Data we collect when you use our services. This includes the amount, frequency, type, location, origin and recipients:
Payment and transaction data.
Profile and usage data. This includes the profile you create to identify yourself when you connect to our websites, mobile and telephone services. It also includes other data about how you use those services. We gather this data from devices you use to connect to those services, such as computers and mobile phones, using cookies and other internet tracking software.
Data from third parties we work with:
Companies that introduce you to us
Credit reference agencies
Other companies that we trade with
Comparison search engines like Google or Bing
Fraud prevention agencies
Public information sources such as Companies House
Loyalty scheme operators
Agents working on our behalf
Government and law enforcement agencies.
Who we share your personal information with
We may share your personal information with employees within BHMA Limited and these organisations:
Agents and advisers who we use to help run your accounts and services, collect what you owe, and explore new ways of doing business
HM Revenue & Customs, regulators and other authorities
Any party linked with you or your business’s product or service
Organisations that introduce you to us
Companies that we introduce you to
Companies you ask us to share your data with
Suppliers who deliver on our behalf
We may need to share your personal information with other organisations to provide you with the product or service you have chosen:
If you use a debit, credit or charge card with us, we will share transaction details with companies which help us to provide this service (such as Visa and Mastercard).
If you have a product which has a loyalty scheme.
If you use direct debits, we will share your data with the Direct Debit scheme.
If you make an insurance claim for faulty or damaged goods, information you give to us or the insurer/carrier may be put on a register of claims. This will be shared with other insurers.
We may choose to sell, transfer, or merge parts of our business, or our assets. Or we may seek to acquire other businesses or merge with them. During any such process, we may share your data with other parties. We’ll only do this if they agree to keep your data safe and private.
If the change to our Group happens, then other parties may use your data in the same way as set out in this notice.
How we use your information to make automated decisions
We sometimes use systems to make automated decisions based on personal information we have – or are allowed to collect from others – about you or your business. This helps us to make sure our decisions are quick, fair, efficient and correct, based on what we know. These automated decisions can affect the products, services or features we may offer you now or in the future, or the price that we charge you for them.
Here are the types of automated decision we make:
We may decide what to charge for some products and services based on what we know about your purchasing volumes.
Tailoring products and services
We may place you in groups with similar customers. These are called customer segments. We use these to study and learn about our customers’ needs, and to make decisions based on what we learn. This helps us to design products and services for different customer segments, and to manage our relationships with them.
We use your personal information to help decide if your personal or business monies may be being used for fraud or money-laundering. We may detect that transactions with us are ways that fraudsters work. Or we may notice that an account is being used in a way that is unusual for you or your business. If we think there is a risk of fraud, we may stop trading with you.
When you open an account with us, we check that the product or service is relevant for you, based on what we know. We also check that you or your business meets the conditions needed to open the account. This may include checking personal age, residency, nationality or financial position, and or the status of your company.
We will supply your first order on a pre-payment basis. Thereafter we will supply on a credit basis to the value of your first transaction with us. Once confidence in your ability to pay outstanding accounts is realised, we can extend the credit value for you.
As a person you have rights over automated decisions.
You can ask that we do not make our decision based on the automated score alone.
You can object to an automated decision, and ask that a person reviews it.
If you want to know more about these rights, please contact us on email@example.com.
Credit Reference Agencies (CRAs)
We carry out credit and identity checks when you apply for an account facility with us for youself or your business. We may use Credit Reference Agencies to help us with this.
We will share your personal information with CRAs and they will give us information about you. The data we exchange can include:
Name, address and date of birth
Company name and address
Director names if applicable
Details of any shared credit
Financial situation and history
Public information, from sources such as the electoral register and Companies House.
We’ll use this data to:
Assess whether you or your business is able to afford to make payments for the products or services received
Make sure what you’ve told us is true and correct
Help detect and prevent financial crime
Manage accounts with us
Trace and recover debts
Make sure that we tell you about relevant offers.
We will go on sharing your personal information with CRAs for as long as you are a customer. This will include details about your settled accounts and any debts not fully repaid on time.
When we ask CRAs about you or your business, they will note it on your credit file. This is called a credit search. Other lenders may see this and we may see credit searches from other lenders.
If you apply for a credit account with someone else, we will link your records with theirs. We will do the same if you tell us you have a spouse, partner or civil partner – or that you are in business with other partners or directors.
You should tell them about this before you apply for a credit account. It is important that they know your records will be linked together, and that credit searches may be made on them.
CRAs will also link your records together. These links will stay on your files unless one of you asks the CRAs to break the link. You will normally need to give proof that you no longer have a financial link with each other.
You can find out more about the CRAs on their websites, in the Credit Reference Agency Information Notice. This includes details about:
Who they are
Their role as fraud prevention agencies
The data they hold and how they use it
How they share personal information
How long they can keep data
Your data protection rights.
Fraud Prevention Agencies (FPAs)
We may need to confirm your identity before we provide products or services to you or your business. Once you have become a customer of ours, we will also share your personal information as needed to help detect fraud and money-laundering risks. We use Fraud Prevention Agencies to help us with this.
Both we and fraud prevention agencies can only use your personal information if we have a proper reason to do so. It must be needed either for us to obey the law, or for a ‘legitimate interest’.
A legitimate interest is when we have a business or commercial reason to use your information. This must not unfairly go against what is right and best for you
We will use the information to:
Help prevent fraud and money-laundering.
Fulfil any contracts you or your business has with us.
We or an FPA may allow law enforcement agencies to access your personal information. This is to support their duty to detect, investigate, prevent and prosecute crime.
FPAs can keep personal information for different lengths of time. They can keep your data for up to six years if they find a risk of fraud or money-laundering.
The information we use
These are some of the kinds of personal information that we use:
Date of birth
History of where you have lived
Contact details, such as email addresses and phone numbers
Data relating to your or your businesses products or services
Data that identifies computers or other devices you use to connect to the internet. This includes your Internet Protocol (IP) address.
Automated decisions for fraud prevention
The information we have for you or your business is made up of what you tell us, and data we collect when you use our services, or from third parties we work with.
We and FPAs may process your personal information in systems that look for fraud by studying patterns in the data. We may find that your account is being used in ways that fraudsters work. Or we may notice that your account is being used in a way that is unusual for you or your business. Either of these could indicate a possible risk of fraud or money-laundering.
How this can affect you
If we or an FPA decide there is a risk of fraud, we may stop activity on your account or block access to your ability to order. FPAs will also keep a record of the risk that you or your business may pose.
This may result in other organisations refusing to provide you with products or services, or to employ you.
Data transfers out of the EEA
FPAs may send personal information to countries outside the European Economic Area (‘EEA’). When they do, there will be a contract in place to make sure the recipient protects the data to the same standard as the EEA. This may include following international frameworks for making data sharing secure.
Sending data outside of the EEA
We will only send your data outside of the European Economic Area (‘EEA’) to:
Follow your instructions.
Comply with a legal duty.
Work with our agents and advisers who we use to help run your accounts and services.
If we do transfer information to our agents or advisers outside of the EEA, we will make sure that it is protected in the same way as if it was being used in the EEA. We’ll use one of these safeguards:
Transfer it to a non-EEA country with privacy laws that give the same protection as the EEA. Learn more on the European Commission Justice website.
Put in place a contract with the recipient that means they must protect it to the same standards as the EEA. Read more about this here on the European Commission Justice website.
Transfer it to organisations that are part of Privacy Shield. This is a framework that sets privacy standards for data sent between the US and EU countries. It makes sure those standards are similar to what is used within the EEA. You can find out more about data protection on the European Commission Justice website.
If you choose not to give personal information
We may need to collect personal information by law, or under the terms of a contract we have with you.
If you choose not to give us this personal information, it may delay or prevent us from meeting our obligations. It may also mean that we cannot perform services needed to run your account of deliver products. It could mean that we cancel a product or service you have with us.
Any data collection that is optional would be made clear at the point of collection.
We may use your personal information to tell you about relevant products and offers. This is what we mean when we talk about ‘marketing’.
The personal information we have for you is made up of what you tell us, and data we collect when you use our services, or from third parties we work with.
We study this 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 can only use your personal information to send you marketing messages if we have either your consent or a ‘legitimate interest’. That is when we have a business or commercial reason to use your information. It must not unfairly go against what is right and best for you.
You can ask us to stop sending you marketing messages by contacting us at any time.
Whatever you choose, you'll still receive statements, and other important information such as changes to your existing products and services.
We may ask you to confirm or update your choices, if you take out any new products or services with us in future. We will also ask you to do this if there are changes in the law, regulation, or the structure of our business.
If you change your mind you can update your choices at any time by contacting us.
How long we keep your personal information
We will keep your personal information for as long as you are a customer of BHMA Limited.
After you stop being a customer, we may keep your data for up to 7 years for one of these reasons:
To respond to any questions or complaints.
To show that we treated you fairly.
To maintain records according to rules that apply to us, such as HMRC (Her Majesty’s Revenue & Customs).
We may keep your data for longer than 7 years if we cannot delete it for legal, regulatory or technical reasons, such as our internal ‘Orderwise’ system. We may also keep it for research or statistical purposes. If we do, we will make sure that your privacy is protected and only use it for those purposes.
How to get a copy of your personal information
You can access your personal information we hold by writing to us at this address:
7-10 Ashley Park,
Letting us know if your personal information is incorrect
You have the right to question any information we have about you that you think is wrong or incomplete. Please contact us if you want to do this.
If you do, we will take reasonable steps to check its accuracy and correct it.
What if you want us to stop using your personal information?
You have the right to object to our use of your personal information, or to ask us to delete, remove, or stop using your personal information if there is no need for us to keep it. This is known as the ‘right to object’ and ‘right to erasure’, or the ‘right to be forgotten’.
There may be legal or other official reasons why we need to keep or use your data, such as trading history for HMRC (Her Majesty’s Revenue & Customs). However; please tell us if you think that we should not be using it.
We may sometimes be able to restrict the use of your data. This means that it can only be used for certain things, such as legal claims or to exercise legal rights. In this situation, we would not use or share your information in other ways while it is restricted.
You can ask us to restrict the use of your personal information if:
It is not accurate.
It has been used unlawfully but you don’t want us to delete it.
It not relevant any more, but you want us to keep it for use in legal claims against us.
You have already asked us to stop using your data but you are waiting for us to tell you if we are allowed to keep on using it.
If you want to object to how we use your data, or ask us to delete it or restrict how we use it, please contact us.
How to withdraw your consent
You can withdraw your consent at any time. Please contact us if you want to do so.
If you withdraw your consent, we may not be able to provide certain products or services to you. If this is so, we will tell you.
How to complain
Please let us know if you are unhappy with how we have used your personal information. You can contact us using our email address firstname.lastname@example.org.
You also have the right to complain to the Information Commissioner’s Office. Find out on their website how to report a concern.
Future formats for sharing data
The Data Privacy laws will change on 25 May 2018. From that date you will have the right to get your personal information from us in a format that can be easily re-used. You can also ask us to pass on your personal information in this format to other organisations.
We are working with our industry to improve the way your data is shared. We’ll update this notice with more details on or after 25 May 2018.