Privacy Policy

We respect your privacy and are committed to using any personal data that we hold responsibly and respectfully. This Privacy Policy aims to give you information on how we at Big City Swing, Inc. collect and process your personal data through your use of the website http://bigcityswing.com.

This Privacy Policy outlines how, when and why we collect your personal information. We’ll also tell you about your privacy rights and how the data protection law protects you.

  1. WHO WE ARE AND IMPORTANT INFORMATION
  2. THE PERSONAL DATA WE COLLECT ABOUT YOU
  3. HOW WE COLLECT YOUR PERSONAL DATA
  4. HOW WE USE YOUR PERSONAL DATA
  5. WHO WE SHARE YOUR PERSONAL DATA WITH
  6. INTERNATIONAL TRANSFERS
  7. DATA SECURITY
  8. DATA RETENTION
  9. YOUR LEGAL RIGHTS
  10. CHANGES TO THIS NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
  11. QUERIES, REQUESTS OR CONCERNS

1. WHO WE ARE AND IMPORTANT INFORMATION

What is the purpose of this privacy policy?

This privacy policy aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you sign up to our Newsletter, submit a form, purchase a product, use a link to go to another page or website. This website is not intended for children and we do not knowingly collect data relating to children. You must read this privacy policy together with any other privacy policy 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. This privacy policy supplements the other policies and is not intended to override them.

Contact Details

Full name of legal entity: Big City Swing, Inc.

Contact email address: admin@bigcityswing.com

Third-party links outside of our control

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 policies.

When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. THE PERSONAL DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioners Office.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data including your name and title.
  • Contact Data including your email address.
  • Technical Data such as your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Usage Data such as information about how you use our website, which pages you visit and for how long.
  • Marketing and Communications Data may include your preferences in receiving marketing communications from us and your communication preferences.

We may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your Usage Data to work out the percentage of website users using a specific feature of our site. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.

We do not 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 do we collect any information about criminal convictions and offenses.

3. HOW WE COLLECT YOUR PERSONAL DATA

We collect your personal information when you:

  • Send a Contact Form through the website
  • Request a specific download or resource through a form on the website
  • Sign up to the E-Newsletter Mailing List
  • Use our site. We may automatically collect Technical Data about your equipment, browsing actions and usage patterns. We collect this data by using cookies, server logs and similar technologies. See our Cookie Policy below for further details.

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:

To carry out our business and provide you with a service requested by you:

  • To send you email communications (only if you have opted-in) including the newsletter, information of legitimate interest to you, and our products and/or services.
  • To respond to your Contact Form
  • To update you with important information on our business including updates to the Privacy Policy

Where we believe there is legitimate interest:

  • Legitimate Interest this means the interest of our business in conducting and managing our business to enable us to give you the best service and the 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).

Comply with a legal or regulatory obligation:

  • Processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

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, with the legal basis we rely on to do so.

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.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To deliver our E-Newsletter and relevant content to you

(a) Identity

(b) Contact

(c) Technical

Consent

To manage our relationship with you which will include:

Notifying you about changes to our terms or privacy policy

(a) Identity

(b) Contact

(c) Marketing and Communications

Necessary to comply with a legal obligation

To respond to a Contact Form you submit through the website

(a) Identity

(b) Contact

Legitimate Interest

To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(c) Technical

Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud

Necessary to comply with a legal obligation

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests to keep our site updated and relevant, to develop our business and to inform our marketing strategy

Cookies

This website uses cookies which are text files which are placed on your computer to collect standard internet log information and visitor behaviour information.

We use technologies, such as cookies, to customise content and advertising, to provide social media features and to analyse traffic to the site. We also share information about your use of our site with our trusted social media, advertising and analytics partners.

We also use this information to track visitor use of the website and complete statistical reports on website activity. The information is all anonymous and includes the number of visitors to the Site, where visitors have come to the Site from and the pages they look at, how they use the pages, how long they spend on them. We use this information to know if our platforms are working as intended, as well as understanding how our users are getting to our site.

We only use Cookies from Google Analytics, Facebook, and Hotjar.

For further information visit www.aboutcookies.org or www.allaboutcookies.org

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies and the above websites will tell you how to do this as well as how to remove cookies from your browser. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

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 at admin@bigcityswing.com.

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. WHO WE SHARE YOUR PERSONAL DATA WITH

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.

External Third Party Services such as:

  • Service Providers who provide email marketing platforms, marketing automation platforms, web designers, IT and System Administration services.
  • Professional advisers including lawyers, accountants, marketers, and insurers who provide legal, accounting, professional, and insurance services.
  • HM Revenue & Customs, regulators and other authorities in the United Kingdom who require reporting of process activities in certain circumstances.

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. We never sell or rent your personal data.

6. INTERNATIONAL TRANSFERS

Some of our third party service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
  • Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
  • Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

Please email us at admin@bigcityswing.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

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 unauthorized 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

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data:

  • The right to request a copy of the personal data which we hold about you;
  • The right to request that we correct any personal data if it is found to be inaccurate or out of date;
  • The right to request your personal data is erased where it is no longer necessary to retain such data;
  • The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data;
  • The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), where applicable i.e. where our processing is based on consent or is necessary for the performance of our contract with you or where we process your data by automated means);
  • The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
  • The right to object to our processing of personal data, where applicable i.e. where processing is based on our legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct marketing or processing for the purposes of scientific/historical research and statistics).

You can see more about these rights at:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of the rights set out above, please email us at admin@bigcityswing.com

No fee required – with some exceptions

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 admin 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.

10. CHANGES TO THIS NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

We reserve the right to change this policy at any time. However, we will not change the way we use your personal information without telling you in advance and giving you the chance to opt out of or prevent the new use of your information.

Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.

11. QUERIES, REQUESTS OR CONCERNS

If you have any questions about this privacy policy, you can contact admin@bigcityswing.com

Last updated: May 2018

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