BENCHMARK CAPITAL LIMITED

PRIVACY AND COOKIES POLICY

As the operators of the website http://www.benchmarkcapital.co.uk/ (“Website”), Benchmark Capital Limited (“We“, “Us”) is committed to protecting and respecting your privacy. This Privacy and Cookies Policy (“Policy”) (together with and any other documents referred to therein) sets out the basis on which the personal data collected from you, or that you provide to Us will be processed by Us. Please read the following carefully to understand our views and practices regarding your personal data and how We will treat it.

For the purpose of the General Data Protection Regulation (“GDPR”, from the GDPR implementation date) or, until GDPR implementation date, the Data Protection Act 1998, (collectively the “Data Protection Laws”) the Data Controller is Creative Technologies Limited.

YOUR PERSONAL INFORMATION

Information we collect from you

We collect and process some or all of the following types of information from you in the course of:

Information that you provide by filling in forms on the Website. about or products or services. We may also ask you for information when you contact us by phone or e-mail.
Specifically, personal details such as name, email address, or any information input by you when using the Website.
If you contact Us, We may keep a record of that correspondence.
Details of your access to the Website, including your IP address, information viewed or searched for, page response times, lengths of visit, login information, browser type and version, traffic data, location data, weblogs and other communication data, and the resources that you access, so We may compile statistics relating to your use of the Website.

If you have provided us with the personal data of another person you confirm that they consent to the processing of their personal data and that you have informed them of our identity and the purposes (as set out above or elsewhere) for which their personal data will be processed.

When using our “Contact” form or e-mailing Us, your name and e-mail address are required from you to enable us to respond to your enquiry. We will inform you at the point of collecting information from you, whether you are required to provide any other information to Us.

USES MADE OF YOUR INFORMATION

Lawful basis for processing

Where you have contacted us via the Website, by e-mail or telephone or participated in any surveys, we rely on “legitimate interest” and the legitimate interest is responding and contacting you regarding the enquiries you have made in relation to the services we offer.

Purposes of processing

We use information held about you in the following ways:

To respond to any enquiries you submit to Us;
To ensure that content on the Website is presented in the most effective manner for you and for the device(s) you use to access and view the Website;
To send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
To provide you with information and offers that you request from Us or which We feel may interest you.
To carry out our obligations arising from any contracts entered into between you and Us.
To allow you to participate in interactive features of our service, when you choose to do so.
As part of Our efforts to keep the Website safe and secure.

DISCLOSURE OF YOUR INFORMATION

We may pass your personal data to our third party service providers, agents, subcontractors and other associated organisations for the purposes of: (i) completing tasks on our behalf (e.g. to host our servers) and (ii) storing, protecting and securing your personal data.

We may disclose your personal data to any member of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 (where applicable).

We may also disclose your personal data to third parties:

in the event that We sell or buy any business or assets, in which case We may disclose your personal data to the prospective seller or buyer of such business or assets; or
if We or substantially all of our assets are acquired by a third party, in which case personal data held by Us about our customers will be one of the transferred assets; or
if We are under a duty to disclose or share your personal data in order to comply with any legal obligation; or
to protect Our rights, property, or safety or that of our affiliated entities and our users and any third party We interact with them to provide the Website.

Other than as set out above, and save insofar as is necessary in order for Us to carry out our obligations arising from any contracts entered into between you and Us, We will not share your data with third parties unless We have procured your express consent to do so.

STORING YOUR PERSONAL DATA

Security

We take appropriate measures to ensure that any personal data are kept secure, including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where We are legally required to do so.

Unfortunately, the transmission of information via the internet is not completely secure. Although We will do our best to protect your personal data, We cannot guarantee the security of your data transmitted to the Website; any transmission is at your own risk. Once We have received your information, We will use strict procedures and security features to try to prevent unauthorised access.

Keeping your personal data up to date

If your personal details change you may update them by contacting Us using the contact details below. If you have any questions about how We use data collected which relates to you, please contact Us by sending a request by email to the contact details below.

We will endeavour to update your personal data within 10 days of any new or updated personal data being provided to Us, in order to ensure that the personal data We hold about you is as accurate and up to date as possible.

How long we keep your personal data

If you contact us using our e-mail address or via our website contact form, requesting general information about our services, we will hold personal data you choose to provide such as your name, address, e-mail address, for 12 months from our last point of contact.

If you contact us using our e-mail address or via our website contact form, requesting quotes and information about our services in respect of specific projects, we will hold personal data you choose to provide such as your name, address, e-mail address, for 12 months from our last point of contact.

Data such as IP addresses, traffic data, location data, weblogs and other communication data will be retained for 12 months.

Where we store your personal data

All information We hold about you is stored on our secure servers within the EEA.

The data that We collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA“). 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 held securely and in accordance with this Policy. Countries outside the EEA do not have the same data protection laws as the United Kingdom and EEA and we have therefore ensured that any of our suppliers who may transfer your personal data outside the EEA has put in place appropriate measures to protect your data, either by being a member of the US-EU Privacy Shield, or by entering into a European Commission approved contract (as permitted under Article 46(5) of the General Data Protection Regulation).

If you would like further information please contact Us using the details below. We will not otherwise transfer your personal data outside of the EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.

YOUR RIGHTS

Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:

access to your personal data and to certain other supplementary information that this Policy is already designed to address
require Us to correct any mistakes in your information which We hold
require the erasure of personal data concerning you in certain situations
receive the personal data concerning you which you have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
object at any time to processing of personal data concerning you for direct marketing
object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
object in certain other situations to our continued processing of your personal data
otherwise restrict our processing of your personal data in certain circumstances
claim compensation for damages caused by our breach of any data protection laws.

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

email, call or write to Us using the “Contact” details below;
let Us have enough information to identify you,
let Us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
let Us know the information to which your request relates.

HOW TO COMPLAIN

We hope that We can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.

CHANGES TO OUR PRIVACY POLICY

We reserve the right to modify this Policy at any time. Any changes We may make to our Policy in the future will be notified and made available to you using the Website. Your continued use of the services and the Website shall be deemed your acceptance of the varied privacy policy.

INFORMATION ABOUT OUR USE OF COOKIES AND IP ADDRESSES

We may collect information about your mobile phone, computer or other device from which you access the Website including where available your IP address, operating system and browser type, for systems administration. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual. We may, however, use such information in conjunction with the data We have about you in order to track your usage of our services.

Our Website uses cookies to distinguish you from other users of our Website. This helps Us to provide you with a good experience when you browse our Website and also allows Us to improve the Website. By using our Website you agree to our use of cookies as more specifically set out below.

A cookie is a small file of letters and numbers that We store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

The cookies We use include:

Cookie	Name	Purpose	Expiry of Cookie and Further Information
ctsuite	CTSuite	Single Sign-on	Session
ASP.NET_SessionId	ASP.NET Session cookie	Manage the user’s session	Session
sess_LastRenewTimeStamp	Session Renew	Manage the minutes remaining in the session to give the user a warning when the session will expire	1 week
sess_RemainingMinutes	Session Renew	Manage the minutes remaining in the session to give the user a warning when the session will expire	1 week
__utma	Google Analytics	Used to distinguish users and sessions. The cookie is created when the javascript library executes and no existing __utma cookies exists. The cookie is updated every time data is sent to Google Analytics.	2 years from set/update
__utmt	Google Analytics	Used to throttle request rate.	10 minutes
__utmb	Google Analytics	Used to determine new sessions/visits. The cookie is created when the javascript library executes and no existing __utmb cookies exists. The cookie is updated every time data is sent to Google Analytics.	30 mins from set/update
__utmc	Google Analytics	Not used in ga.js. Set for interoperability with urchin.js. Historically, this cookie operated in conjunction with the __utmb cookie to determine whether the user was in a new session/visit.	End of browser session
__utmz	Google Analytics	Stores the traffic source or campaign that explains how the user reached your site. The cookie is created when the javascript library executes and is updated every time data is sent to Google Analytics.	6 months from set/update
__utmv	Google Analytics	Used to store visitor-level custom variable data. This cookie is created when a developer uses the _setCustomVar method with a visitor level custom variable. This cookie was also used for the deprecated _setVar method. The cookie is updated every time data is sent to Google Analytics.	2 years from set/update

Please note that third parties affiliates may also use cookies, over which We have no control.

You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon as you visit our Website.

CONTACT

All questions, comments and requests regarding this Privacy and Cookies Policy should be addressed to enquiries@benchmarkcapital.co.uk, or write to Us at Benchmark Capital Limited, Sussex House, North Street, Horsham RH12 1RQ.