Bulletproof privacy notice

Bulletproof Cyber Ltd take the protection of your personal data very seriously and strictly adhere to the rules laid out by data protection laws and the General Data Protection Regulation (GDPR-EU and GDPR-UK).

This privacy notice gives you information on how we collect and process your personal data through your use of this site and any data you may provide if you contact us regarding our products and services.

We have appointed a data protection officer (DPO) who is responsible for monitoring and providing guidance with our GDPR status. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the contact information in section 15 of this privacy notice.

Personal Information is any personal identifiable information, such as your email address, name, home or work address, telephone number, bank details or online identifier, which can directly or indirectly identify you. We refer to it as "Person al Information" here.

We collect your personal data for one of the following purposes:

• To manage communications between you and us
• Where we need to perform the contract we have entered into with you
• To process payments
• To provide you with information you have requested, or which we may feel may be of interest to you
• To ensure the safe operation of our website and to monitor the performance of our website
• For marketing and advertising purposes
• To provide access to trials
• To conduct surveys and solicit customer feedback

We only collect and use personal information about you when the law allows us to. Most commonly, we use it where:

• The data subject (you) has given consent to the processing activity taking place.
• if the processing is necessary for the performance of a contract
• If the processing is necessary for compliance with a legal obligation to which the controller is subject
• If the processing is necessary for the purpose of the legitimate interest pursued by us or our partners.

Where legitimate interest is identified as a lawful basis, we will undertake a legitimate interest assessment which is a three- part test covering:

The purpose test – to identify the legitimate interest

Necessity test – to consider if the processing is necessary for the purpose identified

Balancing test – considering the individual’s interests, rights or freedoms and whether these override the legitimate interests identified.

We collect personal information from you, for example, if you register to our website, use the website, provide information on the website, request product information, call us (your call my be recorded), email us, interact with us on social media or use any of our services. The personal information that we may collect, store and use about you may include:

• Name
• Address
• Billing address
• Telephone number
• Job title
• Email address
• Chat conversations on the website
• Voice calls
• Fax number
• IP addresses
• Transactional information about the services you use and how you interact with us and the services e.g. services viewed, page response times, download errors, length of visit, scrolling, clicks and mouse overs
• Browser type
• Browser language
• Operating system
• Device type
• Time zone
• Communication preferences
• Payment information (we do not store card data and are PCI DSS compliant)

We may use technologies, such as tracking pixels to collect some of the above information from emails we send you. This helps us to focus our marketing to your requirements and provide more relevant emails to you. It also helps us to identify if you are not engaged with our marketing emails.

We may also collect business contact information from third parties such as ZoomInfo.

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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 d ata, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

We take the responsibility for protecting your privacy very seriously and we will ensure your data is secured in accordance with our obligations under the Data Protection laws. We have in place technical and organisational measures to ensure personal information is secured and to prevent your personal data from being accessed in an unauthorised way, altered or disclosed. We have in place a robust access control policy which limits access to your personal data to those employees, contractors and other third parties who only have a business need to know. The processing of your personal data will only take place subject to our instruction.

We have policies and procedures to handle any potential data security breaches and data subjects, third parties and any applicable regulators will be notified where we are legally required to do so.

Bulletproof Cyber Ltd is ISO 27001 certified and has also achieved Cyber Essentials and Cyber Essentials Plus Certification. The scope of all these certifications include all activities the company performs while trading as Bulletproof. The organisation is also PCI DSS compliant.

We have ensured that all employees have had information security and data protection training. If you would like more details of the security we have in place, please see "additional information", section 17 of this policy.

Any payment transactions are encrypted using SSL technology. Where we have given you (or where y ou have chosen) a password which enables you to access certain parts of the site, you are responsible for keeping this password confidential. We ask that you do not share passwords with anyone.

Unfortunately, the transmission of information via the Interne t is not completely secure so we cannot guarantee the security of your information when it is transmitted to our website or from third party websites, any transmission is at your own risk, however we use strict procedures and security features to prevent u nauthorised access.

The site may from time to time contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, we cannot accept any responsibility or liability and you will have to agree to such company’s privacy notice. Please ensure you agree to such policies before submitting your personal data.

We acknowledge that the information you provide may be confidential. We do not sell, rent, distribute or otherwise make Personal Information commercially available to any third party, but we may share information with our service providers for the purposes set out in this Privacy Notice. We will keep your information confidential and protect it in accordance with our Privacy Notice and all applicable laws.

We do not knowingly collect information on children. If we have collected personal information on a child, please contact us immediately using the details in section 15, so we can remove this information without any undue delay.

In this Section, we have summarised the rights that you have under General Data Protection Regulation. Some of the rights are complex, and not all 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 General Data Protection Regulation are:

• Right to Object
• Right of Access
• Right to be informed
• Right to Rectification
• Right to Erasure
• Right to Restrict Processing
• Right to Data Portability

The right to object

You can exercise this right if

• Processing relies on legitimate interest
• Processing is for scientific or historical research
• Processing includes automated decision making and profiling
• Processing is for direct marketing purposes

The right of access

• You or any third party acting on your behalf with your authority may request a copy of the personal data we hold about you without charge.
• We will ask to verify your identity or request evidence from the third party that they are acting on your behalf before releasing any personal data we hold about you.

The right to be informed

• We are required, to provide clear and transparent information to you about how we process your personal data. This privacy notice addresses this right.

The right of rectification

• If you believe the personal data we hold about you is incorrect or incomplete you have the right to correct this and you may exercise this right along with the right to restrict processing until these corrections are made.

The right to erasure

• If there is no legal basis or legitimate reason for processing your personal data, you may request that we erase it.

The right to restrict processing

You may ask us to restrict the processing of your personal data. This means we will still hold it but not process it. This is a conditional right which may only be exercised when:

• Processing is unlawful
• We no longer need the personal data, but it is required for a legal process
• You have exercised your right to object to processing and require processing to be halted while a decision on the request to object is made.
• If you are exercising your right to rectification

The right to data portability

You can request that your personal data is transferred to another controller or processor in a machine-readable format if:

• Processing is based on consent
• Processing is by automated means (i.e. not paper based)
• Processing is necessary for the fulfilment of a contractual obligation

If you have any question about these rights, please see "additional information", section 17 of this policy.

Where you have given consent for processing, or explicit consent in relation to the processing of special category data, you have the right to withdraw this consent at any time, but this will not affect the lawfulness of processing based on consent before its withdrawal.

Where we need to collect personal data by law or in order to process your instructions or perform a contract we have with you and you fail to provide that data when requested, we may not be able to carry out your instructions or perform the contract we have or are trying to enter into with you. In this case, we may have to cancel our engagement or contract you have with us, but we will notify you if this is the case at the time.

Our website uses cookies. Please see our cookies policy for full details of the cookies used.

Your personal data is not used in any automated decision making (a decision made solely by automated means without any human involvement).

Bulletproof may disclose your personal data, listed in section 4 to some third parties to help us deliver our services/products. All third parties are contractually bound to protect the personal data we provide to them. We may use several or all of the following categories of recipients:

• Business partners, suppliers, contractors for the performance of any contract we enter into with them or you
• Companies within our group where necessary for administrative purposes and to provide services to you
• hird parties that support us to provide products and services e.g. IT support, hosting providers, cloud-based softwareservices, providers of telecommunications equipment
• Marketing/PR services providers
• Payment service providers
• Recruitment service providers
• Professional advisors e.g. lawyers, auditor
• Web analytics and search engine provider to ensure the continued improvement and optimisation of our website.

In this section, we provide information about the circumstances in which your personal data may be transferred and stored in countries outside the UK or European Economic Area (EEA).

We may share personal information to third parties outside of the UK or European Economic Area (EEA). Any personal information transferred will only be processed on our instruction and we ensure that information security at the highest standard would be used to protect any personal information as required by the Data Protection laws.

Where personal data is transferred outside of the EEA to a country without an adequacy decision, we will ensure appropriate safeguards are in place prior to the transfer. These could include:

• Standard Contractual Clauses
• Binding Corporate Rules
• An exception as defined in Article 49 of the EU GDPR

For more information about transfers and safeguarding measures, please contact us using the information in section 17.

We take any complaints about our collection and use of personal information very seriously.

If you think that our collection or use of personal information is unfair, misleading, or inappropriate, or have any other concern about our data processing, please raise this with us in the first instance.

To make a complaint, please contact us via email on dpo@bulletproof.co.uk

By Post: Unit 13, Gateway 1000, Whittle Way, Stevenage, Herts, SG1 2FP

By Phone:+44(0)1438 500096

Alternatively, you can make a complaint to the Information Commissioner’s Office:

By Post: Information Commissioners Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

By Website: Click Here

By Email: Click Here

By Phone: 0303 123 1113 (local rate) or 01625 545 745 (National rate)

For customers based in the EU, you may contact our representative at eu@bulletproof.co.uk.

Your trust is important to us. That is why we are always available to talk with you at any time and answer any questions concerning how your data is processed. If you have any questions that could not be answered by this privacy policy or if you wish to receive more in-depth information about any topic within it, please contact our DPO and Compliance Team via email on dpo@bulletproof.co.uk