Privacy Policy – BlueSpan Global

Introduction

BlueSpan Global ("we", "us" or "our") is committed to protecting your personal information and respecting your privacy. This Privacy Policy explains how we collect, use, store and share personal data and the rights you have under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Who We Are

Business Name: BlueSpan Global
Website: www.bluespanglobal.com
Email: info@bluespanglobal.com

BlueSpan Global provides consultancy and related professional services to businesses, including support relating to international markets and business development.

What Personal Data We Collect

Depending on your relationship with us and the services you require, we may collect and process:

Names and contact details
Business and postal addresses
Purchase and account history
Payment details, including bank or payment information
Records of meetings, discussions and decisions
Information relating to enquiries, feedback and complaints
Website usage information, including information about website journeys and cookies
Information supplied during consultations or assessments

During consultancy engagements, we may also receive commercially confidential information about a client's business, such as information about its products, services, operations and trading history. Although information relating solely to a company is not necessarily personal data, information concerning identifiable directors, employees, contractors or other individuals may constitute personal data and will be protected accordingly.

Why We Collect and Use Personal Data

We may use personal information to:

Provide our consultancy services
Respond to enquiries and assess prospective client requirements
Manage client relationships and accounts
Communicate with clients about the services they receive
Maintain records of meetings and decisions
Process payments and maintain appropriate business records
Provide service updates
Send marketing communications where permitted
Conduct appropriate research to support consultancy engagements
Maintain records for business, research or archiving purposes
Work with specialist consultants or international partners where required to provide services

We will only use personal information for purposes that are compatible with the reason it was originally collected, unless we have a lawful reason to use it for another purpose.

Lawful Bases for Processing

Depending on the circumstances, we rely on one or more of the following lawful bases:

Consent – where you have given us permission to process your information for a particular purpose.
Contract – where processing is necessary to enter into or perform a contract with you.
Legitimate Interests – where processing is necessary for our legitimate business interests or those of a third party, provided those interests are not overridden by your rights and freedoms.

For example, we may rely on legitimate interests to maintain appropriate records of client discussions, manage business relationships, understand the requirements of prospective clients and undertake activities reasonably necessary to provide our consultancy services.

Legitimate Interests

During the course of assessing or delivering services, we may need to record information about a client's business, including its products, services, requirements and trading history.

Our legitimate interest is to maintain sufficient information to understand our clients' requirements, provide appropriate professional advice and manage our consultancy relationships effectively.

We recognise that some of this information may be commercially sensitive. We therefore limit the information we collect to what is reasonably necessary and take appropriate measures to protect it.

We do not disclose commercially confidential information to competitors or unrelated organisations without appropriate authority.

Where we need to work with another consultancy, specialist or international partner, we will only share relevant information where there is an appropriate reason and lawful basis to do so. Where appropriate, we will seek the client's permission before making a referral or disclosure.

Where We Obtain Personal Data

We obtain personal information from:

Individuals directly
Directors and employees of prospective and existing client organisations
Interviews and meetings with client team members
Publicly available sources

Information obtained during interviews or consultancy engagements will be recorded and retained securely where necessary to provide our services and maintain appropriate business records.

Sub-Processors and Systems

We use third-party technology providers to support the operation of our business.

These currently include:

Wix – website hosting, website management and enquiry/contact forms

Depending on the services required, we may also engage professional consultants, specialist consultancies, legal advisers or overseas business partners.

Where another organisation processes personal data on our behalf, we will take reasonable steps to ensure appropriate contractual and data protection arrangements are in place.

Sharing Personal Data

We do not sell personal information.

Where necessary and lawful, personal information may be shared with:

Professional consultants
Specialist consultancies
Professional or legal advisers
International business partners where their expertise is required for a client engagement
Service providers processing information on our behalf
Regulatory, law enforcement or other authorities where disclosure is required by law

Where we engage another consultancy because specialist expertise is required, or make a referral to another organisation, relevant information will only be disclosed where there is an appropriate lawful basis and, where applicable, with the client's permission.

International Data Transfers

As part of our international consultancy activities, personal information may sometimes need to be shared with trusted partners located outside the United Kingdom. For example, this may occur where a client wishes to explore or enter an overseas market and assistance from an established partner within that country is required.

Some of our technology and service providers, including Wix, may also process or store personal information outside the UK.

Where personal data is transferred internationally, we will ensure that an appropriate legal mechanism is in place in accordance with UK data protection law.

Depending on the destination and circumstances, this may include:

UK adequacy regulations;
the UK International Data Transfer Agreement (IDTA);
the UK Addendum to the EU Standard Contractual Clauses (SCCs);
applicable Standard Contractual Clauses; or
another legally recognised international transfer mechanism.

Where appropriate, we will also consider whether additional technical, contractual or organisational safeguards are necessary to protect personal information.

Data Retention

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected.

Retention periods will take account of:

The duration of our relationship with the client
The nature of the consultancy services provided
Contractual requirements
Applicable legal, tax and accounting requirements
The need to maintain appropriate professional records
The establishment, exercise or defence of legal claims

Information that is no longer required will be securely deleted, destroyed or anonymised.

Data Security

We take appropriate technical and organisational measures to protect personal information against accidental or unlawful loss, alteration, disclosure, destruction or unauthorised access.

Measures may include:

Access controls
Password-protected accounts and systems
Appropriate security controls provided by our technology suppliers
Limiting access to information to those who reasonably require it
Secure handling and storage of client records
Appropriate confidentiality arrangements with consultants and business partners

Marketing

We may use your contact information to provide relevant information about our services where you have consented or where another lawful basis permits us to do so.

You can ask us to stop sending direct marketing communications at any time by contacting us at info@bluespanglobal.com or by using an unsubscribe option included in a marketing email.

Cookies and Website Information

Our website may use cookies and similar technologies to operate correctly, understand how visitors use the website and improve the user experience.

Where cookies are not strictly necessary for operation of the website, we will obtain consent where required by law.

Further information about the cookies used on our website should be provided through our cookie notice or cookie settings.

Your Data Protection Rights

Depending on the circumstances, UK data protection law gives you rights including:

The right to be informed about how your information is used
The right to access personal information we hold about you
The right to have inaccurate or incomplete information corrected
The right to request deletion of your personal information in certain circumstances
The right to request restriction of processing
The right to object to certain processing, including direct marketing
The right to data portability where applicable
The right to withdraw consent at any time where processing is based on consent

These rights are not absolute and may depend upon the circumstances and the lawful basis under which information is processed.

To exercise your rights, please contact us at info@bluespanglobal.com.

How to Complain

If you have concerns about how we use your personal information, please contact us first at:

BlueSpan Global
Email: info@bluespanglobal.com

We will aim to investigate and resolve your concerns.

You also have the right to complain to the UK's independent data protection regulator:

Information Commissioner's Office (ICO)
Website: https://www.ico.org.uk
Telephone: 0303 123 1113

Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to our services, suppliers, business activities or legal obligations.

The latest version will be made available through our website.