BLME is committed to safeguarding the privacy of personal data and is bound to comply with the UK Data Protection Act 1998, along with similar and applicable laws in other countries around the world. This Privacy Notice forms part of BLME’s obligation to be open and fair with all individuals whose personal data we process and to provide details around how we process such personal data and what we do with it.
We process the personal data of our customers and clients such as name, data of birth, contact details and email address, passport and national insurance number, amongst other things. Processing of this data implies collecting, storing, using or disclosing your personal data.
If you receive other products or services from BLME, or use any of our specific websites or applications, you may be provided with further privacy notices which may be contained in a separate supplemental policy or within any terms and conditions. These additional privacy notices shall supplement this Privacy Notice.
This Privacy Notice relates to the processing of personal data by BLME and any of its subsidiaries. Unless otherwise stated, all references to “we” or “our” shall imply all BLME lines of business that process personal data.
None of the lists or examples provided in this Privacy Notice is intended to be exhaustive or fully representative of every individual.
The scope of this Privacy Notice covers client and customer personal data in respect of the following: -
- Collecting Personal Data
- Using Personal Data
- Disclosing Personal Data
- Retaining Personal Data
- Securing Personal Data
- International Data Transfers
- Subject Access Requests
- Updates / Amendments
- Third Party Websites
- Opt-in / Opt-out
- Our Details
3. Collecting Personal Data
We may collect and store the following kinds of personal data:
- Information about your computer and about your visits to the BLME website, including your IP address, geographical location, browser type and version.
- Information that you provide to us when applying though our website.
- Information that you provide to us for the purpose of subscribing to our marketing communications.
- Information that you provide to us when using any services we provide, or that is generated in the course of the use of those services.
- Information that you post on our social media platforms.
- Information contained in or relating to any communication that you send to us through our website, email or in writing.
- Information that you provide as part of performing money laundering, financial and credit checks as well as for fraud and crime prevention and detection purposes.
- Information related to the security and access of our systems and applications.
- Information to help us comply with our legal and regulatory obligations, including reporting to and being audited by regulators and external auditors.
- Information to help us comply with court orders and to exercise and defend our legal rights.
- Any other personal information that may be sent to us and which we use for legitimate business purposes.
Before you disclose to us the personal information of another person, you must obtain that person's consent to both the disclosure and the processing of that personal information in accordance with this Privacy Notice.
4. Using Personal Data
We may use your personal information to:
- Administer, personalise and secure our website.
- Enable your use of any services that we may provide through our website.
- Supply you with our products and services.
- Send statements, invoices and payment reminders to you or collect payments from you.
- Send you marketing communications.
- Deal with enquiries and complaints.
- Perform money laundering, financial and credit checks.
- Ensure appropriate access to systems and applications.
- Comply with our legal and regulatory obligations.
5. Disclosing Personal Data
We only disclose your personal data in the ways set out in this Privacy Notice or subject to any agreements in place between us. The following circumstances may apply:
- Across our different lines of business, as part of a need to know or as part of improving our existing products and services or as part of providing new services.
- To third parties who process personal data on our behalf.
- To third parties who process personal data on their own behalf but provide us, or you, with a service on behalf of us.
- To third parties with whom information is shared for money laundering checks, credit risk reduction and other fraud and crime prevention purposes.
- To any prospective buyer in the event we sell any part of our business, or its assets, or if substantially all of our assets are acquired by a third party.
- To any regulator, external auditor or applicable body or court where we are required to do so by law or regulation or as part of any investigation.
- To any central or local government department and other statutory or public bodies, such as HMRC.
We do not sell, rent or trade any of your personal data.
We will not, without your consent, disclose or supply your personal data to any third party for the purpose of their or any other third party's direct marketing.
6. Retaining Personal Data
Personal data that we process, for any purpose or purposes, shall not be kept for longer than is necessary. BLME bases its record retention on any legal, regulatory or contractual obligations.
7. Securing Personal Data
Where BLME acts as the controller of personal data, it will ensure that necessary and adequate safeguards are in place to prevent unauthorised access, loss, misuse or alteration of your personal data.
We store all personal information on secure servers with relevant access and firewall controls.
All applications processed through our website are encrypted.
Any personal data sent to us, either in writing or email, may be insecure in transit and we cannot guarantee its delivery.
Passwords must be kept confidential and not disclosed to a third party. BLME does not ask you for your password.
8. International Data Transfers
Personal data that we collect, is predominantly stored in the UK, but may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this Privacy Notice.
You expressly consent to the transfers of personal data described in this section.
9. Subject Access Requests
You may instruct us to provide you with any personal data we hold about you as part of a Subject Access Request. The provision of such information will be subject to:
- The payment of a fee (currently GBP £10); and
- Appropriate evidence of your identity, such as a passport, driving licence as well as a recent bank statement or utility bill.
In certain instances, where exemptions exist, we may withhold personal data that you request and which are permissible by law.
You may wish to contact us if the personal data that we hold about you needs to be corrected or updated.
You may instruct us at any time not to process your personal data for marketing and communications purposes by means of ‘opting-out’.
In certain instances, owing to the nature of how certain products and services are offered, you may not have expressly agreed in advance to the use of your personal data for marketing purposes (‘opting-in’). However, any marketing and communication material we send to you will have the option to ‘opt-out’.
10. Updates / Amendments
In order to remain compliant with any legal and regulatory obligations, or as part of our evolving business practices, we may update this Privacy Notice from time to time by publishing a new version. In certain instances, we may notify you.
11. Third Party Websites
We are not responsible for the practices employed by Third Party Websites linked to or from our Website nor the information or content contained therein. Often links to other websites are provided solely as reference points to information on topics that may be useful to the users of our Website. Please remember that when you use a link to go from our Website to a Third Party Website, our Privacy Notice will no longer apply. Your browsing and interaction on any other Website, including Third Party Websites, which have a link on our Website, are subject to that Website's own Privacy Notice.
13. Opt-in / Opt-out
You have the right, at any time, to ask us not to process your personal data for marketing purposes.
You can opt-out of receiving email communications simply by clicking the unsubscribe link, which is contained within marketing emails.
Please note it can take up to 30 days for a request to be fulfilled because of pre-planned or ongoing marketing activity.
14. Data Protection Registration
We are registered as a data controller with the UK Information Commissioner's Office and our data protection registration number is Z9829862.
15. Our Details
BLME is registered in England and Wales under company number 05897786.
Its registered office is at Cannon Place, 78 Cannon Street, London, EC4N 6HL, United Kingdom.
You can contact us as follows: -
Telephone: (Head Office) +44 (0) 20 7618 0000
In Writing: Data Protection Officer
78 Cannon Street