Privacy and cookie policy

Last updated January 2023.

We respect your privacy and are committed to protecting your personal data. This policy explain the terms on which we collect and process your personal data, and how we protect your personal data when you visit our websites at www.bwcaberdeen.co.uk you engage with us, you sign up to our membership , you purchase an event, you sign up to our mailing list or otherwise use our services. In addition, it explains your privacy rights and how the law protects you. 

  1. Who we are

This is the privacy and cookie policy of BWCAberdeen TA as Granite City Connections a company registered in Scotland under company number SC767215 with its registered office at Stonehaven (“we” or “us”). We are the controller responsible for your personal data.

We comply with our obligations under the EU law retained version of the General Data Protection Regulation (EU) (2016/679) and the UK Data Protection Act 2018 (“data protection laws”). If any of these laws are replaced or superseded, will also comply with that those.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance by emailing karen@bwcaberdeen.co.uk


  1. The data we may collect about you

Personal data/information means any information about an individual from which that person can be identified. It doesn’t include anonymous data. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

  • Contact Data includes billing address, delivery address, email address and telephone numbers.

  • Financial Data includes bank account and payment card details.

  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

  • Technical Data includes internet protocol (IP) address, your login data, 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 our websites. 

  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.  

  • Usage Data includes information about how you use our websites, products, and services. 

  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Aggregated Data such as statistical or demographic data for any purpose, isn’t considered personal data in law as this data will not directly or indirectly reveal your identity. We may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. 

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). We also don’t collect any information about criminal convictions and offences.

  1. How is your personal data collected?

We may use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity and Contact by filling in forms or by corresponding or engaging with us by post, phone, email, social media or otherwise. 

  • Automated technologies or interactions. As you interact with our websites, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources, such as Google, Companies House, or the electoral register.

  1. How we use your personal data

We will only use your personal data when we can rely on a legitimate (lawful) basis, such as:

  • Where we need to perform the contract, we are about to enter into or have entered into with you.

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

  • Where we need to comply with a legal obligation.

  1. Purposes for which we will use your personal data

We have set out below the ways we may use your personal data, and which of the legitimate bases we rely on to do so:





Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To enable you to submit an enquiry to us, whether via email, through our websites or via social media, including but not limited to LinkedIn, Facebook and Instagram. 

Identity 

Contact

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to enable us to respond to your enquiry)

To register you as a new customer of our services, such as signing up to our membership.

Identity 

Contact

(a) Performance of a contract with you

To process and deliver the services, such as our membership or our events, to you including:

(a) Manage payments, fees, and charges

(b) Collect and recover money owed to us

Identity 

Contact 

Financial 

Transaction 

Marketing and Communications

(a) Performance of a contract with you 

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

Identity 

Contact 

Profile 

Marketing and Communications

(a) Performance of a contract with you 

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a prize draw, competition or complete a survey

Identity 

Contact 

Profile 

Usage 

Marketing and Communications

(a) Performance of a contract with you 

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To enable you to register for our mailing list/email marketing

Identity

Contact

Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to enable us to provide you with the newsletter/email marketing and present you with information, goods or services we consider you will be interested in)

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

Identity

Contact

Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

Identity 

Contact 

Profile 

Usage 

Marketing and Communications 

Technical 

(a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

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

Technical 

Usage 

(a) Necessary for our legitimate interests (to define types of customers for our products and services, to keep our websites updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

Identity 

Contact 

Technical 

Usage 

Profile 

Marketing and Communications

(a) Necessary for our legitimate interests (to develop our products/services and grow our business)

  1. Marketing 

You may receive marketing communications from us if you have requested information from us or purchased goods or services from us and you haven’t opted out of receiving that marketing. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. 

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. 

Where you opt out of receiving these marketing messages, this won’t apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

  1. Cookies

Our websites use cookies in accordance with the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 and data protection legislation to distinguish you from other users of our websites. This helps us to provide you with a good experience when you browse our websites and also allows us to improve our websites. 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.

We use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our websites. They include, for example, cookies that enable you to log into secure areas of our websites, use a shopping cart or make use of e-billing services.

  • Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our websites when they are using it. This helps us to improve the way our websites work, for example, by ensuring that users are finding what they are looking for easily.

  • Functionality cookies. These are used to recognise you when you return to our websites. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

  • Targeting cookies. These cookies record your visit to our websites, the pages you have visited and the links you have followed. We will use this information to make our websites and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Please note that third parties may also use cookies, over which we have no control. These named third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third-party cookies are likely to be analytical cookies or performance cookies or targeting cookies:

  • Google Analytics – this is a web analytics service provided by Google, Inc. The cookies used by Google Analytics help us to analyse how users use our websites and to count the number of people who use it. Google Analytics stores your IP address anonymously. Google does not associate your IP address with any personally identifiable information;

  • Facebook Ads (the Facebook pixel) – these cookies collect information about how visitors use our websites. This data is collected anonymously and is used to help improve our websites’ functionality; and

  • Google Ad Words – these cookies collect information about how visitors use our websites. This data is collected anonymously, to help make our marketing communications more relevant, and is used to improve our websites’ functionality.

We will always ask for your consent to use non-essential cookies. You are free to withhold consent to this, but it means that we might not be able to provide the full website experience to you, including some elements of video advertising. If at any time you wish to disable our cookies, you can do so through the settings on your browser, or whenever the pop-up appears on the website (each time you access the website).

  1. Disclosures of your personal data

We may disclose your information in the following cases:

  • If we want to sell our business, or our company, we can disclose it to the potential buyer

  • We can disclose it to other businesses in our group, as defined in the UK Companies Act 2006

  • We can disclose it if we have a legal obligation to do so, or in order to protect other people’s property, safety, or rights

  • We can exchange information with others to protect against fraud or credit risks.

We may contract with third parties to supply services to you on our behalf. These include:

  • Credit card processing services

  • Order fulfilment service providers

  • Analytics service providers

  • Event/campaign management service providers

  • Website management service providers

  • Information technology and related infrastructure provision

  • Email delivery services

  • Our auditors and legal advisors. 

These third parties are known as sub-processors. Where we share your personal data with those sub-processors, they will be bound by confidentiality and data protection obligations. We do this to ensure that your personal data is kept safe and secure. 

  1. Data security

Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure data we collect. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business 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.

If there is an incident where we become aware that there has been a data breach, we will let you know without undue delay. We will then take all necessary steps, including informing the ICO, to limit the extent of the breach and to prevent a further reoccurrence.

  1. International transfers

We may transfer your personal data outside of the European Economic Area (EEA) or the UK where we engage third parties to provide services on our behalf, such as to receive services or deal with payment. Whenever we transfer your personal data out of the EEA or the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented, such as only transferring your personal data to countries that have been deemed to provide an adequate level of protection for personal data. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA or the UK.

  1. Data retention

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. The appropriate retention period will vary depending on the type of personal data collected. 

  1. Your legal rights

Under certain circumstances, you have rights under the data protection legislation in relation to your personal data: 

  • Request access to your personal data.

  • Request correction of your personal data.

  • Request erasure of your personal data.

  • Object to processing of your personal data.

  • Request restriction of processing your personal data.

  • Request transfer of your personal data.

  • Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

You won’t have to pay a fee to access your personal data (or to exercise any of the other rights), but we can charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive, or we can refuse to comply in these circumstances. 

We may need you to provide evidence of your identity as a security measure and we may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month, but it could take 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. 

  1. Third party links

This policy only relates to our websites. We might have links on/within our services to other websites, and these websites will have their own terms and conditions and privacy policies. You should check those privacy policies before providing your personal data to those websites. 

  1. Changes to this policy

We can update this policy from time to time as laws change or as our websites or services change. If we make material changes to this policy, and we need your consent to those changes, we will contact you by email to do so.