Privacy Policy

Bridge Models Limited

PRIVACY POLICY

Last updated: 2 November 2021

1. ABOUT THIS PRIVACY POLICY

1.1 The website www.bridgeagency.com (the Site) is operated by Bridge Models Limited (“we”, “us”, “our”), a company incorporated in England and Wales under company number 9175748. Our registered office is at 115 Baker Street, London, W1U 6RT .

1.2 We are committed to protecting your privacy and complying with our data protection obligations under the Data Protection Act 2018 (the DPA 2018), the UK General Data Protection Regulation 2016/679 (the UK GDPR) and any other applicable UK legislation (together, Data Protection Law).

1.3 When you interact with us or use the Site, we act as the data controller of your personal data. This means that we are responsible for processing your personal data and deciding how to use it. This privacy policy explains the types of personal data we may collect about you when you interact with us, why we collect it, what we use it for and what rights you have over that data. Personal data is any information about an identifiable person. Processing is anything we do with your personal data, including using, storing, sharing and deleting it.

1.4 This policy was last updated on the date shown at the top. We may change this policy at any time by posting an updated version on the Site and will make reasonable efforts to bring any material changes to your attention. You may wish to check it before using the Site as any changes will be effective from the date that they are made.

2. CONTACT INFORMATION

2.1 If you have any concerns or would like further information about our use of data or this policy in general, you can contact Adam Ward at [email protected].

3. WHAT INFORMATION DO WE COLLECT?

3.1 We collect, store and use the types of personal data set out in the table at the end of this policy.

4. HOW WILL WE USE YOUR PERSONAL DATA?

4.1 We will use your personal data for the purposes set out in the table at the end of this policy.

5. HOW DO WE SHARE YOUR PERSONAL DATA?

5.1 When we share personal data, we do so in accordance with Data Protection Law. We may share certain personal data, where necessary, with employees, contractors, consultants or advisers, to facilitate sales and for general commercial purposes.

In addition, where necessary, your personal data may be shared

5.1.1 with group, associated or affiliated companies including Bridge Models Limited Registered In New York , for internal administrative purposes.

5.1.2 if the company or business is sold, transferred or integrated with another business, with our advisers, a prospective purchaser, a prospective purchaser’s advisers or the new owner of the company or business to facilitate the process.

5.2 We may also provide third parties with aggregated but anonymised information and analytics about our customers. Before we do so we will make sure that it does not identify you.

5.3 In some cases, when we share personal data, it will involve the transfer of that personal data to countries outside the UK which have different data protection standards to those which apply in the UK.

5.4 Where we transfer personal data outside the UK we will ensure that there are adequate safeguards to protect your privacy rights under Data Protection Law.

6. THIRD PARTY LINKS

6.1 This Site contains links to other websites over which we have no control. We are not responsible for and do not review or endorse the privacy policies or practices of other sites which you choose to access from this Site. We encourage you to review the privacy policies of those other sites, so you can understand how they collect, use and share your personal information.

7. YOUR RIGHTS

7.1 We respect your rights to privacy and will respond to requests for access or control over information about you in accordance with Data Protection Law. We may require you to verify your identity before we take any action.

7.2 Depending on the reason we have your personal data, you have a right to:

7.2.1 access the personal information we hold about you (commonly known as subject access);

7.2.2 request that we correct or complete personal information we hold about you that is inaccurate or incomplete;

7.2.3 request that we erase your personal information in some circumstances, or object to our processing it as detailed at paragraph 7.5;

7.2.4 restrict how we use your personal information, in certain circumstances;

7.2.5 request that we provide you with copies of your personal information in a machine-readable format or transfer it across different services; and

7.2.6 where we have asked for your consent to process your data, to withdraw this consent.

7.3 These rights are limited in some situations under Data Protection Law – for example, where we can demonstrate that we are under a legal obligation to process your data. Sparqa Legal Resource: Privacy policy

7.4 If you wish to exercise any of these rights, please contact us using the details in paragraph above.

7.5 Your right to object

You have a right to object to our processing of your personal data and ask us to stop doing so. If we are processing your personal data for direct marketing purposes (which includes profiling to the extent that it is related to such direct marketing) and you object to this, we will stop processing your personal data immediately.

If our processing of your personal data is in the public interest or pursuant to our legitimate interests and you object to this, we will stop processing your personal data unless we have compelling reasons which override your interests, or our use of your personal data is for the establishment, exercise or defence of legal claims.

7.6 We hope that we can satisfy any queries you may have about the way we process your data. However, if you have unresolved concerns you also have the right to complain to data protection authorities (in the UK, the Information Commissioner’s Office). You can call the ICO on 0303 123 1113 or go to their website: https://ico.org.uk/make-a-comp...).

8. DATA RETENTION

8.1 Your personal data will only be kept for as long as necessary for our purposes. Specific periods are set out in the table at the end of this policy.

9. DATA PROTECTION PRINCIPLES

9.1 We process your personal data in accordance with the following principles:

9.1.1 we process your personal data lawfully, fairly and in a transparent way;

9.1.2 we collect your personal data for specified, explicit and legitimate purposes; any further processing we do is compatible with the original purposes for which for which we collected it;

9.1.3 we only process personal data which is adequate, relevant and limited to what is necessary to achieve the purpose for which it is processed;

9.1.4 we take reasonable steps to ensure that all personal data is accurate and kept up to date where necessary;

9.1.5 we do not store personal data in a form which identifies you for any longer than is necessary for the purposes of processing; and

9.1.6 we process personal data securely and in a way that protects against unauthorised or unlawful processing, accidental loss, destruction or damage.

9.2 When we ask for your personal data we will tell you whether you are required by law or contract to provide it, and what will happen if you do not provide the data. Sparqa Legal Resource: Privacy policy

9.3 Any request for consent to the processing of your personal data will be made directly to you and will include information about why we require the personal data and what will be done with it.

10. WHAT IS OUR LAWFUL BASIS FOR PROCESSING?

10.1 We will only process personal data when we have a lawful basis for doing that processing. The table at the end of this policy sets out the lawful basis we rely on for each type of data we process.

10.2 We will choose one of the lawful bases in the UK GDPR to justify how we use your personal data. These are:

10.2.1 Consent: You have given consent to the processing of your personal data for one or more specific purposes.

10.2.2 Contract: The processing is necessary for the performance of a contract with you or in order to take steps at your request before entering into a contract.

10.2.3 Legal obligation: We need to process your personal data to comply with a legal obligation.

10.2.4 Vital interests: The processing is necessary to protect the vital interests of you or another person.

10.2.5 Public interest: Processing is necessary for the performance of a task carried out in the public interest or in the exercise of some official authority.

10.2.6 Legitimate interests: Processing is necessary for the purposes of legitimate interests pursued by us or someone else, except where such interests are overridden by your interests or fundamental rights and freedoms requiring the protection of your personal data.

11. ATTRIBUTION

11.1 This privacy policy was created using a template from Sparqa Legal (https://www.sparqa.com), November 2, 2021. Sparqa Legal Resource: Privacy policy

TABLE OF PERSONAL INFORMATION WE USE

Category of personal data	Purpose of processing	Lawful basis for processing	Retention period
Name and contact details	To deliver your purchases to you To send you order updates For fraud prevention and detection To contact you with information, newsletters and marketing materials about our products and services	Performance of contract Compliance with legal obligation Consent	For three years since you gave consent, or until you withdraw consent if earlier
Date of birth	For fraud prevention and detection To ensure legal sale of age-restricted products	Performance of contract Compliance with legal obligation Legitimate interests in ensuring your safety	For three years since you last logged on to the Site
Contact history	To provide customer service and support To train our staff	Performance of contract Legitimate interests in dealing with complaints or claims	For six years since you last logged on to the Site
Purchase history	To provide customer service and support and handle returns To find out what products you like	Performance of contract Consent	For three years since you gave consent, or until you withdraw consent if earlier
Browser, device and Site usage information	To improve the Site To protect the Site against fraud To set default options for you, such as language and currency	Performance of contract Legitimate interest in maintaining our Site	For three years since you last logged on to the Site
Responses to surveys, competitions and promotions	To run the survey, competition or promotion	Performance of contract Legitimate interest in administering and/or improving our products and services generally	For six years
Customer comments and product reviews	To improve our products and services Where relevant, to establish, exercise or defend legal claims	Performance of contract Legitimate interest in dealing with complaints or claims and improving our products and/or services generally	For six years
Information generated in the course of the use of our products and services	For internal research and development purposes To improve and test the features and functions of our Site	Performance of contract Legitimate interest in maintaining our Site and improving our products and/or services generally	For four years
Information collected through cookies and similar technologies	To conduct and store site usage analytics, statistical and trend analysis and market research To generate customer profiles to facilitate marketing initiatives	Consent	For three years since you gave consent, or until you withdraw consent if earlier