INTRODUCTION

A privacy policy is a legal document that discloses the ways in which a website collects, processes, stores, shares and protects user data, the purposes for doing so and the rights of the users in that regard.

All websites interact with and collect data about their visitors in one way or another. This is even more applicable in the case of an e-commerce store. E-commerce sites typically collect personal data like names, email address, IP addresses, session activity and payment details, to name a few. For this reason, a privacy policy is vital as it protects website owners and customers alike, while also ensuring that your website complies with legal obligations.

As stated above, all websites interact with user data in some way. This means that if you have a website and you intend to have people visit that website, then it’s mandatory that you include a privacy policy. The law requires you to inform users about what data you collect, how it’s used, stored and protected. As a matter of fact, under the new EU GDPR legislation (enforceable starting from May 2018), it’s also necessary that your privacy policy inform users of their rights in regards to their data. The disclosures should be transparent, easily understandable, comprehensive and up-to-date. Failure to meet regulatory requirements can result in hefty fines (Article 83). These regulations apply to all organizations (including non-profits) that access data or offer goods or services to people in the EU. The GDPR applies whether your organization is located in the EU or not.

Not only is a privacy policy crucial to ensuring that legal requirements are met, and customer trust is maintained, but many third-party apps and services require it. At its most basic, a privacy policy should include the following:

• Site / app owner details.
• Disclosures related to third-party access to the data.
• What data is being collected, how and why.
• Disclosure of your process for notifying users of changes/ updates to your policy.
• Effective date of policy.

Within the scope of the GDPR, a privacy policy should also include the following:

• Disclosures related to any data processors if different from the site owner. This includes all parties having access to or involved in processing user data. These include 3rd party apps, widgets, social buttons, ad service integrations etc.
• Rights of users: Under the new EU regulations, its mandatory users be able to request, view, transfer and erase their data (where some conditions are met) * Note, these regulations are applicable to ALL business (including non-profits), regardless of location, that accesses data or offers goods or services to people in the EU.

Other related requirements are:

• The link (to the privacy policy) should be clear and prominent
• It should be easily accessible
• Your policy may not use overly complicated or indecipherable language (no legalese and unnecessary jargon).

This document showcases a range of examples of privacy policies adopted by other companies, in certain respects, similar to BSF Enterprise PLC, only for your reference.

BSF ENTERPRISE PLC PRIVACY POLICY

BSF Enterprise PLC, C/o Locke Lord LLP 201 Bishopsgate London EC2M 3AB United Kingdom (“BSF Enterprise PLC” or “we”) provide professional services including, without limitation, invest in biotechnology, innovative marketing and e-commerce companies in the UK, Europe, China, and Australia. This Privacy Policy outlines our general policy and practices for protecting personal information that we collect through our Web site at www.bsfenterprise.com that we operate, and which post this Privacy Policy. This Privacy Policy explains the types of information we gather through our Sites, how we use that information, and the rights individuals may exercise in relation to that information.

We recognize that when you choose to provide us with information about yourself, you trust us to act in a responsible manner.

This Privacy Policy will inform you of how we manage and protect data and of the choices you can make about the way your personal information is collected by us.

Personal information is the information that identifies a living individual, or which could, with other information that we hold, identify that individual. It includes your name and contact details, but also includes other information that is relevant to you such as your preferred property or development.

By submitting personal information to us, you consent to our use of such personal information in accordance with this Privacy Policy.

If you are a California resident, you have a right to opt-out of the “sale” (as defined by the California Consumer Privacy Act of 2018) of your personal information. Click here to exercise your right to opt-out.

1. What personal information does BSF Enterprise PLC collect?

a) Information we collect

We will collect information about your visit to our website. This may include your IP address (this is the number that is automatically assigned to your computer when you are online); operating system, browser type and device used to access the website; when and how you accessed the website; and if you joined the website from another website.

Cookies may be used to store some of the information collected during your visit to our website. These are small files that are stored on your computer when you visit a website. For example, they allow the website to remember the log in details for your account.

For more information, please view our cookie policy here.

b) Information you provide

You provide us with your personal information when you make enquiries or register on our website, or when you contact us by phone, e-mail or make a visit to our sales offices. This may include your name and address and details of which properties and/or projects are of interest to you or further information necessary to assist with a specific enquiry.

2. How does BSF Enterprise PLC use your information?

BSF Enterprise PLC will use your information for the following general purposes:

• to provide you with information that you have requested.
• for our internal purposes such as data analysis, research, surveys, for administering our website and to improve the quality of our customer service.
• to measure or understand the effectiveness of advertising we serve to you and others, and to send relevant advertising to you; and
• for compliance and crime prevention purposes.

In particular, BSF Enterprise PLC will use your personal information in the following ways:

a) When you make an enquiry to BSF Enterprise PLC

We may use a third party to keep a record of any call you make to us so that we are able to return your call. By calling us or asking us to call you, you acknowledge that we may contact you by telephone on the number you have called us from for the purposes of discussing the project.

We may monitor, record, store and use any telephone, email, or other communication with you in order to check any instructions given to us.

b) When BSF Enterprise PLC wishes to communicate with you

At several points throughout the website, you may be given the option to receive occasional information on BSF Enterprise PLC update We may contact you by phone, SMS, email, or post for this purpose. You can let us know your contact preferences by registering for an online account on our website.

If you do not want to be contacted for this purpose, all e-mails will include an “unsubscribe” option allowing you to let us know that you no longer wish to receive any further messages from BSF Enterprise PLC. For more details about how to unsubscribe, please see section 7 (b) below.

3. Using your information in accordance with the data protection laws

Data protection laws require that we meet certain conditions before we are allowed to use your data in the manner described in this Privacy Policy. We take our responsibilities under the data protection laws extremely seriously. To use your personal information, we will rely on the following conditions, depending on the activities we are carrying out:

a) Legitimate interests

To use your personal data for providing you with information you have requested or with other promotional information or announcements, we will rely on a condition known as “legitimate interests”. We will also rely on this condition when processing your information for the administrative and advertising activities described in section 2 (v) and (vi) above. It is in our legitimate interests to make you aware of developments that we believe are relevant to you or updates.

b) Consent

If you have not contacted us or specifically requested information about our projects, we may provide you with marketing information about our projects where you have provided your consent for us to do so.

c) Performing an agreement with you

When you use our website, we will process your personal information to the extent that this is necessary for the performance of our obligations under the Terms and Conditions.

4. How Does BSF Enterprise PLC protect your information?

The data protection laws mean that we need to follow strict security procedures in the storage and disclosure of information that you have given us.

When we share your information with trusted third parties, we may do so by email. We do take data security very seriously, but please remember that we cannot guarantee the absolute security of the emails we send.

The information that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our third-party suppliers. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy by imposing mandatory contractual obligations upon the data recipient.

5. Will BSF Enterprise PLC disclose the information it collects to third parties?

BSF Enterprise PLC will not sell, trade, or rent your personal information to others for their marketing purposes unless you have given us your permission. We will only share information with carefully chosen reputable and trustworthy third parties as described in this Privacy Policy.

6. Information Retention

Once your details are added to our mailing lists for the purpose of providing you with information about our homes and developments and other general offers and updates, your information will remain on that mailing list: (i) until we receive a request from you to stop contacting you for this purpose; or (ii) if we do not receive a response from you for 12 months. We will not contact you for this purpose again until we hear otherwise from you.

7. Your Rights

Your rights under data protection law in relation to the way we process your personal information are set out below.

You may contact us using the details on our website or using the following email address to exercise any of these rights, and we will respond to any request received from you within one month from the date of the request.

a) Access to your personal data

You have a right of subject access. This means that you are entitled to request a copy of your personal information and we will grant you access or provide you with all personal information that we hold about you, subject to some limited exemptions (for example, you will not necessarily be entitled to access third party personal information).

b) Unsubscribe

You can always remove your name and contact details from our various email-lists and other lists. In addition to contacting us in the way noted above, you can ask for your details to be removed from BSF Enterprise PLC email-lists permanently.

c) Data portability

You have a right of data portability. You are entitled to request that the information you have provided to us is then provided to you (or to another organization) in a portable, machine readable, electronic format.

d) Rectify your personal data

You have the right to require us to rectify any inaccurate personal data held by us about you.

e) Erase your personal data

You have a right to require us to erase personal data held by us about you. This right will only apply where (for example): we no longer need to use the personal data to achieve the purpose we collected it for; or where you withdraw your consent if we are using your personal data based on your consent; or where you object to the way we process your data (in line with your right to unsubscribe above).

f) Object to or restrict our use of your personal data

You have a right to object to our processing of personal data held by us about you (for example, if you would not like to be subject to any profiling or direct marketing). You may also ask us to restrict the way in which we process your information in certain circumstances (for example, if you think that the information we hold about you is not accurate or we are not processing the data in accordance with section 3 above).

If you have any concerns regarding our processing of your personal data, we would be happy to address your query in the first instance. However, if you are not satisfied with our handling of any request in relation to your rights, you also have the right to make a complaint to the Information Commissioner’s Office. The address is:

Miao He
C/o Locke Lord LLP
201 Bishopsgate
London EC2M 3AB
United Kingdom

Once we receive your request, we may verify it by requesting information sufficient to confirm your identity. We reserve the right to deny requests if we have a reasonable belief that the request is fraudulent.

8. Changes to this Privacy Policy

BSF Enterprise PLC reserves the right to amend or modify this Privacy Policy from time to time, as determined at BSF Enterprise PLC’s sole discretion, by publishing an update version on the Site. BSF Enterprise PLC encourages you to periodically review this Privacy Policy. You can access the most current version of this Privacy Policy on the Site.