Last updated: July 2015
This Policy applies as between you, the User of this Website and Bright North the owner and provider of this Website. This Policy applies to our use of any and all Data collected by us in relation to your use of the Website.
Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
- means collectively all information that you submit to Bright North via the Website. This definition shall, where applicable, incorporate the definitions provided in the Data Protection Act 1998;
- means a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in Clause 12;
- Bright North
- means Bright North Limited, a company registered in England and Wales (with company number 8340170) whose registered office is at 5.04 New Loom House, 101 Back Church Lane, London, E1 1LU, England;
- UK and EU Cookie Law
- means the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011;
- means any third party that accesses the Website and is not employed by Bright North and acting in the course of their employment; and
- means the website that you are currently using (www.brightnorth.co.uk) and any sub-domains of this site unless expressly excluded by their own terms and conditions.
Scope of this Policy
This Policy applies only to the actions of Bright North and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.
Without limitation, any of the following Data may be collected by this Website from time to time:
- date of birth;
- job title;
- contact information such as email addresses and telephone numbers;
- demographic information such as post code, preferences and interests;
- financial information such as credit / debit card numbers;
- IP address (automatically collected);
- web browser type and version (automatically collected);
- operating system (automatically collected);
- a list of URLs starting with a referring site, your activity on this Website, and the site you exit to (automatically collected)
Our Use of Data
- Any personal Data you submit will be retained by Bright North for no longer than necessary for the purpose for which it was retained.
- Unless we are obliged or permitted by law to do so, and subject to Clause 5, your Data will not be disclosed to third parties. This does not include our affiliates and / or other companies within our group.
- All personal Data is stored securely in accordance with the principles of the Data Protection Act 1998. For more details on security see Clause 11 below.
- Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:
- internal record keeping;
- improvement of our products / services;
- transmission by email of promotional materials that may be of interest to you;
- contact for market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customise or update the Website.
Third Party Websites and Services
- Bright North may, from time to time, employ the services of other parties for dealing with matters that may include, but are not limited to, payment processing, delivery of purchased items, search engine facilities, advertising and marketing.
- Any Data used by such parties is used only to the extent required by them to perform the services that Bright North requests. Any use for other purposes is strictly prohibited. Furthermore, any Data that is processed by third parties shall be processed within the terms of this Policy and in accordance with the Data Protection Act 1998.
Links to Other Websites
Changes of Business Ownership and Control
- Bright North may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Bright North. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Policy, be permitted to use the Data for the purposes for which it was originally supplied to us.
- In the event that any Data submitted by Users is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.
Controlling Use of Your Data
Wherever you are required to submit Data, you will be given options to restrict our use of that Data. This may include the following:
- use of Data for direct marketing purposes; and
- sharing Data with third parties.
Your Right to Withhold Information
- You may access certain areas of the Website without providing any Data at all. However, to use all features and functions available on the Website you may be required to submit certain Data.
Accessing your own Data
You have the right to ask for a copy of any of your personal Data held by Bright North (where such data is held) on payment of a small fee which will not exceed £50.
- Data security is of great importance to Bright North and to protect your Data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure Data collected via this Website.
- We endeavour to do our best to protect your personal Data. However, transmission of information over the internet is not entirely secure and is done at your own risk. We cannot ensure the security of your Data transmitted to the Website.
- By using this Website you may receive certain third party Cookies on your computer. Third party cookies are those placed by websites and/or parties other than Bright North. Third party cookies are used on this Website for user experience and website improvement and are detailed in full below. These cookies are not integral to the services provided by the Website.
- All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.
- Before any Cookies are placed on your computer, subject to sub-Clause 12.5 and sub-Clause 12.8, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Bright North to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.
- Certain features of the Website depend upon Cookies to function. UK and EU Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below. Your consent will not be sought to place these Cookies. You may still block these cookies by changing your internet browser’s settings as detailed below.
- The following first party Cookies may be placed on your computer:
Name of Cookie Purpose Strictly Necessary __CT_Data Associated with analytics service provider ClickTale. Used to count the number of page views or visits of an anonymous visitor to the site. No __distillery Used by our video player to remember where you are in a video so that if playback is interrupted (for example, by losing your Internet connection) then you can get right back to where you left off. No km_ai Associated with Kissmetrics analytics service. Used to provide site owners with information about how visitors use the site. No km_lv Associated with Kissmetrics analytics service. Used to provide site owners with information about how visitors use the site. No _dc_gtm_UA-xxxxxxxx Associated with Google Tag Manager. Used to load other scripts and code into a page. Yes _ga Associated with Google Analytics. Used to distinguish unique anonymous users by assigning a randomly generated number as a client identifier. Yes hsfirstvisit Associated with the HubSpot platform. Used for website analytics. Yes hubspotutk Associated with the HubSpot platform. Used for website analytic Yes __hssrc Associated with the HubSpot platform. Used for website analytics. No __hstc Associated with the HubSpot platform. Used for website analytics. No __smSubscribed Used by SumoMe software whether the panel proposing to subscribe is visible or not. No __smToken Used by SumoMe software to identify a logged in SumoMe administrator. No __utma Used to distinguish users and sessions. Yes __utmc Used to determine new sessions/visits. Yes __utmz Stores the traffic source or campaign that explains how the user reached your site. Yes km_uq Associated with Kissmetrics analytics service. Used to provide site owners with information about how visitors use the site. No optimizelyBuckets Stores JSON of the experiments and variations that a user has been bucketed into. This ensures the user consistently sees the same variation, even over multiple sessions. No optimizelyEndUserId Associated with the Optimizely website optimisation plaftform. This cookie is a unique user identifier No optimizelySegments Associated with the Optimizely website optimisation plaftform. It holds audience segmentation information for a visitor. No PRUM_EPISODES Associated with Pingdom. Used to measure and improve the page load speed. No WRUID Used to anonymously identify a visitor for the purpose of enabling the ClickTale software to track such visitor’s actions across the website. No
and the following third party Cookies may be placed on your computer:
Name of Cookie Purpose Provider _hp2_id.xxxxxxxx Associated with Heap Analytics. Used to generate statistical and other information about website use by means of cookies Heap Analytics heap.sid Associated with Heap Analytics. Used to generate statistical and other information about website use by means of cookies Heap Analytics __cfduid Cookie assoiated with CloudFlare, used to speed up page load times. Used to override any security restrictions based on the IP address the visitor is coming from. It does not contain any user identification information. CloudFlare
- This Website uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling us to better understand how Users use the Website. This, in turn, enables us to improve the Website and the products and services offered through it. You do not have to allow us to use these Cookies, as detailed below, however whilst our use of them does not pose any risk to your privacy or your safe use of the Website, it does enable us to continually improve our business.
- The analytics services used by this Website use the following Cookies:
Name of Cookie First / Third Party Provider Purpose __utma First Google Analytics Used to distinguish users and sessions __utmb First Google Analytics Used to determine new sessions/visits. __utmc First Google Analytics Used to determine new sessions/visits. __utmt First Google Analytics Used to determine new sessions/visits. __utmz First Google Analytics Stores the traffic source or campaign that explains how the user reached your site.
- You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.
- You can choose to delete Cookies at any time however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.
- It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.
Changes to this Policy
Bright North reserves the right to change this Policy as we may deem necessary from time to time or as may be required by law. Any changes will be posted on the Website and you are deemed to have accepted the terms of the Policy on your first use of the Website following the alterations.