Introduction

This is the privacy and cookies policy (“policy”) for Brevis Limited (“Brevis”, “we”, “us”). We are committed to safeguarding the privacy and confidentiality of our website visitors and service users. For more information about us, please see the section titled Our Details.

This privacy policy lays out in which scenarios we are a data controller or data processor. Where we are a data controller, the purposes and lawful basis for processing are set out. Where we are a data processor, the terms of processing are either described in this policy or in a separate signed document between us and the data controller.

Personal data is any information relating to an identified or identifiable living person. We hold and process personal data for a number of purposes, and will describe details of each separately.

Data that we hold can sometimes be held in order to carry out various activities as listed below. Where it exists, a contractual obligation takes precedence over other legal basis for processing.

General purposes for processing

There are some purposes of processing and holding data which apply to all categories of data and data processing activities that are listing in this policy.

We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

In addition to the specific purposes for which we may process your personal data set out elsewhere in this policy, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Our processing activities

Clients who use our service and the individuals associated with them

Introduction

Our clients (“they”, “them”) provide personal data on themselves and on the individuals associated with them in order for us to fulfill a contractual obligation to provide our services. This contractual obligation is laid out in our terms and conditions, to which customers must agree to prior to using our service.

What data do we hold and for what purposes?

We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system, and the logging system for our website. This includes cookie data. For more information on cookies, please see the cookies section of this policy. This usage data may be processed for the purposes of ensuring fulfillment of our services. 

We may process your account data (“account data”). The account data may contain personal contact details such as your name and email address. The source of the account data is you or the organisation to whom we are providing services. The account data may be processed for the purposes of providing our services, ensuring the security of our website and services, operating our website, maintaining back-ups of our databases and communicating with you. 

We may process personal data that is provided in the course of the use of our services (“service data”). The service data may include any data that would typically be found in the bookkeeping data of an organisation, such as payroll data, contact information, banking information. The source of the service data is you, or the organisation to whom we are providing services. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, administering and managing our business, maintaining back-ups of our databases and communicating with you. 

We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data”). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.

We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

What is our legal basis for processing?

Our legal basis for processing is the fulfillment of a contractual obligation to provide services and/or taking steps, at the request of yourself or the organisation to whom we are providing services, or in order to take steps, at your request, to enter into such a contract.

How long do we hold data for?

Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation).  

In the absence of specific legal, regulatory or contractual requirements, our baseline retention period for records and other documentary evidence created in the provision of services is 8 years.

We may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

People who visit our website

Introduction

There are people who visit our website who have not agreed to terms and conditions of use of our service. This section of the policy describes the purposes of processing data and the categories of data that we hold.

What data do we hold and for what purpose?

We may process data about your use of our website (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths. The source of the usage data is our analytics tracking system, and the logging system for our website. This usage data may be processed for the purposes of analysing the use of the website. This includes cookie data. For more information on cookies, please see the cookies section of this policy. 

We may process information contained in any enquiry you submit to us regarding our services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.

We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping.

What is our legal basis for processing?

The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services, and the proper administration of our website and business and communications with users.

How long do we hold data for?

Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation).  

Unless required for one of the purposes listed below, and in the absence of specific legal, regulatory or contractual requirements, our baseline retention period for records and other documentary evidence created in the provision of services is 8 years.

We may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Business contacts

Introduction

We hold and process personal data of business contacts that we may meet at various events. This data is usually business data, but may contain some personal data, usually as necessary to contact an individual as well as details of conversations that may have occurred.

What data do we hold and why?

We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.

We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

How long do we hold data for?

Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation).  

In the absence of specific legal, regulatory or contractual requirements, our baseline retention period for records and other documentary evidence created in the provision of services is 8 years.

We may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Employees and people associated with us

Employees should refer to the staff handbook for details about their data privacy.

Cookies

We use cookies in order to provide our service and website. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

We use cookies for the following purposes:

  • authentication – we use cookies to identify you when you visit our website and as you navigate our website;
  • status – we use cookies to help us to determine if you are logged into our website;
  • personalisation – we use cookies to store information about your preferences and to personalise our website for you;
  • security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;
  • analysis – we use cookies to help us to analyse the use and performance of our website and services; and
  • cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.

Cookies used by our service providers:

  • Our service providers use cookies and those cookies may be stored on your computer when you visit our website. These cookies are necessary for the basic functioning of our website (such as single sign on features with third parties), and in order for us to manage and administer our business (such as analytics software and customer relationship management).

Managing cookies

Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all the features on our website. If you block cookies you will not be able to sign into our platform and access the benefits of our service. 

Locations of processing

The hosting facilities for our website and offices are situated in the European Economic Area (EEA). Wherever possible, we will try to make sure that your personal data does not leave the EEA. However, there may be some scenarios that we will host or process data outside of the EEA. Transfers to any of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission

Sharing data

We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

You acknowledge that any personal data that you submit to the public domain through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

Our details

This website is owned and operated by Brevis Limited.

We are registered in England and Wales under registration number
10320957, and our registered office is at 5 Stockholm Way, Wapping, London, E1W 1YQ.

You can contact us:
(a) by post, addressed to the Board of Directors at the above address.;
(b) using our website contact form;

Your rights

This section summarises the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.

You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

You may exercise any of your rights in relation to your personal data by written notice to us.