BCCM Privacy Policy

BELFAST CITY CENTRE MANAGEMENT COMPANY PRIVACY POLICY

1. HOW WE USE YOUR DATA
We are committed to protecting your privacy.  It is important that you understand how we look after your personal data and how we make sure that we meet our legal obligations to you under the UK data protection rules (including associated guidance) (the "Data Protection Laws").  This privacy policy outlines how BCCM will use, store and share your personal data, and supplements any other fair processing or privacy notices provided to you.
If you have any questions in relation to this policy or generally how your personal data is processed by us please contact us by letter addressed to: City Centre Manager; or  by email at info@belfastcentre.com
This policy applies to any personal data that we collect about you when you:
• visit our website [http://www.belfastcentre.com] (our "website");
• contact us;
• Partner with us;
• Provide us with goods and/or services.
2. WHO ARE WE?
In this privacy policy, the terms "we", "our", and "us" are used to refer to Belfast City Centre Management Company Limited ("BCCM") registered in Northern Ireland with number NI037696 whose registered office is at Sinclair House 2nd Floor, 95-101 Royal Avenue, Belfast, BT1 1FE;.
We are a controller of your information which means that we are responsible for looking after it.  We will use your personal data fairly, lawfully and in a transparent manner, and in accordance with the Data Protection Laws.
3. WHAT INFORMATION DO WE COLLECT ABOUT YOU?
We collect your name and contact details (including your address, telephone number and e-mail address) when you input this information into our website. 
Each time you visit our website we may also automatically collect information and personal data about your computer for system administration including, where available, your IP address, operating system and browser type.  We do this to help us analyse how users use the websites (including behaviour patterns and the tracking of visits across multiple devices), to establish more about our website users and to assist us in managing your account and improving your online experience
You may share personal data about yourself and your circumstances by:
• entering into a partnership agreement with us
• tendering to provide us with goods and/or services;
• filling in forms on our website, registering to use our website, and continuing to use our website;
• giving us information about yourself in any communications with us either by telephone, e-mail, post or otherwise to report a complaint or issue;
• signing in at reception at our offices;
• submitting a job application or CV to us;
You are not obliged to provide your personal data to us.  However, if you do not provide your personal data to us, we may not be able to provide services to you, respond to your queries, allow you into our offices, or process your job application.
Please note that we may combine personal data we receive from other sources with personal data you give to us and personal data we collect about you.

4. WHY DO WE NEED YOUR INFORMATION?
The main purpose for which we use your information is to provide our goods and services to Belfast City Centre users.
We also use your information:
•  to provide you with information that you request from us or which we feel may interest you;
• to develop and improve our services;
• to provide support to our Partners;
• to administer and improve our website to ensure that content is presented in the most effective manner;
• to notify you about changes to our services;
• to review your CV and suitability for a role.
4.1 Basis for using your information
Legitimate business interests
We use your personal as set out in this privacy policy for the legitimate interests of our business to enable us to:
• provide you with goods and services as requested by you;
• carry out research to understand our users and how they use our products and services;
• develop and improve our services to Belfast City Centre Users;
• Fulfil our partnership activities and obligations to promote Belfast City Centre. 
We are required to carry out a balancing test of our legitimate business interests in using your personal data outlined above against your interests and rights under the Data Protection Laws.  As a result of our balancing test, , we have determined, acting reasonably and considering the circumstances, that we are able to process your personal data in accordance with the Data Protection Laws on the basis that we have a legitimate business interest.
5. WHO DO WE SHARE YOUR INFORMATION WITH?
We may share your information our partners but only for the purposes specified in this privacy policy
We may also use a number of carefully selected third parties to supply us with products and services, such as legal advice.  We will only share your information with these suppliers where it is necessary for them to provide us with the services we need.  We do not share your information with third parties for marketing purposes.
6. WHERE IS YOUR INFORMATION STORED AND HOW LONG DO WE KEEP IT FOR?
6.1 Retention of your personal data
We will typically keep your personal data for 6 years from our last contact with you with us in order to enable us to deal with any issues or concerns you may have about how we handled your account, and also to allow us to bring or defend legal proceedings.  In some circumstances, some of your data will be deleted in much shorter timescales, for example:
•  recruitment and interview records for unsuccessful candidates are kept for 6  months after the start date of the successful candidate;]
6.2 Security of your personal data
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our websites; any transmission is at your own risk.  Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
7. WHAT RIGHTS DO YOU HAVE?
You have a number of rights under the Data Protection Laws in relation to the way we process your personal data, which are set out below.  You may contact us using the details at the beginning of this privacy policy to exercise any of these rights.
In some instances, we may be unable to carry out your request, in which case we will write to you to explain why.
1. You have the right to request access to your personal data You have the right to request confirmation that your personal data is being processed, access to your personal data (through us providing a copy) and other information about how we process your personal data.
2.  You have the right to ask us to rectify your personal data You have the right to request that we rectify your personal data if it is not accurate or not complete.
3.  You have the right to ask us to erase your personal data You have the right to ask us to erase or delete your personal data where there is no reason for us to continue to process your personal data.  This right would apply if we no longer need to use your personal data to provide the debt management services to you, where you withdraw your consent for us to process special categories of your personal data, or where you object to the way we process your personal data (see right 6 below).
4.  You have the right to ask us to restrict or block the processing of your personal data You have the right to ask us to restrict or block the processing of your personal data that we hold about you.  This right applies where you believe the personal data is not accurate, you would rather we block the processing of your personal data rather than erase your personal data, where we don need to use your personal data for the purpose we collected it for but you may require it to establish, exercise or defend legal claims.
5.  You have the right to port your personal data You have the right to obtain and reuse your personal data from us to reuse for your own purposes across different services.  This allows you to move personal data easily to another organisation, or to request us to do this for you.
6.  You have the right to object to our processing of your personal data You have the right to object to our processing of your personal data on the basis of our legitimate business interests, unless we are able to demonstrate that, on balance, our legitimate interests override your rights or we need to continue processing your personal data for the establishment, exercise or defence of legal claims.
7.  You have the right not to be subject to automated decisions You have the right to object to any automated decision making, including profiling, where the decision has a legal or significant impact on you.
8.  You have the right to withdraw your consent You have the right to withdraw your consent where we are relying on it to use your personal data.

8. WHAT IF YOU HAVE A COMPLAINT?
If you have any concerns regarding our processing of your personal data, or are not satisfied with our handing of any request may by you, or would otherwise like to make a complaint, please contact our City Centre Manager in the first instance using the details at the start of this privacy policy, so that they can do their very best to sort out the problem.
You can also contact the Information Commissioner's Office at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF www.ico.org.uk.
9. OTHER WEBSITES
Our websites may, from time to time, contain links to and from the websites of third parties.  If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies or your use of those websites.
10. CHANGES TO THIS PRIVACY POLICY
We will take all measures necessary to communicate any changes to this privacy policy to you, and will post any updated privacy policies on this page.
This policy was last reviewed and updated in October 2018.