WHY DO WE HAVE THIS PRIVACY NOTICE?

We are Boxraw and treating individuals and their personal information with respect reflects our core values and the values of our brand(s). So we want you to know as much as possible about what we do with your personal information. Also you and your personal information are protected by various laws and guidance and Boxraw is committed to upholding these and respecting your privacy and keeping your information safe. So whilst this privacy notice is quite long, we want you to be fully informed.

In this privacy notice any reference to "us", "we", "our" or "ourselves" is a reference to Boxraw, and the particular part of the Boxraw group that you have a relationship with and any reference to "you", "your" and "yourself" is a reference to you as an individual who has a relationship with us or is in contact with us.

This privacy notice applies to everyone who interacts with us in any way, unless the reason you interact with us is already covered by another of our privacy notice(s). So this privacy notice will not apply in relation to you to the extent you are currently applying or have applied to work for Boxraw, you are one of our current or former staff, you are a customer or prospective customer of ours, you are a user of any of our apps or if your personal information has been captured by our CCTV or Access Control systems.

Please note that we have a separate privacy notice that relates to personal information captured by our CCTV and Access Control systems. A copy can be found here

We also have a separate privacy notice that applies generally to individuals who apply to work for us, a copy of which will be provided to you during the recruitment/interview process.

Finally we have a separate privacy notice that applies to our customers and potential customers, a copy of which can be found here so this will apply if you purchase products from us, add yourself to our marketing database, enter any of our promotions/competitions, apply to attend any of our events or you have an unpaid active social media relationship with us. You should also read these privacy notices to the extent that they will apply to your activities as they may apply to you in addition to this privacy notice.

However this privacy notice will cover you if you interact with us for any other reason. For example this privacy notice will cover someone who uses our website or just links to or follows our social media accounts but does not post comments about our social media, works at a supplier of ours or another organisation that we deal with, an associate member of our lifting club, an athlete or introducer that we have a paying relationship with, a model we engage to fit and showcase our products, personal trainers or others who provide us with paid content, one of our shareholders, a member of the public who contacts us or anyone else who is affected by our activities to the extent not covered by another of our privacy notices. This privacy notice provides details in accordance with data protection laws about how we collect and use personal information about you during and after your relationship with us.

As this privacy notice covers a wide range of individuals and different types of relationships and interactions with us, not all aspects of this privacy notice will apply to you. The aspects of this privacy notice that will apply to you will depend upon the nature of your relationship and interactions with us. If you are unsure then you can always ask us by contacting mydata@boxraw.com.

THE CONTROLLER OF YOUR PERSONAL INFORMATION

For the purposes of data protection laws and this privacy notice, the controller of your personal information is whichever part of the Boxraw group is processing your personal information. This will usually be the part of the Boxraw group that you interact with or have a relationship with. Being a controller of your personal information means that we are responsible for deciding how we hold and use your personal information. Our main trading entity is Boxraw Limited (Reg No. 10118084) which is incorporated in England and Wales. If you are based in the UK then this company will be the controller of your personal information. If you are based outside of the UK then the controller of your personal information will be the part of our group. Sometimes we may pass personal information to different parts of our group, so this privacy notice covers our whole group and more than one part of our group may be a controller of your personal information. However regardless of where you are based and regardless of which part of our group may be a controller of your personal information, any queries you have regarding your personal information will be dealt with by Boxraw Limited, which can be contacted at mydata@boxraw.com.

YOUR DUTY TO INFORM US OF CHANGES

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during the period of your interactions with us.

WHAT IF YOU DO NOT PROVIDE PERSONAL INFORMATION?

Failing to provide some of the personal information we require may have an adverse impact on our ability to interact with you. However generally you are not obliged to provide us with any of your personal information.

IF YOU HAVE QUERIES OR CONCERNS JUST ASK!

We have appointed a data protection officer (DPO) to oversee our compliance with the data protection laws. If you have any questions about this privacy notice or how we handle your personal information, please contact our DPO on mydata@boxraw.com.

CHANGES TO THIS NOTICE

We keep our privacy notice under regular review and we may update this privacy notice at any time. The current version of this notice is available on our website here or by requesting a copy from mydata@boxraw.com. If there are any material changes to this privacy notice in the future we will let you know, usually by updating the version on our website.

DATA PROTECTION PRINCIPLES

We are committed to being transparent about how we collect and use your personal information and in meeting our data protection obligations. Data protection laws say that the personal information we hold about you must be:

• Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
• Relevant to the purposes we have told you about and limited only to those purposes.
• Accurate and kept up to date.
• Kept only as long as necessary for the purposes we have told you about.
• Kept securely.

To make sure this happens we are required under applicable data protection laws to notify you of the information contained in this privacy notice. It is important that you read this document before you begin interacting with us so that you understand how and why we will process your personal information.

WHAT PERSONAL INFORMATION DO WE COLLECT?

In connection with your relationship or interactions with us, we may collect and process a wide range of personal information about you. This includes:

• Personal contact details such as name, title, address, email address and telephone number(s).
• Information about your date of birth, age, gender, marital status, next of kin, dependants, family members and emergency contacts.
• Bank account details, financial transactions, payments.
• Any terms and conditions relating to your relationship with us.
• Any communications between ourselves and you.
• Details of services carried out or products provided by you in connection with our relationship with you, details of your interest in and connection with any organisation which supplies any services or products to us, details of any financial products or services supplied to us.
• Business related information, such as where you are a sole trader, a partner or a company director or a key member of staff of a business we have a relationship with.
• Performance information related to our relationship with you or a business we have a relationship with.
• Your social media handles, social media posts, information about your social media followers, information about any product/services endorsements by you, information about you as a social media influencer and other aspects of your social media activity.
• Publicly available personal information, including any which you have shared via a public platform, online or on social media.
• Details of your work history including organisations, positions, roles, responsibilities.
• Details of your sporting or athletic achievements and activity and related plans and progress.
• Personal history and information including hobbies, interests, dietary requirements and your preferences.
• Creditworthiness as we may undertake investigations into your creditworthiness in order to establish whether to enter into or continue a business relationship with you.
• How you use our website as we collect information about the pages you look at and how you use them, usernames, account details and passwords, entry and exit data when you look at or leave our website, details of products, events and materials that may be interest to you, online subscription information for example when you subscribe to one of our updates, blogs or other materials, browser related information, cookies that are set on your device by our website (for more details see our separate cookie policy at here
• Your usage of the IT systems we make available to visitors to our premises such as any visitor internet facilities at our premises.
• IP address information which allows us to track your usage of our website.
• Identification information including your driving license and/or passport and background checks.
• Gym training records, professional details.
• Vehicle registration number, make and model if you are driving to visit us at our premises.
• Details of any queries, complaints, claims and cases involving both us and yourself including any related communications.
• CCTV footage and other information obtained through electronic means such as swipe card records and access control systems if you visit our premises (see our separate CCTV and Access Control privacy notice here
• Photographs, video footage, audio recordings and other content, for example any created as part of our marketing or promotion campaigns or when you are on our premises or which you create or provide to us.
• Information from Companies House, details of shareholdings in our group and associated information such as share votes, dividend entitlement, share sales/purchases.
• Any other personal information you provide to us.

We may also in some cases collect and process more sensitive special category personal information including:

• Information about your health including any medical condition, health, and sickness records, including:
  • where you have a disability or medical condition for which we need to make reasonable adjustments, including where you visit our premises.
  • where you inform us about any ill-health, injury, or disability.
  • information about your health, for example in the context of using our gym facilities.
• In some cases equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health and religion or beliefs. This will usually only be where it is relevant to events, promotions, campaigns or other activities that may involve you.
• In very rare cases political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning sex life or sexual orientation may be processed for other purposes, but this will usually only be where you provide it to us, it is relevant to a business relationship with us or it relates to a legal claim in some way.
• In very rare cases where it is relevant, we may also collect criminal records information about you, for example an offence committed by you or alleged to have been committed by you that impacts on your relationship with us.

If you are providing us with details of any other individuals they have a right to know and to be aware of what personal information we hold about them, how we collect it and how we use and may share that information. Please share this privacy notice with them. They also have the same rights as set out in this privacy notice in relation to their personal information that we collect.

WE AIM NOT TO COLLECT PERSONAL INFORMATION ABOUT CHILDREN

Our website, events, promotions, blogs, materials and other services we provide are not intended for use by anyone under the age of 18 years and we do not knowingly collect personal information relating to anyone under the age of 18 years old unless for some reason you provide it to us.

WHERE DO WE COLLECT YOUR PERSONAL INFORMATION FROM?

Boxraw collects your personal information in a variety of ways and from a variety of sources as set out below:

• Most of your personal information is collected directly from you, for example through contact with you, correspondence with you, through your applications, subscriptions, memberships, from your passport or other identity documents such as your driving licence; when you visit our premises, from correspondence with you or through meetings or other interactions with us or other personal information you provide to us.
• If you work for an organisation that has a relationship with us, then then we may collect some of your personal information from them.
• From websites, the internet, social media or other platforms including public sources of information.
• Third parties such as organisations you have worked for in the past, Companies House, professional or trade organisations.
• From our website and information technology and communications systems, access control systems and CCTV and suppliers we use in connection with them.
• From third parties appointed by you, for example any agency you work with or any financial or legal advisors.
• From third parties appointed by us, for example legal advisors appointed by us or credit reference agencies, identity or background check providers, data cleansing service providers or market/data research and analysis service providers.
• From government or government related bodies, regulators, the police, law enforcement authorities or the security services.

WHAT ARE OUR BASES FOR PROCESSING YOUR PERSONAL INFORMATION?

We will only use your personal information when the law allows us to. This means we must have one or more legal bases to use your personal information. Most of these will be self-explanatory. The most common legal bases which will apply to our use of your personal information are set out below:

• Where we need to perform the contract we have entered into with you which covers your relationship with us or to take steps to enter into that contract.
• Where we need to comply with a legal obligation which applies to us, for example complying with health and safety laws for visitors.
• Where it is necessary for legitimate interests pursued by us or a third party and your interests and fundamental rights do not override those interests. We have set out in the section below how we use your personal information together with more details on our legitimate interests.
• You have given your consent. Generally we do not rely on or need your consent for almost all uses we make of your personal information.

We may in limited circumstances process sensitive special category personal information about you (which covers personal information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person’s sex life or sexual orientation) then we also need to have one or more of the following lawful bases for using your personal information.

• Where we have your explicit consent to do so.
• Where it is necessary for us to comply with our obligations and exercising our rights in the field of employment law, social security law and social protection law, for example processing your health information so we can ensure it is safe for you to use our gym facilities.
• Where we need to protect your vital interests (or someone else's vital interests).
• Where you have already made public the personal information.
• In establishing, exercising or defending legal claims, whether those claims are against us or by us.
• Where it is necessary in the public interest.

We will not usually process any of these types of special category personal information about you, and in cases where we do process special category personal information about you it will generally be to comply with legal obligations, where you have given your consent or to establish, exercising or defending legal claims. In some cases more than one lawful bases may apply to our use of your personal information.

HOW WILL WE USE YOUR PERSONAL INFORMATION?

There are many ways we will need to use your personal information in the context of your relationship with us. We have set out the main uses below, and indicated the main applicable legal bases of processing, but there may be other specific uses which are linked to or covered by the uses below.

• We will process your personal information to conduct any business or other relationship we have with you. For example, we may need to process your personal information to provide you with a contract if you are an influencer for or supplier to our business, we will need to perform any contract we have with you or an organisation you work for, you might be an associate member of our lifting club and we will process your information so you can use our gym facilities or you might have accepted the chance to take part in our events, promotions or campaigns. As well as relating to the entry into or performance of a contract with you either directly or indirectly, this will also be in our legitimate interests. We may also in some limited cases rely on your consent.
• We also need to monitor and manage our relationship with you, which may involve meetings, assessments, communications with you, decisions regarding your relationship with us. As well as relating to the entry into or the performance of a contract with you either directly or indirectly, this will also be in our legitimate interests.
• We may need to process your personal information in order to hold or conduct promotions or campaigns. This may relate to the entry into or performance of a contract with you either directly or indirectly, it may be in our legitimate interests, and in some cases we may rely on your consent to do this.
• We may need to process your personal information to help train our staff, and make sure they deliver the high standards expected in relation to our brand. This will be in our legitimate interests.
• We may need to carry out background, identity or other checks in relation to you or to carry out credit checks to decide whether to enter into a business relationship with you. This will be in our legitimate interests, and in some cases we may have a legal obligation to do so.
• As a business we may have many legal obligations connected to our relationship with you or connected to visiting our premises which we need to comply with, for example, to comply with health and safety laws so we can ensure it is safe for you to use our gym facilities, to comply with data protection laws, to make filings at Companies House, to ensure equality and equal opportunities or to invoke other legal rights.
• We will also need to keep and maintain proper records relating to your relationship with us and information about you which is relevant to that relationship. As well as relating to the entry into or performance of a contract with you either directly or indirectly, this will also be in our legitimate interests, and we may also have legal obligations to do this.
• In some cases we may need to process your personal information to prevent, detect or prosecute criminal activity. This will also be in our legitimate interests; we may also have legal obligations or be exercising a legal right to do this and it will also be in the public interest.
• You may have contacted us about a query, compliant or enquiry and we need to be able to respond to you and deal with the points you have raised. This will also be in our legitimate interests; we may also have legal obligations or be exercising a legal right to do this.
• We may need to gather evidence for and be involved in possible legal cases. As well as relating to the entry into of a contract with you either directly or indirectly, this will also be in our legitimate interests, we may also have legal obligations or be exercising a legal right to do this and it may also be needed to establish, bring or defend legal claims.
• To manage and keep a record of our relationship with you and any associated information. It may relate to the entry into or performance of a contract with you either directly or indirectly, it will also be in our legitimate interests, and we may also have legal obligations or be exercising a legal right to do this.
• To ensure effective general business administration and to manage our business. As well as relating to the entry into or performance of a contract with you either directly or indirectly, this will also be in our legitimate interests, and we may also have legal obligations or be exercising a legal right to do this.
• To obtain referrals from other organisations you have worked for or with. As well as relating to the entry into or performance of a contract with you either directly or indirectly, this will also be in our legitimate interests, and we may also have legal obligations or be exercising a legal right to do this.
• To monitor any use you make of our information and communication systems and our website and social media accounts to ensure compliance with our information technology policies, ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution and also to monitor your use of our website and social media. As well as relating to the entry into or performance of a contract with you either directly or indirectly, this will also be in our legitimate interests, and we may also have legal obligations or be exercising a legal right to do this. In relation to social media you may also have already made the personal information public.
• We may need to process your personal information to help train our staff, and make sure they deliver the high standards expected in relation to our brand. This will be in our legitimate interests.
• To conduct data analytics and analysis studies to review and better understand trends and improve our business, use of our website and social media which relates to us, and those same things in relation to our competitors. This will also be in our legitimate interests, and we may also have legal obligations or be exercising a legal right to do this. We may sometimes anonymise and aggregate personal information for insight and research purposes, but this information will not identify you.
• We may be carrying our market and/or product research, for example so that we can improve our offering and range of products or improve our use of our website or social media. This will be in our legitimate interests.

CHANGE OF PURPOSE

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you by updating this privacy notice on our website, so please check back regularly for any updates.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. We will rarely need to rely on your consent to process any of your personal information.

AUTOMATED DECISION-MAKING

Automated decision-making takes place when an electronic system uses personal information to make a decision about that person without any human intervention which produces legal effects concerning them or similarly significantly affects them. We do not currently use this type of automated decision making in our business in relation to you.

You will not be subject to decisions that will have a significant impact on you based solely on automated decision making unless we have a lawful basis for doing so and we have notified you.

However, we do use automated processing so that we can show you personalised advertisements whilst browsing our website or those of other companies. Any advertisements you see may relate to your browsing activity on our website from your computer or other devices.

These advertisements are provided by us via external market leading specialist providers using techniques such as pixels, web beacons, ad tags, mobile identifiers and ‘cookies’ placed on your computer or other devices. For further information on the use of cookies, or for details of how you can remove or disable cookies at any time - see our cookie policy

We may analyse your browsing and purchasing activity online and your responses to marketing communications. The results of this analysis, together with other demographic data, allow us to decide what advertisements are suitable for you and to ensure that we draw to your attention products, services, events and offers that are tailored and relevant to you. To do so, we use software and other technology for automated processing. This allows us to provide a more personalised service and experience.

We may also review personal information held about you by external social media platform providers, such as the personal information available on social media platforms such as Twitter, Instagram, YouTube, Twitter and Facebook.

We aim to update you about products and services which are of interest and relevance to you as an individual.  To help us do this, we process personal data by profiling and segmenting, identifying what our customers like and ensuring advertisements we show you are more relevant based on demographics, interests, purchase behaviour, online web browsing activity and engagement with previous communications.

WHO HAS INTERNAL ACCESS TO YOUR PERSONAL INFORMATION?

Your personal information may be shared internally with our staff, (including with our managers, researchers, procurement team, media, insights, events, campaign, tech and legal teams and senior staff in the business area involved in your relationship with us) where access to your personal information is necessary for the performance of their roles. We only provide access to your personal information to those of our staff who need to have access to your personal information.

WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH EXTERNALLY?

When using your personal information we may share it with third parties but we will only do so when it is appropriate and we have a legal basis for doing so. Third parties that we may share your personal information with include:

• Any third party approved by you.
• An organisation you work for or that represents you if that organisation has a relationship with us.
• Service or product providers to our business, for example information technology services suppliers, credit reference agencies, modelling agencies, talent agencies, marketing and public relations service providers.
• If you are connected to one of our suppliers, to other companies in the supply chain so they can contact you about any supply chain issues.
• Third parties that process personal information on our behalf and in accordance with our instructions.
• Another company within our group of companies, especially if you may have a relationship with that part of our group.
• Purchasers, investors, funders and their advisers if we sell all or part of our business, assets or shares or restructure whether by merger, re-organisation or in another way.
• Our legal and other professional advisers, including our auditors or any professional advisors appointed by you, for example a legal advisor or an agency you work with.
• Third party record keepers, for example to maintain our share register or to make filings at Companies House.
• Social media and other online platforms where relevant to our relationship with you.
• Governmental bodies, HMRC, regulators, police, law enforcement agencies, security services, courts/tribunals.

We also use Google Analytics which sets cookies to collect information about how visitors use our website. See our Cookie Policy here. We use the information to compile reports and to help us improve the website. The cookies collect information in an anonymous form, including the number of visitors to the website and blog, where visitors have come to the website from and the pages they visited.  To opt out of being tracked by Google Analytics across all websites visit Google Analytics Opt-out.

We also work with Awin Limited who may collect information when you interact with our site. The collection and use of this information is subject to Awin’s privacy policy which can be found here.

We do not disclose personal information to anyone else except as set out above unless we are legally entitled to do so. We may provide third parties with aggregate statistical information and analytics about users of our products and services but we will make sure no one can be identified from this information before we disclose it.

INTERNATIONAL TRANSFERS

It is sometimes necessary to share your personal information outside of the UK and/or the European Economic Area (the EEA) or it will be collected outside of the UK and/or the EEA. This will typically occur when service providers to our business are located outside the EEA or if you are based outside the EEA.  These transfers are subject to special rules under data protection laws.

The same applies to any transfer of personal information to another part of our group of companies based outside of the UK and/or the EEA. We also apply the same standards to any transfer of personal information between members of our group, regardless of where the group company is based.

If we transfer your personal information outside of the UK and/or the EEA, we will ensure that the transfer will be compliant with applicable data protection laws and all personal information will be secure.  Our standard practice is to assess the laws and practices of the destination country and relevant service provider and the security measures that are to be taken as regards the personal Information in the overseas location; alternatively, we use standard data protection/contractual clauses. This means that when a transfer such as this takes place, you can expect a similar degree of protection in respect of your personal information.

Our directors and other key staff working for us may in limited circumstances access personal information from outside of the UK and/or EEA if they are on holiday abroad outside of the UK or EEA. If they do so they will be using our security measures and the same legal protections will apply that would apply to accessing personal information from our premises.

In limited circumstances the people to whom we may disclose personal information may be located outside of the UK and EEA and we will not have an existing relationship with them, for example a foreign police force outside of the UK and/or the EEA. In these cases we will impose any legally required protections to the personal information as required by law before it is disclosed.

Also if you are based outside of the UK and/or EEA, then your personal data may all or mainly be held and used outside of the UK and/or EEA anyway, for example if you are a supplier to us dealing with a member of our group located outside of the UK or EEA.

If you would like any more details about how we protect your personal information in relation to international transfers then please contact our DPO at mydata@boxraw.com.

HOW DO WE PROTECT YOUR PERSONAL INFORMATION?

We are committed to keeping your personal information safe and secure and so we have numerous security measures in place to protect against the loss, misuse, and alteration of information under our control. We will always aim to use best in class security systems implemented across our networks and hardware to ensure access and information are protected. Our security measures include:

• Encryption of personal information where appropriate.
• Regular cyber security assessments of all service providers who may handle your personal information.
• Regular planning and assessments to ensure we are ready to respond to cyber security attacks and data security incidents.
• Regular penetration testing of systems.
• Security controls which protect our information technology systems infrastructure and our premises from external attack and unauthorised access.
• Regular backups of information technology systems data with functionality to correct errors or accidental deletion/modification to data.
• Internal policies setting out our information security rules for our staff.
• Regular training for our staff to ensure staff understand the appropriate use and processing of personal information.
• Where we engage third parties to process personal information on our behalf, they do so on the basis of our written instructions, they are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of personal information.

We take information security very seriously and will use all reasonable endeavours to protect the integrity and security of the personal information we collect about you.

FOR HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

We will hold your personal information for the duration of your relationship with us and then usually for a further period of up to 6 years after that. However, for some business relationships, for example those relating to land or leases of premises, we may need to keep records for 12 years or more. Whichever time period normally applies, in some cases we may need to keep your personal information for longer, for example if it is still relevant to a dispute or legal case or claim.

We will not retain your personal information for longer than necessary for the purposes for which it was collected and it is being used. We do not guarantee to retain your personal information for the whole of the periods set out above; they are usually the maximum period, and in some cases we may keep your personal information for a much shorter period.

For more information please see our Data Retention Policy which can be obtained from our DPO at mydata@boxraw.com.

YOUR RIGHTS

As an individual whose personal information we collect and process, you have a number of rights. You may:

• Withdraw any consent you have given to us, although this will only be relevant where we are relying on your consent as a lawful basis to use your personal information, but it is an absolute right. Once we have received notification that you have withdrawn your consent, we will no longer process your personal information for the purpose or purposes for which you originally gave your consent, unless we have another lawful basis for doing so.
• Request details about how your personal information is being used. This right is linked with the right of access mentioned below.
• Request access and obtain details of your personal information that we hold (this is commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This means that you can ask us to delete or stop processing your personal information, for example where we no longer have a reason to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (set out below). The right to have data erased does not apply in all circumstances.
• Object to the processing of your personal information where we are relying on a legitimate interest (ours or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
• Object to direct marketing where we are processing your personal information for direct marketing purposes, for example contacting you about products that might interest you. This is an absolute right.
• Request the restriction of processing of your personal information. This enables you to ask us to stop processing your personal information for a period if data is inaccurate or there is a dispute about whether or not your interests override our legitimate grounds for processing data.
• Request the transfer of your personal information to another party in certain circumstances.
• Object to certain automated decision making processes using your personal information.

You should note that some of these rights, for example the right to require us to transfer your personal information to another service provider or the right to object to automated decision making, may not always apply as they have specific requirements and exemptions which apply to them and they may not apply to personal information recorded and stored by us. Also, for example we do not use automated decision making in relation to your personal information which has legal or other significant effects for you, but we do use automated processing to show you relevant advertisements. However, some of your rights have no conditions attached, so your right to withdraw consent or object to processing for direct marketing are absolute rights.

If you would like to exercise any of these rights, please contact our DPO at mydata@boxraw.com.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person or dealt with by a person who has no right to do so.

Whilst this privacy notice sets out a general summary of your legal rights in respect of personal information, this is a complex area of law. More information about your legal rights can be found on the ICO’s website here.

COMPLAINTS

We hope you don’t have any reason to complain, and we will always try to resolve any issues you have. If you are base in the UK you have the right to make a complaint at any time to the ICO (the UK data protection regulator) about how we deal with your personal information or your rights in relation to your personal information. If you are based outside of the UK you may have the right to complain to your local data protection regulator. You can make a compliant in writing to the ICO, Wycliffe House, Water Lane, Wilmslow, SK9 5AF, United Kingdom or you can go to here.

If you are based outside of the UK, you may have the right to complain to your local data protection regulator – we recommend checking your rights on the website of your local data protection regulator.

CONTACTING US

If you have any queries regarding our use of your personal information or this privacy notice then please contact our DPO at mydata@boxraw.com or write to DPO, Boxraw Limited, Ground & First Floor Offices, Herbert Art Gallery, Jordan Well, Coventry, England, CV1 5QP. You can use these details regardless of which of our group companies you have a relationship with.