Breadalbane Privacy Commitment

Breadalbane has worried about customer and user privacy for 5 years, long before it became fashionable, politically correct, or legally binding to take such a position. We ask for only the least amount of information necessary, gathering only what we believe is essential for doing business, or for the specific transaction at hand. We let customers know the information we have on them and allow them to opt out of specific engagements. But, by far, our biggest commitment is that we do not make any income from advertising revenue. This means we avoid the fundamental conflict of interest between gathering customer information and fuelling advertising revenue, and the unavoidable compromises in customer privacy that it brings.

The goal of this policy is to make explicit the information we gather on our customers and users, how we will use it, and how we will not. This policy is unfortunately longer than we would like, but we must unambiguously address all the relevant cases. We will try and keep the language simple and direct as much as possible.

Scope of this Privacy Policy

This Privacy Policy applies to all Breadalbane websites that link to it. It also applies to the products and services provided by Breadalbane through these websites, our mobile applications, and applications posted by Breadalbane on Breadalbane’s online marketplace and in other third-party online marketplaces. This Privacy Policy does not apply to any of our websites, products or services that have a separate privacy policy.

Part I – Information Breadalbane collects and controls

This part deals with how Breadalbane collects and uses information about website visitors, potential customers, users of Breadalbane’s products and services, and others who contact Breadalbane through forms or email addresses published on or linked to our websites.

Part II – Information that Breadalbane processes on your behalf

This part deals with how Breadalbane handles data that you entrust to Breadalbane when you use our products and services, or when you share any personal or confidential information with us while requesting customer support.

Part III – General

This part deals with topics that are relevant to both Parts I and II, and other general topics such as Breadalbane’s security commitments and how we will inform you when we change this Privacy Policy.

Part I – Information Breadalbane collects and controls

What information Breadalbane collects

We collect information about you only if we need the information for some legitimate purpose. Breadalbane will have information about you only if (a) you have provided the information yourself, (b) Breadalbane has automatically collected the information, or (c) Breadalbane has obtained the information from a third party. Below we describe the various scenarios that fall under each of those three categories and the information collected in each one.

Information that you provide us

i. Account signup

When we make a funding enquiry on your behalf to our panel of funders, we ask for information like your name, contact number, email address and company name to complete the initial diligence process. You may also provide us with more information such photographic identification to comply with anti-money laundering regulations. You may also provide financial details about you and/or your business. This information can also be passed to our panel of funders with your prior consent.

ii. Event registrations and other form submissions

We record information that you submit when you (i) register for any event, including webinars or seminars, (ii) subscribe to our newsletter or any other mailing list, (iii) submit a form in order to download any product, whitepaper, or other materials, (iv) participate in contests or respond to surveys, or (v) submit a form to request customer support or to contact Breadalbane for any other purpose.

iii. Testimonials

When you authorize us to post testimonials about our products and services on websites, we may include your name and other personal information in the testimonial. You will be given an opportunity to review and approve the testimonial before we post it. If you wish to update or delete your testimonial, you can contact us at info@breadalbanefinance.co.uk

iv. Interactions with Breadalbane

We may record, analyse and use your interactions with us, including email, telephone, and chat conversations with our panel of funders and colleagues, for improving our interactions with you and other customers.

Information that we collect automatically

i. Information from browsers, devices and servers

When you visit our website, we collect information that web browsers, mobile devices and servers make available, such as the internet protocol address, browser type, language preference, time zone, referring URL, date and time of access, operating system, mobile device manufacturer and mobile network information. We include these in our log files to understand more about visitors to our websites.

ii. Information from first party cookies and tracking technologies

We use temporary and permanent cookies to identify users of our services and to enhance user experience. We embed unique identifiers in our downloadable products to track usage of the products. We also use cookies, beacons, tags, scripts, and other similar technologies to identify visitors, track website navigation, gather demographic information about visitors and users, understand email campaign effectiveness and for targeted visitor and user engagement by tracking your activities on our websites. We only use first-party cookies and do not use third-party cookies or other third-party tracking technologies on our websites. You can learn more about the cookies used on our websites. We also use first-party Local Storage Objects (LSOs) such as HTML5 to store content information and preferences to provide certain features.

iii. Information from application logs and mobile analytics

We collect information about your use of our products, services and mobile applications from application logs and in-house usage analytics tools, and use it to understand how your business use and needs can improve our products. This information includes clicks, scrolls, features accessed, access time and frequency, errors generated, performance data, storage utilized, user settings and configurations, and devices used to access and their locations.

Information that we collect from third parties

i. Signups using federated authentication service providers

: You can log in to Breadalbane Services using supported federated authentication service providers such as LinkedIn, Microsoft and Google. These services will authenticate your identity and give you the option to share certain personal information with us, such as your name and email address.

ii. Referrals

If someone has referred any of our products or services to you through any of our referral programs, that person may have provided us your name, email address and other personal information. You may contact us at info@breadalbanefinance.co.uk to request that we remove your information from our database. If you provide us information about another person, or if another person gives us your information, we will only use that information for the specific reason for which it was provided to us.

iii. Information from our reselling partners and service providers

If you contact any of our reselling partners, or otherwise express interest in any of our products or services to them, the reselling partner may pass your name, email address, company name and other information to Breadalbane. If you register for or attend an event that is sponsored by Breadalbane, the event organizer may share your information with us. Breadalbane may also receive information about you from review sites if you comment on any review of our products and services, and from other third-party service providers that we engage for marketing our products and services.

iv. Information from social media sites and other publicly available sources

When you interact or engage with us on social media sites such as Facebook, Twitter, Google+ and Instagram through posts, comments, questions and other interactions, we may collect such publicly available information, including profile information, to allow us to connect with you, improve our products, or better understand user reactions and issues. We must tell you that once collected, this information may remain with us even if you delete it from the social media sites. Breadalbane may also add and update information about you, from other publicly available sources.

Purposes for using information

In addition to the purposes mentioned above, we may use your information for the following purposes:

• To communicate with you (such as through email) about products and services that you have signed up for, changes to this Privacy Policy, changes to the Terms of Service, or important notices;

• To keep you posted on new products and services, upcoming events, offers, promotions and other information that we think will be of interest to you;

• To ask you to participate in surveys, or to solicit feedback on our products and services;

• To set up and maintain your account, and to do all other things required for providing our services, such as enabling collaboration, providing website and mail hosting, and backing up and restoring your data;

• To understand how users, use our products and services, to monitor and prevent problems, and to improve our products and services;

• To provide customer support, and to analyse and improve our interactions with customers;

• To detect and prevent fraudulent transactions and other illegal activities, to report spam, and to protect the rights and interests of Breadalbane, Breadalbane’s users, third parties and the public;

• To update, expand and analyse our records, identify new customers, and provide products and services that may be of interest to you;

• To analyse trends, administer our websites, and track visitor navigations on our websites to understand what visitors are looking for and to better help them;

• To monitor and improve marketing campaigns and make suggestions relevant to the user.

Legal bases for collecting and using information

Legal processing bases applicable to Breadalbane

If you are an individual from the European Economic Area (EEA), our legal basis for information collection and use depends on the personal information concerned and the context in which we collect it. Most of our information collection and processing activities are typically based on (i) contractual necessity, (ii) one or more legitimate interests of Breadalbane or a third party that are not overridden by your data protection interests, or (iii) your consent. Sometimes, we may be legally required to collect your information, or may need your personal information to protect your vital interests or those of another person.

Withdrawal of consent

Where we rely on your consent as the legal basis, you have the right to withdraw your consent at any time, but this will not affect any processing that has already taken place.

Legitimate interests notice

Where we rely on legitimate interests as the legal basis and those legitimate interests are not specified above, we will clearly explain to you what those legitimate interests are at the time that we collect your information.

Your choice in information use

Opt out of non-essential electronic communications

ou may opt out of receiving newsletters and other non-essential messages by using the ‘unsubscribe’ function included in all such messages. However, you will continue to receive notices and essential transactional emails.

Disable cookies

You can disable browser cookies before visiting our websites. However, if you do so, you may not be able to use certain features of the websites properly.

Optional information

You can choose not to provide optional profile information such as your photo. You can also delete or change your optional profile information. You can always choose not to fill in non-mandatory fields when you submit any form linked to our websites.

Who we share your information with

All Breadalbane group entities listed here have access to the information covered in Part I. We do not sell any personal information. We share your information only in the ways that are described in this Privacy Policy, and only with parties who adopt appropriate confidentiality and security measures.

Employees and independent contractors

Employees and independent contractors of all Breadalbane group entities have access to the information covered in Part I on a need-to-know basis. We require all employees and independent contractors of Breadalbane group entities to follow this Privacy Policy for personal information that we share with them.

Third-party service providers

We may need to share your personal information and aggregated or de-identified information with third-party service providers that we engage, such as marketing and advertising partners, event organizers, web analytics providers and payment processors. These service providers are authorized to use your personal information only as necessary to provide these services to us.

Domain registrars

When you register a domain through Breadalbane from domain name registrars, we share your name and contact information such as your physical address, email address and phone number with them as per the ICANN domain registration rules.

Reselling partners

We may share your personal information with our authorized reselling partners in your region, solely for the purpose of contacting you about products that you have downloaded or services that you have signed up for. We will give you an option to opt out of continuing to work with that partner.

Marketplace application developers

When you install or purchase any application developed using Breadalbane’ s APIs that is posted on Breadalbane’ s online marketplace, your name and email address will be shared with the developer of the application, so they may engage with you directly as the provider of that application or service. Breadalbane does not control the use of your personal information by the developers, which will be based on their own privacy policies.

Other cases

Other scenarios in which we may share the same information covered under Parts I and II are described in Part III.

Your rights with respect to information we hold about you as a controller

If you are in the European Economic Area (EEA), you have the following rights with respect to information that Breadalbane holds about you. Breadalbane undertakes to provide you the same rights no matter where you choose to live.

Right to access

You have the right to access (and obtain a copy of, if required) the categories of personal information that we hold about you, including the information’s source, purpose and period of processing, and the persons to whom the information is shared

Right to rectification

You have the right to update the information we hold about you or to rectify any inaccuracies. Based on the purpose for which we use your information, you can instruct us to add supplemental information about you in our database.

Right to deletion

You have the right to request that we delete your personal information in certain circumstances, such as when it is no longer necessary for the purpose for which it was originally collected.

Right to restriction of processing

You may also have the right to request to restrict the use of your information in certain circumstances, such as when you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Right to data portability

You have the right to transfer your information to a third party in a structured, commonly used and machine-readable format, in circumstances where the information is processed with your consent or by automated means.

Right to object

You have the right to object to the use of your information in certain circumstances, such as the use of your personal information for direct marketing.

Right to complain

You have the right to complain to the appropriate supervisory authority if you have any grievance against the way we collect, use or share your information. This right may not be available to you if there is no supervisory authority dealing with data protection in your country.

Retention of information

We retain your personal information for as long as it is required for the purposes stated in this Privacy Policy. Sometimes, we may retain your information for longer periods as permitted or required by law, such as to maintain suppression lists, prevent abuse, if required in connection with a legal claim or proceeding, to enforce our agreements, for tax, accounting, or to comply with other legal obligations. When we no longer have a legitimate need to process your information, we will delete or anonymize your information from our active databases. We will also securely store the information and isolate it from further processing on backup discs until deletion is possible.

Part II – Information that Breadalbane processes on your behalf

Information entrusted to Breadalbane and purpose

Information provided in connection with services: You may entrust information that you or your organisation (“you”) control, to Breadalbane in connection with use of our services or for requesting technical support for our products. This includes information regarding your customers and your employees (if you are a controller) or data that you hold and use on behalf of another person for a specific purpose, such as a customer to whom you provide services (if you are a processor). The data may either be stored on our servers when you use our services or transferred or shared to us as part of a request for technical support or other services.

Information from mobile devices

When you elect to allow it, some of our mobile applications may have access to the camera, call history, contact information, photo library, and other information stored on your mobile device. Our applications require such access to provide their services. Similarly, when you elect to provide access, location-based information is also collected for purposes including, but not limited to, locating nearby contacts or setting location-based reminders. This information will be exclusively shared with our mapping providers and will be used only for mapping user locations. You may disable the mobile applications’ access to this information at any time by editing the settings on your mobile device. The data stored on your mobile device and their location information to which the mobile applications have access will be used in the context of the mobile application and transferred to and associated with your account in the corresponding services (in which case the data will be stored on our servers) or products (in which case the data will remain with you unless you share it with us).

(All the information entrusted to Breadalbane is collectively termed “service data”)

Ownership and control of your service data

We recognise that you own your service data. We provide you complete control of your service data by providing you the ability to (i) access your service data, (ii) share your service data through supported third-party integrations, and (iii) request export or deletion of your service data.

How we use service data

We process your service data when you provide us instructions through the various modules of our services. For example, when you generate an invoice, information such as the name and address of your customer or supplier will be used to generate the invoice; and when you use our campaign management service for email marketing, the email addresses of the persons on your mailing list will be used for sending the emails.

Who we share service data with

Breadalbane group and third party sub-processors

In order to provide services and technical support for our products, the contracting entity within the Breadalbane group engages other group entities and third parties.

Employees and independent contractors

We may provide access to your service data to our employees and individuals who are independent contractors of the Breadalbane group entities involved in providing the services (collectively our “employees”) so that they can (i) identify, analyse and resolve errors, (ii) manually verify emails reported as spam to improve spam detection, or (iii) manually verify scanned images that you submit to us to verify the accuracy of optical character recognition. We ensure that access by our employees to your service data is restricted to specific individuals and is logged and audited. Our employees will also have access to data that you knowingly share with us for technical support or to import data into our products or services. We communicate our privacy and security guidelines to our employees and strictly enforce privacy safeguards within the Breadalbane group.

Other cases

Other scenarios in which we may share information that are common to information covered under Parts I and II are described in Part III.

Retention of information

We hold the data in your account as long as you choose to use Breadalbane Services. Once you inform us you wish to terminate your dealings with Breadalbane, your data will eventually get deleted from active database during the next clean-up that occurs once in 6 months. The data deleted from active database will be deleted from backups after 3 months.

Data subject requests

If you are from the European Economic Area and you believe that we store, use or process your information on behalf of one of our customers or funders, please contact the customer or funder if you would like to access, rectify, erase, restrict or object to processing, or export your personal data. We will extend our support to our customers in responding to your request within a reasonable timeframe.

Part III – General

Children’s personal information

Our products and services are not directed to individuals under 16. Breadalbane does not knowingly collect personal information from children who are under 16 years of age. If we become aware that a child under 16 has provided us with personal information, we will take steps to delete such information. If you believe that a child under 16 years has provided personal information to us, please write to info@breadalbanefinance.co.uk with the details, and we will take the necessary steps to delete the information we hold about that child.

How secure is your information?

At Breadalbane, we take data security very seriously and have taken all reasonable steps to ensure the ongoing security of any data we hold on you personally.

Data Protection Officer

We have appointed a Data Protection Officer to oversee our management of your personal information in accordance with this Privacy Policy. If you have any questions or concerns about our privacy practices with respect to your personal information, you can reach out to our Data Protection Officer by sending an email to info@Breadalbanefinance.co.uk or by writing to: Data Protection Officer, Breadalbane Corporate Solutions Ltd, 7 Hopetoun Crescent, Edinburgh, EH7 4AY.

Locations and international transfers

We share your personal information and service data within the Breadalbane Group. By accessing or using our products and services or otherwise providing personal information or service data to us, you consent to the processing, transfer, and storage of your personal information or Service Data within the United States of America, the European Economic Area (EEA) and other countries where Breadalbane operates. Such transfer is subject to a group company agreement that is based on EU Commission’s Model Contractual Clauses.

Data processing addendum

To enable you to be compliant with the data protection obligations under the General Data Protection Regulation, we are prepared to sign a Data Processing Addendum (DPA) that is based on Standard Contractual Clauses. You can request a DPA from Breadalbane by completing this form . Once we get your request, we’ll forward the DPA to you for your signature.

Do Not Track (DNT) requests

Some internet browsers have enabled ‘Do Not Track’ (DNT) features, which send out a signal (called the DNT signal) to the websites that you visit indicating that you don’t wish to be tracked. Currently, there is no standard that governs what websites can or should do when they receive these signals. For now, we do not take action in response to these signals.

External links on our websites

Some pages of our websites may contain links to websites that are not linked to this Privacy Policy. If you submit your personal information to any of these third-party sites, your personal information is governed by their privacy policies. As a safety measure, we recommend that you not share any personal information with these third parties unless you’ve checked their privacy policies and assured yourself of their privacy practices.

Blogs and forums

We offer publicly accessible blogs and forums on our websites. Please be aware that any information you provide on these blogs and forums may be used to contact you with unsolicited messages. We urge you to be cautious in disclosing personal information in our blogs and forums. Breadalbane is not responsible for the personal information you elect to disclose publicly. Your posts and certain profile information may remain even after you terminate your account with Breadalbane. To request the removal of your information from our blogs and forums, you can contact us at info@breadalbanefinance.co.uk

Social media widgets

Our websites include social media widgets such as Facebook “like” buttons and Twitter “tweet” buttons that let you share articles and other information. These widgets may collect information such as your IP address and the pages you navigate in the website and may set a cookie to enable the widgets to function properly. Your interactions with these widgets are governed by the privacy policies of the companies providing them.

Disclosures in compliance with legal obligations

We may be required by law to preserve or disclose your personal information and service data to comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements.

Enforcement of our rights

We may disclose personal information and service data to a third party if we believe that such disclosure is necessary for preventing fraud, investigating any suspected illegal activity, enforcing our agreements or policies, or protecting the safety of our users.

Business Transfers

We do not intend to sell our business. However, in the unlikely event that we sell our business or get acquired or merged, we will ensure that the acquiring entity is legally bound to honour our commitments to you. We will notify you via email or through a prominent notice on our website of any change in ownership or in the uses of your personal information and service data. We will also notify you about any choices you may have regarding your personal information and service data.

Compliance with this Privacy Policy

We make every effort, including periodic reviews, to ensure that personal information you provide is used in conformity with this Privacy Policy. If you have any concerns about our adherence to this Privacy Policy or the manner in which your personal information is used, kindly write to us info@breadalbanefinance.co.uk We’ll contact you, and if required, coordinate with the appropriate regulatory authorities to effectively address your concerns.

Notification of changes

We may modify the Privacy Policy at any time, upon notifying you through a service announcement or by sending an email to your primary email address. If we make significant changes to the Privacy Policy that affect your rights, you will be provided with at least 30 days’ advance notice of the changes by email to your primary email address. If you think that the updated Privacy Policy affects your rights with respect to your use of our products or services, you may terminate your use by sending us an email within 30 days. Your continued use after the effective date of changes to the Privacy Policy will be deemed to be your agreement to the modified Privacy Policy. You will not receive email notification of minor changes to the Privacy Policy.