Definitions and interpretation 1. In this privacy policy, the following definitions are used:

Data
collectively all information that you submit to SBEM Ltd via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;

Data Protection Laws
any applicable law relating to the processing of personal Data, including but not limited to the Directive 96/46/EC (Data Protection Directive) or the GDPR, and any national implementing laws, regulations and secondary legislation, for as long as the GDPR is effective in the UK;

GDPR
the General Data Protection Regulation (EU) 2016/679;

SBEM Ltd, or us
SBEM Ltd, a company incorporated in England and Wales with registered number 07287228 whose registered office is at 1 Harbour House, Harbour Way, Shoreham by Sea, West Sussex, BN43 5HZ;

User or you
any third party that accesses the Website and is not either (i) employed by SBEM Ltd and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to SBEM Ltd and accessing the Website in connection with the provision of such services; and

Website
the website that you are currently using, www.sbemltd.co.uk

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2. In this privacy policy, unless the context requires a different interpretation:

• a. the singular includes the plural and vice versa;
• b. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;
• c. a reference to a person includes firms, companies, government entities, trusts and partnerships;
• d. “including” is understood to mean “including without limitation”;
• e. reference to any statutory provision includes any modification or amendment of it;

Scope of this privacy policy

3. This privacy policy applies only to the actions of SBEM Ltd and Users with respect to this Website.

4. For purposes of the applicable Data Protection Laws, SBEM Ltd is the “data controller”. This means that SBEM Ltd determines the purposes for which, and the way, your Data is processed.

Data collected

5. We may collect the following Data, which includes personal Data, from you:

• a.name;
• b.date of birth;
• c.gender;
• d.contact Information such as email addresses and telephone numbers;

in each case, in accordance with this privacy policy.

How we collect Data

6. We collect Data in the following ways:

• a.data is given to us by you;
• b.and data is collected automatically.

Data that is given to us by you

7.  SBEM Ltd will collect your Data in several ways, for example:

• a.when you contact us through the Website, by telephone, post, e-mail or through any other means;
• b.when you complete surveys that we use for research purposes (although you are not obliged to respond to them);
• c.when you elect to receive marketing communications from us;
• d. when you use our services;

in each case, in accordance with this privacy policy.

Data that is collected automatically

8. To the extent that you access the Website, we will collect your Data automatically, for example:

• a.we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.

Our use of Data

9. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:

• a.internal record keeping;

in each case, in accordance with this privacy policy.

Who we share Data with

10. We may share your Data with the following for the following reason:

•  a.our employees, agents and/or professional advisors – to assess a new contractor to suitable roles; to make payment to contractors for completed assignments and to obtain advice from professional advisors ;

in each case, in accordance with this privacy policy.

Keeping Data secure

11. We will use technical and organisational measures to safeguard your Data, for example:

• a.access to your account is controlled by a password and a user name that is unique to you.
• b.we store your Data on secure servers.

12. We are certified to PCI DSS. This family of standards helps us manage your Data and keep it secure.

13. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: admin@sbemltd.co.uk.

14. If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

Data retention

15. Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this privacy policy or until you request that the Data be deleted.

16. Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

Your rights

17. You have the following rights in relation to your Data:

• a.Right to access – the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
• b.Right to correct – the right to have your Data rectified if it is inaccurate or incomplete.
• c.Right to erase – the right to request that we delete or remove your Data from our systems.
• d.Right to restrict our use of your Data – the right to “block” us from using your Data or limit the way in which we can use it.
• e.Right to data portability – the right to request that we move, copy or transfer your Data.
• f.Right to object – the right to object to our use of your Data including where we use it for our legitimate interests.

18. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: Sally@sbemltd.co.uk.

19. If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk/.

20. It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

General

21. You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.

22. If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.

23. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

24. This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.

Changes to this privacy policy

25. SBEM Ltd reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations.

You may contact SBEM Ltd by email at admin@sbemltd.co.uk.

01 October 2020