Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
Important information and who we are
We are Bitwise Limited. We are a company incorporated and registered in Scotland. Our company number is SC107588. Our registered address is Crescent House, Carnegie Campus, Dunfermline, KY11 8GR.
When we refer to “we”, “us” or “our” in this policy, we are referring to Bitwise Limited. We are the data ‘controller’ in relation to the personal data you provide to us, which means we determine the purposes and the way in which your personal data is, or will be, processed.
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave one of our websites, we encourage you to read the privacy notice of every website you visit.
How is your personal data collected?
We use different methods to collect data from and about you including through:
• Direct interactions. You may give us your personal data by filling in forms or by corresponding with us in person, by email, by phone, by post or otherwise.
• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see below on Cookies for further information.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources. For example, analytics providers such as Google.
Information we collect from you
We may collect and process the following data about you:
• Customer Data. Where you are a contact at one of our customers we may retain your contact details.
• Correspondence Data. If you contact us, we may keep a record of that correspondence.
• Prospect Data. Where you are a contact at a prospective customer we may retain your contact details and related details of our interactions with you.
• Supplier Data. Where you are a contact at one of our suppliers we may retain your contact details.
• Job Applicant Data. We may keep a record of your personal data in order that we can consider your application.
• Technical Data. When you browse our website, we automatically collect some technical information about your visit to our website, including, but not limited to, the IP address used to connect your computer to the internet, your browser type and version and your browser plug-in types and version.
How do we use your personal data?
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where we have your prior consent to use your personal data .
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting us.
• Where we need to comply with a legal or regulatory obligation.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Disclosure of your information
We may have to share your personal information with the following third parties:
• External third-party service providers acting as processors who provide the following services:
- Web hosting; and
- Metrics and analytics.
• Please note this may include international service providers.
• Professional advisers, including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors, controllers or joint controllers who require reporting of processing activities in certain circumstances. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
• If Bitwise Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
If we transfer your personal data out of the EEA, we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
• The country has been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• If we use certain service providers based out with the EEA, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
• If we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
• In any other case, we will obtain your explicit consent before any transfer takes place.
Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place appropriate security measures in accordance with industry best practice to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We have various ISO certifications including ISO 27001, which covers Information Security Management. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
All information you provide to us is securely stored.
How long we store your personal data for
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Where we anonymise your personal data (i.e. so that it can no longer be associated with you) for further research or statistical purposes, then we may use this information indefinitely without further notice to you.
What are cookies?
A cookie is a text file containing a small amount of information that is sent to your browser when you visit a website. The cookie is then sent back to the originating website on each subsequent visit, or to another website that recognises it. Cookies are an extremely useful technology and do lots of different jobs.
What cookies do we use?
These fall into the following categories:
• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to complete the contact form on our web site.
• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. Our site uses Google Analytics (GA) to track user interaction. We use this data to determine the number of people using our site, to better understand how they find and use our web pages and to see their journey through the website. Although GA records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us. GA also records your computer’s IP address which could be used to personally identify you but Google do not grant us access to this.
Important information about cookies
You have the option to reject the cookies being used on our website or you can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you block all cookies (including essential cookies) you may not be able to access all or parts of our site.
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
If you wish to exercise any of the rights set out above, please Contact us. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Access to your information
You have the right to ask for a copy of the information which we hold on you (commonly known as a ‘data subject access request’).
This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Correcting personal data
You have the right to request that we correct personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold corrected, though we may need to verify the accuracy of the new data that you provide to us.
Deleting personal data
You may ask us to delete or remove personal data where there is no good reason for us continuing to process it. This is more commonly known as the ‘right to be forgotten’. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
Please note, however, that we may not always be able to comply with your request to delete or remove personal data for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Objecting to processing
You have the right to stop us processing your personal data for direct marketing purposes. You can also exercise the right at any time by contacting us at Contact us.
You may also object to us processing your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Restriction of processing
This enables you to ask us to suspend the processing of your personal data in the following scenarios:
• if you want us to establish the data’s accuracy;
• where our use of the data is unlawful but you do not want us to erase it;
• where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
• you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Transferring your personal data
In certain circumstances, you may request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.
Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Where we are relying on consent to process your personal data you can withdraw your consent at any time. Please note that this will not affect the lawfulness of any processing carried out before you withdraw your consent.
Review by an independent authority
You will always have the right to lodge a complaint with a supervisory body. The relevant authority in the UK is the Information Commissioner’s Office. If you do have a complaint, we would appreciate the chance to deal with your concerns before you approach the ICO, so please do Contact us in the first instance if possible.
This version was last updated on 22nd September 2018.
Historic version of this policy can be obtained by Contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Questions, comments and requests regarding this policy are welcomed and should be addressed to our Data Protection Officer at Crescent House, Carnegie Campus, Dunfermline, KY11 8GR.