Byte Privacy Notice

1. INTRODUCTION

Byte respects your privacy and is committed to protecting your personal data. This Privacy Notice tells you how we look after your personal data in your interactions with us both online and offline, and it tells you about your privacy rights and how the law protects you.

2. PURPOSE OF THIS PRIVACY NOTICE

This Privacy Notice gives you information about how Byte collects and processes your personal data through your use of our websites, chatbot and your other dealings with us both online and offline, including any data you may provide to us when you apply for a job with us, provide services to us of any kind, sign up to our newsletters, take part in a competition, or visit us at our offices.

Our websites and chatbot are not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

3. CONTROLLER

Byte is made up of different legal entities which together form the Byte Club. Full details of all of those entities are at the end of this Privacy Notice in the Byte Club section.

This Privacy Notice is issued on behalf of the whole Byte Club so when we mention “Byte“, “we“, “us” or “our” in this Privacy Notice, we are referring to the relevant company in the Byte Club responsible for processing your data.

Byte London Limited is the controller and responsible for the Byte London website, the Byte chatbot and any communications with Byte which originate in the UK.

Byte New York, Inc is the controller and responsible for the Byte New York website and any communications with Byte which originate in the USA.

4. CONTACT DETAILS

If you have any questions about this Privacy Notice, including any requests to exercise Your legal rights, please contact us at dataprotection@bytelondon.com. You can also contact us at our offices as set out in the Byte Club section below.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us at dataprotection@bytelondon.com in the first instance.

5. CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

It is important that the personal data we hold about you is accurate and current. Please tell us at dataprotection@bytelondon.com if your personal data changes during your relationship with us.

6. THIRD PARTY LINKS

Our websites and chatbot 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 our websites, we encourage you to read the privacy notice of every website you visit.

7. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

Identity Data includes first name, last name, previous names, username or similar identifier, marital status, title, date of birth, gender and CCTV images.
Contact Data includes postal address, email address and telephone numbers.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our websites or chatbot.
Profile Data includes your username and password, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our websites, chatbot and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and third parties acting on our behalf and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

8. IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

9. 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 Identity, Contact Data by filling in forms or by corresponding with us by any method. This includes personal data you provide when you:

apply for a job with us or provide any services to us;
interact with us through our websites or chatbot;
register your details or create an account on our websites;
subscribe to our service or publications;
request marketing to be sent to you;
enter a competition, promotion or survey;
give us some feedback; or
visit our offices which have CCTV systems operated for the security of both our visitors and staff.

Automated technologies or interactions. As you interact with our websites, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. More information is set out in the Cookies section below.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

Technical Data from the following parties:

(a) analytics providers such as Google which has operations outside the EU;

(b) social media platforms such as facebook which has operations outside the EU; and

Identity and Contact Data from publicly availably sources such as Companies House, the Land Registry and the Electoral Register based inside the EU.

10. HOW 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, known as the legal grounds or legal bases of processing:

Where we need to perform the contract we are about to enter into or have entered into with you.
This means we process your data because it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
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.
This means the processing of your data is in the interests of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. 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 at dataprotection@bytelondon.com.
Where we need to comply with a legal or regulatory obligation.
This means we process your personal data because it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Where we have your consent to do so.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending broadcasts to you via our chatbot. You have the right to withdraw consent to our broadcasts at any time by contacting us at dataprotection@bytelondon.com.

11. HOW DO WE OBTAIN YOUR CONSENT?

Where our use of your personal data requires your consent, you can provide such consent:

at the time we collect your personal data following the instructions provided;
or by contacting us at dataprotection@bytelondon.com.

12. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below a description of all the ways we plan to use your personal data, and which of the legal grounds (performance of a contract, legitimate interests, legal obligation or consent) we rely on to do so. We have also identified what our legitimate interests are where appropriate.

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 at dataprotection@bytelondon.com 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.

Purpose/Activity	Type of data	Legal ground for processing including basis of legitimate interest
To register you as a new user of our websites or chatbot	Identity Contact	Necessary for our legitimate interests (to provide you with use of the websites / chatbot)
To verify information you provide to us when you apply for a job with us and to assess your suitability for the role, including checking references, background checks and your right to work in the UK	Identity Contact	Performance of a potential contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to ensure we hire the right people)
To manage our relationship with you which may include: (a) paying you for services that you provide to us (b) notifying you about changes to our terms or privacy notice (c) asking you to leave a review or take a survey	Contact Profile Marketing and Communications	Performance of a contract with you (for example a contract for your services) Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how users use our services)
To enable you to take part in a prize draw, competition or complete a survey	Identity Contact Profile Usage Marketing and Communications	Performance of a contract with you Necessary for our legitimate interests (to study how users use our services, to develop them and grow our business)
To administer and protect our business and our websites and chatbot (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity Contact Technical	Performance of a contract with you (for example a contract for your services) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation
To deliver relevant websites and chatbot content to you and measure or understand the effectiveness of the content we serve to you	Identity Contact Profile Usage Marketing and Communications Technical	Necessary for our legitimate interests (to study how users use our services, to develop them, to grow our business and to inform our communications strategy)
To use data analytics to improve our websites, chatbot, services, marketing, user relationships and experiences	Technical Usage	Necessary for our legitimate interests (to define types of users for our services, to keep our websites updated and relevant, to develop our business and to inform our communications strategy)
To make suggestions and recommendations to you about services that may be of interest to you	Identity Contact Technical Usage Profile	Necessary for our legitimate interests (to develop our services and grow our business)
We use CCTV in our premises for security and crime prevention	Identity	Necessary for our legitimate interests (security and crime prevention)

13. MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing communications, which will usually take the form of broadcasts via our chatbot. We have established the following personal data control mechanisms:

Marketing communications from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which communications may be relevant for you.

You will receive marketing communications from us if you have requested information from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving those communications.

Third-party marketing

We will get your express opt in consent before we share your personal data with any company outside the Byte Club for marketing purposes.

Opting out

You can ask us to stop sending you marketing messages at any time by contacting us at any time at dataprotection@bytelondon.com.

14. COOKIES

Cookies are small pieces of data that websites store on a device. Cookies can improve your browsing experience because they help websites remember preferences and understand how people use different features. Our website is hosted by WordPress, which uses analytics cookies to track use of our websites. Details about how WordPress uses cookies can be found at https://wordpress.org/about/privacy/cookies/. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our websites may become inaccessible or not function properly.

15. CHANGE OF PURPOSE

We will only use your personal data 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 you would like an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at dataprotection@bytelondon.com.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal ground which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

16. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in the Purposes for which we will use your personal data section above.

Internal Third Parties

Other companies in the Byte Club acting as joint controllers or processors and who may be based in the EU or the USA.

External Third Parties

Service providers based in the EU, USA and Russia who provide IT, system administration services and other technology solutions.
Professional advisers including lawyers, bankers, auditors and insurers based in the EU and USA who provide consultancy, banking, legal, insurance, accounting and other professional support services.
HM Revenue & Customs, regulators and other authorities.
Specific third parties such as Facebook, Google, Squarespace and WordPress.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
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.

17. INTERNATIONAL TRANSFERS

We share your personal data within other offices in the Byte Club. This will involve transferring your data outside the European Economic Area (EEA), including to the USA.

Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
Where 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.

Please contact us at dataprotection@bytelondon.com if you want more information on the specific mechanism used by us when transferring your personal data out of the EEA.

18. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

19. DATA RETENTION

How long will you use my 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.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us at dataprotection@bytelondon.com.

20. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You may have the right to:

Request access to your personal data (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.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. 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. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of 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. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
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. 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.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you want to exercise any of the rights set out above, please contact us at dataprotection@bytelondon.com.

21. NO FEE USUALLY REQUIRED

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.

22. WHAT WE MAY NEED FROM YOU

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.

23. TIME LIMIT TO RESPOND

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.

24. BYTE CLUB

Byte Club is made up of the following companies:

Byte Club Limited, incorporated in England with registered number 10743162. Registered office address: 6th Floor Charlotte Building, 17 Gresse Street, London, United Kingdom, W1T 1QL.

Byte London Limited, incorporated in England with registered number 08782065. Registered office address: 6th Floor Charlotte Building, 17 Gresse Street, London, United Kingdom, W1T 1QL.

Byte London’s main office (and its postal address) is at 3rd Floor, The Emerson Building, 4-8 Emerson Street, London SE1 9DU.

Byte New York Inc, incorporated in Delaware, USA with its principal office at: 33 Irving Pl, New York, NY 10003, USA

This Privacy Notice was last updated on: 17 May 2018