Introduction

Welcome to the The Bruno Effect' privacy statement.

This statement explains how we collect and look after your personal data when you visit our website and tells you about your privacy rights and how the law protects you.

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR).

This privacy statement contains a glossary at section 10 below that explains any technical or legal terminology used in this privacy statement.

1. Important information: who we are and about this statement

Purpose of this privacy statement

The purpose of this privacy statement is to explain how The Bruno Effect collects and processes your personal data through your use of our website, regardless of where you visit it from. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.

The Bruno Effect website is not intended for children and we do not knowingly collect data relating to children. If you are aware that any personal data of anyone under 18 years old has been shared with our website please let us know so that we can delete that data.

It is important that you read this statement as well as any other privacy, transparency or fair processing notice we may bring to your attention on specific occasions when we are collecting or processing personal data about you. This privacy statement supplements our website terms of use. It is not intended to override them.

Data Controller

When you provide us with personal data through the website The Bruno Effect is the data controller. The Bruno Effect is the trading name of The Bruno Effect Limited and is referred to by use of the terms "we", "us" and "our" in this statement.  It is a limited liability company incorporated and registered in England and Wales with company number 12451543 and has its registered office at 35 Ballards Lane London N3 1XW.  As data controller, The Bruno Effect is legally responsible for deciding how and for what purpose the personal data you provide through the website is used.

We have appointed a data privacy manager who is responsible for managing your personal data and any questions in relation to this privacy statement. If you have any questions at all, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

Name of data privacy manager: Delia Bruno

Email address: delia@thebrunoeffect.com

Postal address: 35 Ballards Lane London N3 1XW

If you believe we have misused your personal data or failed to respect your rights, you may 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 we encourage you to contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

We always publish the latest version of our privacy statement here on our website. This version was updated and published on 10th November 2021. Previous versions can be obtained by contacting our data privacy manager.

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.

Third-party links

This privacy statement applies to this website only. Throughout this website we may link to other websites owned and operated by certain third parties to make additional products and services available to you.

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties also to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies or statements. When you link to them, we encourage you to read their privacy statements as well.

2. The data we collect about you

Personal data or information means any information about a living individual from which that person can be identified. It does not include data about you from which your identity has been removed (anonymised data).

If you do not provide the personal data we ask for where it is requested, it may delay or prevent us from providing services to you.

We may collect and process the following personal data about you:

• Information that you provide to us directly through our website www.thebrunoeffect.com. This includes information you provide when you register to use our website, subscribe to any of our services, post material on our website or request further services. We may also ask you for information if you enter a competition or promotion sponsored by us or if you report a problem with our site.
• If you contact us by email, telephone or post, we may keep a record of those communications, including recordings of telephone calls.
• We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
• Details of queries and searches you carry out through our site.
• Details of your visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data and the resources that you access.

This personal data falls into the following categories:

• Identity Data including name, username or similar identifier, marital status or title, date of birth and gender.
• Contact Data including address, email address and telephone numbers.
• Technical Data including 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 this website.
• Profile Data including your username and password, your interests, preferences, feedback and survey responses. 
• Usage Data including information about how you use our website, products and services.
• Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.

We may 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 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 part of the website or a 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 will not collect any Special Categories of Personal Data about you (for example, 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.

3. How we collect your personal data and use of cookies

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 by post, phone, email or otherwise. This includes personal data you provide when you:
• subscribe to our services and to our newsletters or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• contact us directly or give us feedback.
• 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 as set out below.
  
  IP addresses and cookies. 
  We may send small files to your computer when you visit our sites. These files (cookies) store your session identifier. This enables us to identify your computer and to allow our systems to tailor their response to your requests. We only use cookies to save your website preferences, keep you logged into the website or to customise the way you view the website to meet your choices.
  
  Except through the use of cookies, we do not automatically log or collect data unless you specifically provide it to us. You can set your computer browser to reject cookies but this may preclude your use of certain parts of this website.
  
  You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. To find out more about cookies, including how to control and delete them, visit www.allaboutcookies.org. If you decide to disable or refuse cookies, please note that some parts of our sites may become inaccessible or not function properly. Please also see below for Google Analytics cookies and how to disable them.
  
  Please note that our advertisers may also use cookies, over which we have no control.
  
  Google Analytics
  
  We use Google Analytics to help analyse use of our website. This analytical tool uses cookies to collect standard internet log information and visitor behaviour information in an anonymous form. The information generated by the cookie about your use of the website (including your IP address) is transmitted to Google. This information is then used to evaluate your use of the website and to compile statistical reports on website activity for the website generally.
  To opt out of being tracked by Google Analytics visit http://tools.google.com/dlpage/gaoptout.
  
  We will not (and will not allow any third party) to use the statistical analytics tool to track or to collect any personally identifiable information of visitors to our site. We will not associate any data gathered from this site with any personally identifying information from any source as part of our use of the Google Analytics tool. Google will not associate your IP address with any other data held by Google. Neither we nor Google will link, or seek to link, an IP address with the identity of a computer user.

4. How we use your personal data

We will only use your personal data as permitted by law. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform a contract we are about to enter into or have entered into with you, e.g., to provide certain services.
• 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.
• Where we need to comply with a legal or regulatory obligation.
• Marketing to which you have consented

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us at delia@thebrunoeffect.com.

Purposes for which we will use your personal data

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.

Note that we may process your personal data for more than one lawful purpose depending on the specific purpose for which we are using your data. Please contact us at delia@thebrunoeffect.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.

Marketing and advertising

You may choose how and whether we contact you in connection with marketing and advertising.

You always have the right to ask us not to process your personal data for marketing purposes either by checking certain boxes on the forms we use to collect your data or by contacting us at 35 Ballards Lane, London, N3 1XW or delia@thebrunoeffect.com.

You can ask third parties to stop sending you marketing messages at any time either by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you by them.

Promotional offers 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 what may be of interest to 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 that marketing. You may unsubscribe from these at any time by following the appropriate link.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any other company for marketing purposes.

We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience.

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 35 Ballards Lane, London, N3 1XW or delia@thebrunoeffect.com

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis 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.

5. 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 paragraph 4 above.

• External Third Parties as set out in the Glossary below.
• 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.

6. International transfers

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. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers, 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. 
• 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. For further details, see European Commission: EU-US Privacy Shield.

Please contact us at 35 Ballards Lane, London, N3 1XW or delia@thebrunoeffect.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. 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.

8. 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.

Different retention periods apply for different types of personal data. 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.

9. Your legal rights

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 below, please contact us at 35 Ballards Lane, London, N3 1XW or delia@thebrunoeffect.com.

You 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.

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.

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.

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.

10. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product 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 35 Ballards Lane, London, N3 1XW or delia@thebrunoeffect.com.

Performance of Contract means processing your data where 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.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

External Third Parties

• Service providers acting as processors based in the United Kingdom, United States and Europe, who provide IT and system administration services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom and United States who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.