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Privacy Policy

ABOUT US

The Bagelry is the trading name of: Mr Scott & Mrs Janine Muller who’s premises reside at Lubards Farm, Hullbridge Road, Rayleigh, Essex, SS6 9QG. We are committed to protecting your privacy. This Policy forms part of our legal information and confirms how we handle data that identifies you. If you have any queries concerning your personal information, please contact us at admin@thebagelry.co.uk

The use of the Internet pages of The Bagelry is possible without any collection of personal data by us; however, if you want to use some services via our website, processing of personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from you.

FOR MORE INFORMATION CONTACT

Scott Muller (Partner)
Telephone: 01702 587269
Email: scott@thebagelry.co.uk

DATA CONTROLLER

The data controller of our website and other data related business activities is: Scott Muller @ The Bagelry, Lubards Farm, Hullbridge Road, Rayleigh, Essex, SS6 9QG.

The Bagelry is both a data controller and a data processor on behalf of our clients. This policy applies whether we are acting as a data controller or processor with respect to the personal data of clients, employees and colleagues. Any data subject or individual on whom we hold information may, at any time, contact us directly with all questions and suggestions concerning data protection, we will deal with enquiries promptly (no more than 30 days)

OUR WEBSITES SERVER

Our website is hosted within a EU based data centre – Rack Space Hosting (Eukhosts).

DATA BREACHES

We will report any unlawful data breach of our website’s database or the database(s) of any of our third party data processors, or the loss of any other offline data, to any and all relevant persons and authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.

DATA PROTECTION INFORMATION

Any information you supply to The Bagelry will be treated in accordance with GDPR. You can obtain further information about data protection by visiting www.ico.org.uk.

User privacy and data protection are human rights and we have a duty of care to our clients and contractors within that Data. The Data will only be collected and processed when absolutely necessary and this Data will not be distributed or made public.

All private data (email address, IP address, names, telephone etc.) are stored on secure computers. No personal data will be given or sold without the express written permission of the user.

You may request to see copies of any personal information held and also request that that information is updated or removed in its entirety by contacting the data controller.

We are committed to safeguarding the privacy of our clients, employees and colleagues.

HOW WE USE YOUR PERSONAL DATA

We may process your name, address, telephone number, job title, email address and other identifying data including financial information.

This service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you.

Should we acquire them, we will also process and store still photographs and/or video and audio files on behalf or our clients.

The legal basis for this processing is either your consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

We may process website usage data. The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use.

The source of the usage data is Google analytics, this usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is consent OR our legitimate interests, namely monitoring and improving our website and services.

We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent OR our legitimate interests.

We may process information relating to our customer relationships, including customer contact information (“customer relationship data“). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer.

The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is consent OR our legitimate interests, namely the proper management of our customer relationships.

We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data“). The transaction data may include your contact details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions.

The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.

We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

We may process video and still images and audio recorded in course of our business. This data may be processed for the purpose of delivering completed work to our customers. The legal basis for this processing is consent OR our legitimate interests OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely [the protection and assertion of our legal rights, your legal rights and the legal rights of others.

In addition to the specific purposes for which we may process your personal data, we may also process where such processing is necessary for compliance with a legal obligation to which we are subject, or] in order to protect your vital interests or the vital interests of another natural person.

HOW YOUR DATA IS PROTECTED

We use a multi-layered approach to security –

“Perimeter Security” – our entire IT infrastructure is stored in a secure location. Only two key holders exist.

“Network Security” – All of the IT is further secured using strong password protection, using a mixture of alphanumeric and symbols. We use DropBox & Adobe Creative Cloud as a cloud storage system for documents and company files. Both are GDPR compliant.

Portable hard drives for use off-site and on location will not usually have personal information stored on them, and where they do they will have password-protected encryption at the drive level. We ensure all servers; routers, laptops, desktops, smartphones etc. are kept up to date with the relevant security patches and updates by the manufacturer.

“Privilege Based” – Only those who need to access your information will be able to access it. We use multiple alphanumeric passwords for access to all IT infrastructure. Where access is given to another person then an audit is carried out to ensure that only the required information is accessed and the passwords are changed.

LEGISLATION

Our business, internal systems and website are designed to comply with the following national and international legislation with regards to data protection and user privacy: UK Data Protection Act 1988 (DPA) EU Data Protection Directive 1995 (DPD) EU General Data Protection Regulation 2018 (GDPR)

Our site’s compliance with the above legislation means that it is compliant with the data protection and user privacy legislation set out by many other countries and territories. If you are unsure about whether this site is compliant with your own country of residences’ specific data protection and user privacy legislation you should contact our data protection officer

PERSONAL INFORMATION

The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to The Bagelry. By means of this data protection declaration, we would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, you are informed, by means of this data protection declaration, of the rights to which you are entitled.

CONTACT FORMS AND EMAILS

The website of the The Bagelry contains information that enables a quick electronic contact to our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.

COLLECTION OF GENERAL DATA AND INFORMATION

The website of The Bagelry collects a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files. Collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Internet site, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.

When using these general data and information, The Bagelry does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimise the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, The Bagelry analyses anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our company, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject

CONTACT POSSIBILITY VIA THE WEBSITE

The website of The Bagelry contains information that enables a quick electronic contact to our company as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.

RETAINING AND DELETING PERSONAL DATA

Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria

ROUTINE ERASURE AND BLOCKING OF PERSONAL DATA

Your personal information and any other data you give will be stored, securely, for a minimum of 24 months. If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.

PERIOD FOR WHICH THE PERSONAL DATA WILL BE STORED

The period for which the personal data will be stored is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfilment of the contract or the initiation of a contract.

The period of retention of video and audio material will be determined based on contractual obligation to clients and will be advised at the time of consent.

THIRD PARTY COMMUNICATION CHANNELS

The Bagelry use the personal information you provide to effectively undertake and provide services. Specific items of data may be shared with 3rd parties in order to facilitate these services.

We use third party communication channels. An example of these are: Social media messaging, email servers, Whilst this does expose our communications with you to third parties, each partner we have chosen to work with is reputable, and their service to us is understood to be as a carrier or enabler of communication, and not a processor of information.

The Bagelry has performed fair due diligence to assure that communication channels are fit for purpose, and reasonably secure. We do understand that communication channels are in their nature distributed worldwide and subject to technical change. We regularly review our usage of such channels to ensure the security of both subjects’ data and our business integrity.

THIRD PARTY DATA PROCESSORS

We use third parties to process personal data on our behalf.

Google – This site uses Google Analytics (GA) to track user interaction

Facebook – Image/File upload and sharing

Instagram – Image sharing

Third party crew– where applicable, names, telephone numbers and addresses may be shared with crew members for the purposes of completing their services on shoot days.

INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA

We sometimes use services based in other countries outside the EEA/EU to provide our overall service. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, will protect transfers to each of these countries. We will only use services in countries with a favourable “adequacy decision’, or where greater and equivalent protection to GDPR exists – for example the EU-US privacy shield.

SOCIAL MEDIA AND VIDEO SHARING

FACEBOOK/TWITTER/ INSTAGRAM/LINKEDIN/YOUTUBE/VIMEO

On our website, the controller has integrated components of the enterprises (FACEBOOK, TWITTER, INSTAGRAM, LINKEDIN, YOUTUBE, VIMEO) these are all social media and video sharing networks. The Bagelry shares and posts photos and videos to these social media platforms for business and promotional activities. No personal data that we have obtained is included in these posts without express permission of the data subject.

PHOTOGRAPHS/FILM AND BACKUPS

In the course of our business we record pictures and sound that could potentially be used to identify individuals and therefore could be considered to be data rather than digital assets. Sometimes we process this material in a way that includes its uploading to the internet for viewing by clients prior to delivery. Where this takes place this it is always by means of a secured link on a compliant platform.

We store backup video both off and online, in a variety of formats, within and outside the EU. This is a fundamental part of our business offering i.e. the very long-term secure backups of media. Raw rushes and the drives and back ups to which they relate are stored in locked premises and we seek specific consent for recording, processing and archiving of video and audio on a by project basis.

Where images of people do not have specific individual consent for example at a public event we assume a basis of legitimate interest. We always make sure attendees know filming will be taking place where possible or we consider whether attendees could have a reasonable expectation that filming will be taking place. If a member of the public requests exclusion from filming we always respect their wishes and provide the contact details of our data controller.

Both video and photographs, like many types of digital media, contain metadata. These data fields can include information like dates, time, location and personal data such as names, content details and job details. We do store, in an off-line password protected database which is only accessible to The Bagelry, references to the image names, and ID’s, and within that database references back to the customers, subjects and jobs for which those images were acquired in order that we can adequately control and process that data and ensure your rights.

The Bagelry do not use or condone the use of facial recognition software within photographs or film.

COPYRIGHT

Images The Bagelry create are subject to copyright, however some subjects/objects within the images can be subject to differing external copyrights. This means that the data and information regarding to a particular image can relate to more than one subject or party. We manage copyright and rights management within an offline database.

BACKUPS

As a responsible business, The Bagelry ensures all on-site files and data are routinely backed up off site. This backup may be within or outside of the EU. Where backups contain private data The Bagelry ensures backups are secure and encrypted. The logistics relating to these backups impose a practical implication when a subject requests data is removed, and as such, removals are subject to a reasonable workflow, and are not instant.

DATA STORAGE

The Bagelry stores data locally (in our offices) in electronic and paper formats. Additionally, along with a paper equivalent, we purposefully store data in multiple locations. We do this to ensure data security and integrity, and to provide an effective, long-term backup of image assets.

Backups are for the purposes of business resilience, regulatory compliance, rights management, and to provide customers a long-term service.

GDPR COMPLIANCE, AND OTHER REGULATORY ACTIVITIES

The Bagelry needs to keep proper records for accounting and taxation purposes (as an example). A subjects right to request data is removed does not alter the need of The Bagelry to maintain proper accounting and record keeping. If a subject does make a data removal request and such a tension exists, The Bagelry will inform the subject of any decisions and options.

SITE VISITATION TRACKING

Our website site uses Google Analytics (GA) to track user interaction. We use this data to determine and calculate the number of people using our site, this is so we can better understand how they find and use our web pages and to see their journey through our 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. We consider Google to be a third party data processor. GA makes use of cookies, details of which can be found on Google’s developer guides. Our website uses the analytics.js implementation of GA and you are able to disable cookies on your Internet browser which will stop GA from tracking any part of your visit to pages within this website.

DATA PROTECTION FOR APPLICATIONS AND THE APPLICATION PROCEDURES

The data controller shall collect and process the personal data of applicants for the purpose of the processing of the application procedure. The processing may also be carried out electronically. This is the case, in particular, if an applicant submits corresponding application documents by e-mail or by means of a web form on the website to the controller. If the data controller concludes an employment contract with an applicant, the submitted data will be stored for the purpose of processing the employment relationship in compliance with legal requirements. If no employment contract is concluded with the applicant by the controller, the application documents shall be automatically erased two months after notification of the refusal decision, provided that no other legitimate interests of the controller are opposed to the erasure. Other legitimate interest in this relation is, e.g. a burden of proof in a procedure under the General Equal Treatment Act (AGG).

LEGAL BASIS FOR THE PROCESSING

Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations that are necessary for carrying out pre-contractual measures, for example in the case of enquiries concerning our products or services. Is our company subject to a legal obligation by which processing of personal data is required, such as for the fulfilment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR.

In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1) lit. d GDPR.

Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because the European legislator has specifically mentioned them. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).

ROVISION OF PERSONAL DATA AS STATUTORY OR CONTRACTUAL REQUIREMENT; REQUIREMENT NECESSARY TO ENTER INTO A CONTRACT; OBLIGATION OF THE DATA SUBJECT TO PROVIDE THE PERSONAL DATA; POSSIBLE CONSEQUENCES OF FAILURE TO PROVIDE SUCH DATA

We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner).

Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded.

Before the data subject provides personal data, the data subject must contact our Data Protection Officer. Our Data Protection Officer clarifies to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.

DEFINITIONS

The data protection declaration of The Bagelry is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used.

In this data protection declaration, we use, inter alia, the following terms:

PERSONAL DATA

Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

DATA SUBJECT

Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.

PROCESSING

Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

RESTRICTION OF PROCESSING

Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.

PROFILING

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

CONTROLLER OR CONTROLLER RESPONSIBLE FOR THE PROCESSING

Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

PROCESSOR

Processor is a natural or legal person, public authority, agency or other body, which processes personal data on behalf of the controller.

RECIPIENT

Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

THIRD PARTY

Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data. CONSENT

Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

RIGHTS OF THE DATA SUBJECT

RIGHT OF CONFIRMATION

Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact the data controller.

Your principal rights under data protection law are:

1. The right to access; 2. The right to rectification; 3. The right to erasure; 4. The right to restrict processing; 5. The right to object to processing; 6. The right to data portability; 7. The right to complain to a supervisory authority; and 8. The right to withdraw consent.

RIGHT OF ACCESS

Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:

• The purposes of the processing; • The categories of personal data concerned; • The recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations; • Where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period; • The existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing; • The existence of the right to lodge a complaint with a supervisory authority; • Where the personal data are not collected from the data subject, any available information as to their source;

The existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.

Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer. If a data subject wishes to avail himself or herself of this right of access, he or she may at any time contact the data controller.

RIGHT TO RECTIFICATION

Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

If a data subject wishes to exercise this right to rectification, he or she may, at any time contact the data controller.

RIGHT TO ERASURE (RIGHT TO BE FORGOTTEN)

Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:

The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.

The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.

The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.

The personal data have been unlawfully processed.

The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.

The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.

If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by The Bagelry, he or she may at any time contact our data controller. The Bagelry shall promptly ensure that the erasure request is complied with immediately. Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required.

The Bagelry will arrange the necessary measures in individual cases.

RIGHT OF RESTRICTION OF PROCESSING

Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies: • The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data. • The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead. • The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims. • The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by The Bagelry, he or she may at any time contact us. The Bagelry will arrange the restriction of the processing.

RIGHT TO DATA PORTABILITY

Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

In order to assert the right to data portability, the data subject may at any time contact the data controller.

RIGHT TO OBJECT

Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.

The Bagelry shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.

If The Bagelry processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to The Bagelry to the processing for direct marketing purposes, The Bagelry will no longer process the personal data for these purposes.

In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by The Bagelry for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

In order to exercise the right to object, the data subject may directly contact the Data Protection Officer of The Bagelry or another employee. In addition, the data subject is free in the context of the use of information society services, and notwithstanding

Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.

AUTOMATED INDIVIDUAL DECISION-MAKING, INCLUDING PROFILING

Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit consent.

If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject’s explicit consent, The Bagelry shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.

If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may at any time directly contact the data controller.

RIGHT TO WITHDRAW DATA PROTECTION CONSENT

Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.

If the data subject wishes to exercise the right to withdraw the consent, he or she may at any time directly contact the data controller.

COOKIES

Our website uses cookies to better the users experience while visiting the website. Where applicable this website uses a cookie control system allowing the user on their first visit to the website to allow or disallow the use of cookies on their computer/device. This complies with recent legislation requirements for websites to obtain explicit consent

from users before leaving behind or reading files such as cookies on a user’s computer/device.

Cookies are small files saved to the user’s computer’s hard drive that track, save and store information about the user’s interactions and usage of the website. This allows the website, through its server to provide the users with a tailored experience within this website.
 Users are advised that if they wish to deny the use and saving of cookies from this website on to their computers hard drive they should take necessary steps within their web browsers security settings to block all cookies from this website and it’s external serving vendors.

This website uses tracking software to monitor its visitors to better understand how they use it.

This software is provided by Google Analytics which uses cookies to track visitor usage. The software will save a cookie to your computer’s hard drive in order to track and monitor your engagement and usage of the website, but will not store, save or collect personal information. You can read Google’s privacy policy here for further information http://www.google.com/privacy.html .

CHANGES TO OUR PRIVACY POLICY

This privacy policy may change from time to time in line with legislation or industry developments. We will not explicitly inform our clients or website users of these changes. Instead, we recommend that you check this page occasionally for any policy changes.

RIGHT OF ACCESS

Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:

• The purposes of the processing; • The categories of personal data concerned; • The recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations; • Where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period; • The existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing; • The existence of the right to lodge a complaint with a supervisory authority; • Where the personal data are not collected from the data subject, any available information as to their source;

The existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.

Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer. If a data subject wishes to avail himself or herself of this right of access, he or she may at any time contact the data controller.

RIGHT TO RECTIFICATION

Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

If a data subject wishes to exercise this right to rectification, he or she may, at any time contact the data controller.

RIGHT TO ERASURE (RIGHT TO BE FORGOTTEN)

Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:

The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.

The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.

The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.

The personal data have been unlawfully processed.

The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.

The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.

If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by The Bagelry, he or she may at any time contact our data controller. The Bagelry shall promptly ensure that the erasure request is complied with immediately. Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required.

The Bagelry will arrange the necessary measures in individual cases.

RIGHT OF RESTRICTION OF PROCESSING

Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:

• The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data. • The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead. • The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims. • The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by The Bagelry, he or she may at any time contact us. The Bagelry will arrange the restriction of the processing.

RIGHT TO DATA PORTABILITY

Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

In order to assert the right to data portability, the data subject may at any time contact the data controller.

RIGHT TO OBJECT

Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.

The Bagelry shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.

If The Bagelry processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to The Bagelry to the processing for direct marketing purposes, The Bagelry will no longer process the personal data for these purposes.

In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by The Bagelry for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

In order to exercise the right to object, the data subject may directly contact the Data Protection Officer of The Bagelry or another employee. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.

AUTOMATED INDIVIDUAL DECISION-MAKING, INCLUDING PROFILING

Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit consent.

If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject’s explicit consent, The Bagelry shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.

If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may at any time directly contact the data controller.

RIGHT TO WITHDRAW DATA PROTECTION CONSENT

Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.

If the data subject wishes to exercise the right to withdraw the consent, he or she may at any time directly contact the data controller.

COOKIES

Our website uses cookies to better the users experience while visiting the website. Where applicable this website uses a cookie control system allowing the user on their first visit to the website to allow or disallow the use of cookies on their computer/device. This complies with recent legislation requirements for websites to obtain explicit consent from users before leaving behind or reading files such as cookies on a user’s computer/device.

Cookies are small files saved to the user’s computer’s hard drive that track, save and store information about the user’s interactions and usage of the website. This allows the website, through its server to provide the users with a tailored experience within this website.
Users are advised that if they wish to deny the use and saving of cookies from this website on to their computers hard drive they should take necessary steps within their web browsers security settings to block all cookies from this website and its external serving vendors.

This website uses tracking software to monitor its visitors to better understand how they use it.

This software is provided by Google Analytics which uses cookies to track visitor usage. The software will save a cookie to your computer’s hard drive in order to track and monitor your engagement and usage of the website, but will not store, save or collect personal information. You can read Google’s privacy policy here for further information http://www.google.com/privacy.html .

CHANGES TO OUR PRIVACY POLICY

This privacy policy may change from time to time in line with legislation or industry developments. We will not explicitly inform our clients or website users of these changes. Instead, we recommend that you check this page occasionally for any policy changes.

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