This Privacy Notice (“Privacy Notice”) applies to the processing of personal data in connection with the provision of the Bowey website at bowey.io (the “Site”), and all of the goods and services that we offer, including from the Site and our other service operations (“Services”). We respect the privacy of every person who visits our Site and/or uses our Services and we are committed to ensuring a safe online experience for all.1. Purpose of this privacy noticeThis Privacy Notice explains our approach to any personal data that we might collect from you or which we have obtained about you from a third party and the purposes for which we process your personal data. This Privacy Notice also sets out your rights in respect of our processing of your personal data. When we talk about “personal data”, we mean any information which relates to an identified or identifiable living individual. Individuals might be identified by reference to a name, an identification number, location data, an online identifier (such as an IP address) or to other factors that are specific to them, such as their physical appearance. This Privacy Notice informs you of the nature of the personal data about you that is processed by us and how you can request that we delete it, update it, transfer it and/or provide you with access to it. This Privacy Notice is intended to assist you in making informed decisions when using the Site and our Services. Please take a moment to read and understand it. This Privacy Notice only applies to the use of your personal data obtained by us, whether from you directly or from a third party. It does not apply to personal data collected by third parties during your communications with those third parties or your use of their products or services (for example, where you follow links to third party websites over which we have no control, or you purchase goods or services from those third parties). 2. About usThe Site and our Services are made available by Bowey Media LLC (“Bowey”, “we”, “us”, “our”). Bowey is the data controller responsible for your personal data.3. How to contact usIf you have any questions about this Privacy Notice or want to exercise your rights set out in this Privacy Notice, you can contact us by visiting the form on our dedicated contact page.4. How we collect and receive personal dataWe collect and receive personal data using different methods:Personal data you provide to us: You may give us your personal data directly. This will be the case when, for example, you contact us with enquiries, complete forms on our Site, subscribe to receive our marketing communications, or provide feedback to us. Personal data we collect using cookies and other similar technologies: When you access and use our Site, we will collect certain technical information about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Personal data received from third parties: From time to time, we will receive personal data about you from third parties. Such third parties may include analytics providers, payment providers, and third parties that provide technical services to us so that we can operate our Site and provide our Services.Publicly available personal data: From time to time we may collect personal data about you (including your contact details, biography, interests or affiliations) from publicly available sources (including open source data sets), media reports or that you or a third party may otherwise make publicly available (for example through publishing articles, news stories, or posts on social media platforms). 5. Who we collect personal data aboutWe collect and process personal data from the following people:Site visitors: If you browse our Site, register for updates on our Site, contact us with an enquiry through our Site, submit a complaint through our Site or use any Services available on our Site, we will collect and process your personal data in connection with your interaction with us and our Site.Customers: If you buy products or services from us, we may collect and process your personal data in connection with the supply of goods or services to you.Personnel who work for our partners and suppliers (including subcontractors): If you (or your organization) supply products or services to us or otherwise partner with us, we may collect and process your personal data in connection with our receipt of those products and services and/or partnership. This may include personal data included in any email or telephone communications or recorded on any document relating to an order for the products or services.Job applicants: If you apply for a job with us, whether through the Site or otherwise, we will collect and process your personal data in connection with your application.6. Personal data we collectWe use your personal data for the following purposes:Fulfilment of our ServicesWe collect and maintain personal data that you submit to us for the purpose of supplying Services that you have requested from us via our Site or where we contract with you to provide our Services. We may collect and process your personal data whether you are interacting with us on your own behalf or on behalf of any organization you represent. The personal data we process may include your name and contact information (such as email address and telephone number) and your payment information (where applicable). We process this information so that we can fulfil the supply of Services, maintain our user databases and to keep a record of how our Services are being used.Our legal basis for processing: It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you, or it is in our legitimate interest or a third party’s legitimate interest to use personal data in such a way to ensure that we provide our Services in an effective, safe and efficient way.Linking to social media sites and interacting with our social media pagesIf you click on one of the social media links on our Site or otherwise interact with our social media pages (including interacting with any ‘like’ or similar embedded features on our Site or social media accounts) we and the relevant social media platform may receive information relating to such interaction and may share your personal data in connection with this purpose. Please note that we are a joint controller with the relevant social media platform in respect of the personal data we use which is collected via your use of our social media pages. Your personal data may be used by the relevant social media platform for additional purposes. For details of how the relevant social media platform uses your personal data, please see the privacy policy of the relevant social media platform. Our legal basis for processing: It is in our legitimate interest or a third party’s legitimate interest to use personal data in such a way to ensure that we provide the Site and our Services in an effective way and to promote our Site and our Services via social media. Customer service and general enquiriesOur Site invites you to submit general inquiries about our Site and our Services. When you make an inquiry, we will collect and process your name, contact information (including email address and/or telephone number) and any other personal data that is relevant to your inquiry. We use this information to manage and respond to your inquiry.Our legal basis for processing: It is in our legitimate interest to use your personal data in the ways described above to ensure that we are able to help you with your inquiry and provide a good standard of service to you.Email and digital marketing activitiesWe use your name and email address to send you (or the organization you represent) marketing communications by email. We may use your mobile telephone number to send you marketing communications by SMS/MMS. Our marketing communications will include information, thought pieces, articles, as well as general information about our organization, our Site, the Services we provide and the promotions we offer.We may share your personal information with a variety of third party email or text message marketing providers (including MailerLite) who assist us in delivering our email marketing campaigns, newsletters, and other mass emails or text messages to you.Where your personal data is not in an anonymous form (for example, your email address), it is in our legitimate interest to use your personal data for marketing purposes. We will only send you marketing communications where you have consented to receive such communications, or where we have another lawful right to send such communications to you.RecruitmentWe also use your personal data to communicate with you about the recruitment process, to keep records about our recruitment process and to comply with our legal obligations in relation to recruitment. We will process any personal data about you that you volunteer, including during any interview, when you apply for a position with us. We may also process your personal data obtained from any third parties we work with in relation to our recruitment activities, including without limitation, recruitment agencies, background check providers, credit reference agencies and your referees. The personal data we process may include your name and contact information (including your email address and telephone number), details of your education, qualifications and employment history, any other personal data which appears in your resume or application, or any personal data that you volunteer during an interview or your interactions with us. All employment-related decisions are made entirely on merit.Our legal basis for processing: Where we use your personal data in connection with recruitment, it will be in connection with us taking steps at your request to enter into a contract we may have with you or it is in our legitimate interest to use personal data in such a way to ensure that we can make the best recruitment decisions.Receipt of services from suppliersIf we have engaged you or the organization you represent to provide us with products or services (for example, if you provide us with services such as IT support, production, artwork or financial advice), we will collect and process your personal data in order to manage our relationship with you, to receive products and services from you and, where relevant, to provide our Services to others.The personal data we collect from you may include your name, job title, contact information (including email address and telephone number), bank account or other payment details and any other personal data you volunteer which is relevant to our relationship with you.Our legal basis for processing: It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you or it is in our legitimate interest to use personal data in such a way to ensure that we have an effective working relationship with you and are able to receive the services that you provide, and provide our Services to others, in an effective way.Business administration and legal complianceWe use your personal data for the following business administration and legal compliance purposes: To comply with our legal obligations; To enforce our legal rights; To protect the rights of third parties; and In connection with a business transition such as a merger, reorganization, acquisition by another company, or sale of all or a portion of our assets. Our legal basis for processing: Where we use your personal data in connection with a business transition, to enforce our legal rights or to protect the rights of third parties, it is in our legitimate interest to do so. For all other purposes described in this section, we have a legal obligation to use your personal data to comply with any legal obligations imposed upon us such as a court order.7. If you fail to provide your personal dataWhere we are required by law to collect your personal data, or we need to collect your personal data under the terms of a contract we have with you, and you fail to provide that personal data when we request it, we may not be able to perform the contract we have or are trying to enter into with you. This may apply where you do not provide the personal data we need in order to provide the Services you have requested from us or to process an application for employment with us. In this case, we may have to cancel your application or the provision of the relevant Services to you, in which case we will notify you. 8. How we obtain your consentWhere our use of your personal data requires consent, you can provide or withdraw such consent:At the time we collect your personal data following the instructions provided; orBy informing us using the contact details set out on our contact page.9. Our use of cookies and similar technologiesOur Site may use certain cookies, web beacons, pixel tags, log files and other technologies to track user analytics and optimize site functionality.10. Third party links and servicesThis Privacy Notice does not apply to your interaction with services provided by third parties. Our Site may contain links to third party websites and services.When you use a link to go from our Site to another website (even if you don’t leave our Site) or you request a service from a third party, this Privacy Notice shall not apply to the processing of your personal data carried out by the relevant third party provider. Your browsing and interactions on any other websites, or your dealings with any other third party service provider, is subject to that website’s or third party service provider’s own rules and policies. We do not monitor, control or endorse the privacy practices of any third parties. This Privacy Notice applies solely to personal data processed by us through your use of our Site, your receipt of our Services and/or in connection with our business operations. 11. Sharing personal dataWe will only share personal data with others when we are legally permitted to do so. When we share personal data with others, we put contractual arrangements and security mechanisms in place to protect the personal data shared and to comply with our data protection, confidentiality and security standards and obligations. When processing your personal data, we may need to share it with third parties as follows: Third-party organizations that provide applications/functionality, data processing or IT services: We share personal data with third parties who support us in providing our Services and help provide, run and manage our internal IT systems. Such third parties may include, for example, providers of information technology, cloud-based software as a service providers, identity management, website hosting and management, data analysis, data back-up, security and storage services. We also share your personal data with third-party service providers to assist us with insight analytics.Payment providers and banks: We share personal data with third parties who assist us with the processing of payments and refunds.Third-party email marketing and CRM specialists: We share personal data with specialist suppliers who assist us in managing our marketing database and sending out our email marketing communications.Auditors, lawyers, accountants and other professional advisers: We share personal data with professional services firms who advise and assist us in relation to the lawful and effective management of our organization and in relation to any disputes we may become involved in. Law enforcement or other government and regulatory agencies and bodies: We share personal data with law enforcement or other government and regulatory agencies or other third parties as required by, and in accordance with, applicable law or regulation. Sharing with other third parties: Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, or to establish, exercise or defend legal rights. We will only fulfill requests for personal data where we are permitted to do so in accordance with applicable law or regulation. 12. How long we keep your personal dataIn respect of personal data that we process in connection with the supply of our Services, we may retain your personal data for up to six years from the date of supply of the relevant Services and in compliance with our data protection obligations. We may then destroy such files without further notice or liability. In respect of any other personal data that we process, we will retain relevant personal data for up to three years from the date of our last interaction with you and in compliance with our data protection obligations. We may then destroy such files without further notice or liability. If any personal data is only useful for a short period (e.g. for a specific marketing campaign or in relation to recruitment), we will not retain it for longer than the period for which it is used by us. If you have opted out of receiving marketing communications from us, we will need to retain certain personal data on a suppression list indefinitely so that we know not to send you further marketing communications in the future. 13. Confidentiality and security of your personal dataWe are committed to keeping the personal data you provide to us secure and we will take reasonable precautions to protect your personal data from loss, misuse or alteration. We have implemented information security policies, rules and technical measures to protect the personal data that we have under our control from: Unauthorized access;Improper use or disclosure;Unauthorized modification; andUnlawful destruction or accidental loss.All our data processors who have access to and are associated with the processing of personal data are obliged to respect the confidentiality of the personal data of all users of our Site and our Services.14. Personal data of childrenWe do not specifically target our Site or our Services at children. However, due to the nature of our organization and the Services we provide, we may from time to time collect and process personal data relating to individuals under the age of 18. Where we do so, we will comply with all applicable laws and regulations relating to the processing of personal data of minors. 15. How to access your information and your other rightsYou have the following rights in relation to the personal data we hold about you. If you would like to exercise any of these rights, please contact us using the details set out on our contact page.Your right of access: If you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a copy of that personal data.Your right to rectification: If the personal data we hold about you is inaccurate or incomplete, you are entitled to have it rectified.Your right to erasure: You can ask us to delete or remove your personal data in some circumstances, such as where we no longer need it or where you withdraw your consent (where applicable).Your right to restrict processing: You can ask us to ‘block’ or suppress the processing of your personal data in certain circumstances such as where you contest the accuracy of that personal data or you object to us processing it for a particular purpose.Your right to data portability: You have the right, in certain circumstances, to obtain personal data you have provided to us (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer it to a third party of your choice. Your right to object: You can ask us to stop processing your personal data, and we will do so, if we are relying on our own or someone else’s legitimate interest to process your personal data, except if we can demonstrate compelling legal grounds for the processing; or if we are processing your personal data for the purposes of direct marketing. Your rights in relation to automated decision-making and profiling: You have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for the entering into, or the performance of, a contract between you and us. Your right to withdraw consent: If we rely on your consent as our legal basis for processing your personal data, you have the right to withdraw that consent at any time. You can exercise your right of withdrawal by contacting us through our contact page or by using any other opt-out mechanism we may provide, such as an unsubscribe link in an email.16. Changes to this privacy noticeTo ensure that you are always aware of how we use your personal data, we will update this Privacy Notice from time to time to reflect any changes or proposed changes to our use of your personal data. We may also make changes to comply with changes in applicable law or regulatory requirements. We encourage you to review this Privacy Notice periodically to be informed of how we use your personal data.