PRIVACY POLICY

Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

“Services”	means our website and browser extension;
“Account”	means an account required to access and/or use certain areas and features of our services;
“Cookie”	means a small text file placed on your computer or device when you visit certain parts of our site and/or when you use certain features of our services. Details of the Cookies used by are set out in Part 14 and our cookie policy, below; and
“Cookie Law”	means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

Information About Us

The Beagle Button browser extension and website are owned and operated by Beagle

Button Ltd, a limited company registered in England under company number 11926789.

Registered address: Sustainable Bankside Ii, Sustainable Bankside Ii, London, SE1 0NZ

Representative: David Henry

Email address: [email protected]

Telephone number: 07751728708

Postal address: Sustainable Bankside Ii, Sustainable Bankside Ii, London, SE1 0NZ

What Does This Policy Cover?

This Privacy Policy applies to your use of our Site and browser extension. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

What Is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

• The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.
• The right to access the personal data we hold about you. Part 13 will tell you how to do this.
• The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
• The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 15 to find out more.
• The right to restrict (i.e. prevent) the processing of your personal data.
• The right to object to us using your personal data for a particular purpose or purposes.
• The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
• The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
• Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 15.

What Data Do You Collect and How Is It Used?

The data that we handle can be split into two groups; anonymised and personal.

Anonymous:

The table below shows the anonymised data that we capture and how we use it. All of this data is anonymised, meaning that we can’t attribute any of this to a specific user.

Anonymous Data Collected	How We Use That Data
Browsing data (including URLs visited, page titles, headings and breadcrumbs)	To provide relevant recommendations when viewing a page and to improve the matching functionality
Usage information within the extension	To understand which features are being used and how they are used
Errors which occur within the extension	To fix bugs
Server logs	To mitigate unauthorized access to the service and to fix bugs
Browser vendor, device type, operating system, screen resolution	To make sure the extension and website work well for all our users

Personal:

Depending upon your use of our services, we may collect and hold some or all of the personal data set out in the table below, using the methods also set out in the table. Under the Data Protection Legislation,we must always have a lawful basis for using personal data, this is also listed.

Personal Data Collected	How We Use That Data	Our Lawful Basis
Email address	Registering you with an account on our browser extension and allowing sign-in to that account	Essential for secure account access. Consent is given by user input of email.
Email address	Providing you with updates to our privacy policy or terms & conditions	Essential for secure account access. Consent is given by user input of email.
Email address	Sending you marketing communications (you may opt-out at any time by contacting us at [email protected])	Consent is given by the user when creating an account. Opt-out is available
Email address	Providing and managing your Account.	Consent is given by the user when creating an account.
Sustainability Preferences	Personalising and tailoring our recommendations through the browser extension.	Consent is given by user when creating an account and selecting preferences

Please also see Part 14 for more information about our use of Cookies and similar technologies and our Cookie Policy (joinbeagle.com/cookie-policy). We do not collect any ‘special category’ or ‘sensitive’ personal data or personal data relating to children or data relating to criminal convictions and/or offences.

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email with information, news, and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will not share your personal data with third parties for marketing purposes.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected,we will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights

How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

Type of Data	How Long We Keep It
Email address	For as long as the user account is active, defined as no longer than 1 year after the browser extension has been uninstalled, or upon your request by contacting us at [email protected]
Profile information: preferences	For as long as the user account is active, defined as no longer than 1 year after the browser extension has been uninstalled, or upon your request by contacting us at [email protected]

How and Where Do You Store or Transfer My Personal Data?

We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:

We may share your data within the group of companies of which we are a part. Where this involves the transfer of personal data outside the EEA, our group ensures that personal data is protected by requiring all companies within the group to follow the same rules with respect to personal data usage. These are known as “binding corporate rules”. More information on binding corporate rules is available from the European Commission.

Where we transfer your data to a third party based in the US, the data may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar to those in Europe. More information is available from the European Commission.

Please contact us using the details below in Part 15 for further information about the particular data protection mechanisms used by us when transferring your personal data to a third country.

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

• limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
• procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so;
• encrypting all data at rest using AES-256 encryption
• encrypting all data during transfer using HTTPS (TLS with RSA encryption)

Do You Share My Personal Data?

We use Google Analytics for aggregated, anonymized website traffic and extension use analysis. In order to track your session usage, Google drops a cookie (_ga) with a randomly-generated ClientID in your browser. This ID is anonymized and contains no identifiable information like email, phone number, name, etc. We also send Google your IP Address. We use GA to track aggregated behavior, such as what pages of our website you looked at, for how long, as well as which of our recommendations you clicked through on. This information is important to us for improving the user experience, determining site effectiveness and making sure our recommendations are right for you. If you would like to access what browsing information we have - or ask us to delete any GA data - please delete your _ga cookies and/or reach out to us via [email protected].

Beyond that, we will not share any of your personal data with any third parties, subject to the following exceptions.

If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.

In some limited circumstances,we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority

How Can I Control My Personal Data?

In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via our Site, you may be given options to restrict our use of your personal data. In particular,we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails or at the point of providing your details or by contacting us at [email protected].

You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

Can I Withhold Information?

You may access our Site and install and use our browser extension without providing any personal data at all. However, to use all features and functions available on our site and our browser extension you may be required to submit or allow for the collection of certain data.

You may restrict our use of Cookies. For more information, see Part 14 and our Cookie Policy (joinbeagle.com/cookie-policy).

How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within 28 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

How Do You Use Cookies?

Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us.we use Cookies to facilitate and improve your experience of Our Site and to provide and improve our services. In addition, Our Site uses analytics services provided by Google Analytics, which also use Cookies. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling us to better understand how people use Our Site. For more details, please refer to our Cookie Policy (joinbeagle.com/cookie-policy).

How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:

Email address: [email protected].

Telephone number: 07751728708

Postal Address: Beagle, Sustainable Workspaces, 25 Lavington Street, SE1 0NZ.

Changes to this Privacy Policy

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be immediately posted on our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of our services following the alterations. We recommend that you check this page regularly to keep up-to-date. This Privacy Policy was last updated on 5.05.2020.