Privacy and cookie policy

(last amended 07 March 2020)
We are committed to protecting the privacy and security of personal data. This policy tells you how we will collect and use your personal data, and what you should expect in respect of the personal information about you that we have collected. We do not sell or trade your personal data to third parties. We may, with your consent, share your personal data within our group of companies.

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

In this Privacy Policy the word “you” or “your” relates to both you and any child in respect of whom you have submitted personal data to us.

We are BXM Expeditions Limited (Registered in England & Wales with Company No: 09584842). Our Registered Office address is Green Banks, 24 The Hill, Merrywalks, Stroud, Gloucestershire, United Kingdom, GL5 4EP.

The person with responsibility for our data protection compliance is Ben Maxfield (“the Data Protection Manager”), and he can be contacted via email at info@bxmexpeditions.co.uk or by telephone on 0800 433 2963.

Where we are the controller of the personal data that we keep and use, we are responsible for making sure that our systems, processes and people comply with the relevant data protection legislation in respect of that personal data. In certain cases, we may act as a processor of personal data on behalf of others; in those circumstances, we will tell you who the controller is.

We will comply with applicable data protection legislation (including, before the UK leaves the EU, the General Data Protection Regulation (“GDPR”)). We will act in respect of personal data to comply with the six principles of data protection legislation, which are:
• Lawfulness, fairness and transparency;
• Purpose limitation;
• Data minimisation;
• Accuracy;
• Storage limitation;
• Integrity and confidentiality.

Unit 5 Axis Business Centre
Westmead Industrial Estate
Swindon
SN5 7YS
info@bxmoutdoors.com
Tel: 0800 433 2963

You have rights in respect of how your personal data can be processed; these include the right to request:
• a copy of your personal data;
• that inaccurate data is rectified; and
• that your personal data is, in certain circumstances, erased or restricted.

You have the right to complain to the Information Commissioner, which you can do by contacting the Information Commissioner’s Office (ICO) directly. Full contact details, including a helpline number, can be found on the ICO website (www.ico.org.uk). This website also has useful information on your rights and our obligations. However, please raise any concerns or issues with us first so that we may deal with this as quickly as possible for you.

Whilst we provide services to children, schools, parents and guardians, personal data for children (for example a child that wishes to take part in one of our expeditions) should only be uploaded or submitted by a child’s parents or legal guardian.

COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
We collect and process data for the following reasons:
1. personal data collected and created in relation to our provision or the potential provision of our services, expeditions and products to you which would include customers and relevant contacts; and
2. personal data relating to people who have asked to attend events and expeditions run by us, receive our newsletters and other information services or marketing materials; and
3. personal data relating to our people (which means those people working for our firm, or providing services to us, or potentially working or providing services to us, including employees, consultants, temporary or casual workers and contractors).
All of our people are required to abide by our Privacy Policy when handling personal data and are provided with appropriate data protection training. Any breach of data protection will be taken seriously and may result in disciplinary action. Our Data Protection Manager will provide the advice and guidance to our people on data protection issues, as is required.
1. Providing our services

COLLECTION:
We will collect personal information which may include names, addresses, contact details including email addresses, dates of birth, health information (including allergies) business information and required identification information and documentation for our customers and customer contacts. This will be done for the management of the commercial relationship with our customers and to allow you access to protected and secure areas of our website. Additionally, we may collect and use additional personal data when a person is identified during the course of our service provision.
We may collect this personal data from you directly, and also from third parties, including publicly available third-party sources. Additional personal data will be collected as it is created by or supplied to us in our performance of our services.
We will also collect personal information, including name and contact information, for individuals with whom we have a professional business relationship related to our provision of our services and products.
Where we collect any health or other special category data, the parent or legal guardian of the child must first submit a signed copy of our medical consent form before we process that data

USE:
We will use the personal data in the provision of our services and products, including for the necessary administration of the relationship with our customer, and to comply with requirements that we are required or recommended to undertake by law.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• in performance of a contract (the agreement to provide our services and products); and/or
• compliance with a legal obligation; and/or
• vital interests of the data subject; and/or
• where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
We may also use your personal data in the following situations, which are likely to be less common:
• where we need to protect your interests (or someone else’s interests);
• where it is needed in the public interest or for official purposes.

DISCLOSURE:
We may share personal data with third parties as is necessary in the provision of our services and products, including to third party providers who deliver services to support the operation of our company or third parties with whom we need to deal in the provision of our services and products. We may also need to share your personal data with a regulator or otherwise to comply with the law.

We may also disclose your personal data with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.

Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

In respect of all disclosures of personal data, we will only share the personal information which is necessary for the particular purpose for which it is provided, or where we have another legitimate interest in doing so, and we will ensure that the personal data is appropriately protected.

RETENTION PERIOD:
We will keep personal data only for as long as is necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting or reporting requirements. Normally, our retention period for personal data collected for this purpose is one year.

2. Our events, newsletters, other information services & marketing materials (“our Information”)

COLLECTION:
We will collect information such as name, email address, IP address (or similar unique identifiers) job title and the business that you work for together with the additional information that you provide to us, for example when you let us know those areas of our business that you are interested in receiving information about. In respect of events that we offer, this information may include details of access or dietary requirements that you have (which may reveal information about the religious beliefs of a data subject).

We may collect this information from you (whether directly or via automated means such as our website) or from third parties (such as a client).

We will collect personal data when you tell us that you wish to receive all or part of our information, or otherwise give us your personal details. You may at any time tell us that you wish to stop receiving our Information.

USE:
Personal data will be used to provide you with our information that you ask for, or that we think is relevant to the preferences that you may have given to us. We may analyse what areas of information are of interest to you so that we can better target the Information that we provide.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• with your consent; and/or
• in performance of a contract (the agreement to provide our services and products); and/or
• where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

DISCLOSURE:
We may share personal data with third parties in respect of the provision of our Information, including to third parties who provide services to us, including IT, website hosting, email delivery and other services. In respect of all disclosures of personal data, we will only share the personal information which is necessary for the particular purpose for which it is provided, or where we have another legitimate interest in doing so, and we will ensure that the personal data is appropriately protected.

RETENTION PERIOD:
We will keep personal data only for as long as is necessary to fulfil the purposes for which we collected it. Any personal data that we have from you solely for the purposes of your receiving our Information will not be used once you have asked us to stop providing these to you (except to the extent that it is necessary to stop you receiving the Information).

3. Our people
COLLECTION:
We will collect names, addresses, email and other contact details, education and employment history, identity and other background checks (which may include appropriate criminal and financial checks and confirmation of the right to work in the UK), marital status and information on next of kin and dependents, financial information (such as bank details and NI numbers), date of birth, gender, a copy of your passport and driving licence, performance information and compensation history, recruitment information (including references), salary, benefits, pension and annual leave information, disciplinary and grievance information, photographs, information about your use of our information and communications systems and CCTV footage or other information obtained through electronic means.

We may collect and use special categories of personal data as required in the carrying out of obligations and exercising specific rights of us or the data subject in the field of employment. This may include information relating to matters such as health, racial origin, religious belief and offences or alleged offences.

Personal data may be collected from you during the selection process (for example via your application form and CV) and during your employment (including holiday forms, expense claims, performance reviews, any disciplinary or grievance processes), or from third parties, including referees, health service providers, background check providers.

USE:
Personal data of our people will be used for HR administration and management, both in respect of the selection of people to work for us (including suitability, eligibility and/or fitness to work), and those who do work for us, to include learning and development, disciplinary and security (of people, offices and data) requirements, providing and liaising with benefits providers, business management and planning (including accounting and auditing), paying you and dealing with tax and NI deductions, assessing and deciding on salary reviews and compensation, conducting performance reviews and managing performance, dealing with legal disputes involving you or others, preventing fraud, monitoring your use of our information and communications systems, ensuring compliance with our policies, and equal opportunities monitoring.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• In performance of a contract with you; and/or
• compliance with a legal obligation; and/or
• vital interests of the data subject; and/or
• where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

We may also use your personal data in the following situations, which are likely to be less common:
• where we need to protect your interests (or someone else’s interests);
• where it is needed in the public interest or for official purposes.

In respect of all disclosures of personal data, we will only share the personal information which is necessary for the particular purpose for which it is provided, or where we have another legitimate interest in doing so, and we will ensure that the personal data is appropriately protected.

In respect of special categories of personal data, we may process this in the following circumstances:
• in limited circumstances with your explicit written consent; and/or
• where we need to carry out our legal obligations and in line with our policies; and/or
• where it is needed in the public interest (such as for equal opportunities monitoring or in relation to our occupational pension scheme), and in line with our policies; and/or
• where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your (or someone else’s) interests and you are not capable of giving your consent, or where you have already made the information public. We may also process such information about our people (or former people) in the course of our legitimate business activities with the appropriate safeguards.

The special categories of personal data may be used in the following ways:
• in relation to leaves of absence, to comply with employment and other laws;
• in relation to your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work, to monitor, manage and administer benefits and absences;
• in relation to your race, national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.

DISCLOSURE:
Personal data may be transferred to service providers who support the operation of our business (such as payroll service providers), to other third parties reasonably necessary in the conduct of our business (including insurers, professional advisors, regulators). These third parties may be acting as our processor, or as a controller of personal data in their own right. Personal data may also be shared with our clients in offering or in the provision of legal services.

In respect of all disclosures of personal data, we will only share the personal information which is necessary for the particular purpose for which it is provided, or where we have another legitimate interest in doing so, and we will ensure that the personal data is appropriately protected.

RETENTION PERIOD:
We will keep personal data only for as long as is necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting or reporting requirements. We will normally keep personal data of applicants who we do not employ for six months after we receive it.
We will keep personal data of employees throughout your employment and normally for a minimum of six years after your employment ends.

4. Changes to your personal data
It is very important that the personal information that we hold about you is accurate and current. Please tell us if your personal information changes during your relationship with us.

5. Data Security
We have put in place measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those of our people and other third parties who have a business need to know. They will only process your personal data on our instructions and where they have agreed to treat the information confidentially and to keep it secure. We have put in place procedures to deal with any suspected data security breach and will notify you and the ICO of a suspected breach where we are legally required to do so.

6. Where we store your personal data
We principally store data, both electronically and on file. Files are normally kept at our offices, with archive storage for historic files locally. The servers used for our electronic storage are All websites and VPS are hosted in secure, state-of-the-art data centres based in the Midlands, UK. They’re manned 24/7 and include high-level physical security measures. These cover everything from backup power generators to advanced fire protection.

7. Your rights
Under certain circumstances, you have the right by law to request:
• access to your personal data. This enables you to ask to receive a copy of the personal data that we hold about you and to check that we are lawfully processing it.

• correction of the personal data that we hold about you.
• erasure of your personal data.
• Object to processing of your personal data where we are relying on our legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
• restriction of processing of your personal data.
• transfer of your personal data to another party.

8. Links from our website
Our website may, from time to time, contain links to and from the websites of third parties that we permit to make such links. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. We recommend that you check these policies before you submit any personal data to these websites.

CHANGES TO THIS PRIVACY POLICY
Any changes we may make to our privacy policy in the future will be posted on our website, so please ensure that you are viewing the correct version.
Please contact us if you have any questions, comments or requests regarding this Privacy Policy.

COOKIE POLICY
This Cookie Policy explains how BXM Store Ltd ("Company", "we", "us", and "our") uses cookies and similar technologies to recognize you when you visit our websites at https://www.bxmexpeditions.co.uk, ("Websites"). It explains what these technologies are and why we use them, as well as your rights to control our use of them. In some cases we may use cookies to collect personal information, or that becomes personal information if we combine it with other information.

What are cookies? Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are widely used by website owners in order to make their websites work, or to work more efficiently, as well as to provide reporting information. Cookies set by the website owner (in this case, BXM Store Ltd) are called "first party cookies".

Cookies set by parties other than the website owner are called "third party cookies". Third party cookies enable third party features or functionality to be provided on or through the website (e.g. like advertising, interactive content and analytics). The parties that set these third party cookies can recognize your computer both when it visits the website in question and also when it visits certain other websites.

Why do we use cookies? We use first and third party cookies for several reasons. Some cookies are required for technical reasons in order for our Websites to operate, and we refer to these as "essential" or "strictly necessary" cookies. Other cookies also enable us to track and target the interests of our users to enhance the experience on our Online Properties.

Third parties serve cookies through our Websites for advertising, analytics and other purposes. This is described in more detail below. The specific types of first and third party cookies served through our Websites and the purposes they perform are described below (please note that the specific cookies served may vary depending on the specific Online Properties you visit): How can I control cookies?

You have the right to decide whether to accept or reject cookies. You can exercise your cookie rights by setting your preferences in the Cookie Consent Manager. The Cookie Consent Manager allows you to select which categories of cookies you accept or reject. Essential cookies cannot be rejected as they are strictly necessary to provide you with services.

The Cookie Consent Manager can be found in the notification banner and on our website. If you choose to reject cookies, you may still use our website though your access to some functionality and areas of our website may be restricted. You may also set or amend your web browser controls to accept or refuse cookies. As the means by which you can refuse cookies through your web browser controls vary from browser-to-browser, you should visit your browser's help menu for more information. In addition, most advertising networks offer you a way to opt out of targeted advertising.

If you would like to find out more information, please visit http://www.aboutads.info/choices/ or http://www.youronlinechoices.com. The specific types of first and third party cookies served through our Websites and the purposes they perform are described in the table below (please note that the specific cookies served may vary depending on the specific Online Properties you visit):

Essential website cookies: These cookies are strictly necessary to provide you with services available through our Websites and to use some of its features, such as access to secure areas.

What about other tracking technologies, like web beacons? Cookies are not the only way to recognize or track visitors to a website. We may use other, similar technologies from time to time, like web beacons (sometimes called "tracking pixels" or "clear gifs").

These are tiny graphics files that contain a unique identifier that enable us to recognize when someone has visited our Websites or opened an e-mail including them. This allows us, for example, to monitor the traffic patterns of users from one page within a website to another, to deliver or communicate with cookies, to understand whether you have come to the website from an online advertisement displayed on a third-party website, to improve site performance, and to measure the success of e-mail marketing campaigns.

In many instances, these technologies are reliant on cookies to function properly, and so declining cookies will impair their functioning. Do you use Flash cookies or Local Shared Objects? Websites may also use so-called "Flash Cookies" (also known as Local Shared Objects or "LSOs") to, among other things, collect and store information about your use of our services, fraud prevention and for other site operations. If you do not want Flash Cookies stored on your computer, you can adjust the settings of your Flash player to block Flash Cookies storage using the tools contained in the Website Storage Settings Panel.

You can also control Flash Cookies by going to the Global Storage Settings Panel and following the instructions (which may include instructions that explain, for example, how to delete existing Flash Cookies (referred to "information" on the Macromedia site), how to prevent Flash LSOs from being placed on your computer without your being asked, and (for Flash Player 8 and later) how to block Flash Cookies that are not being delivered by the operator of the page you are on at the time).

Please note that setting the Flash Player to restrict or limit acceptance of Flash Cookies may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with our services or online content.

Do you serve targeted advertising? Third parties may serve cookies on your computer or mobile device to serve advertising through our Websites. These companies may use information about your visits to this and other websites in order to provide relevant advertisements about goods and services that you may be interested in. They may also employ technology that is used to measure the effectiveness of advertisements. This can be accomplished by them using cookies or web beacons to collect information about your visits to this and other sites in order to provide relevant advertisements about goods and services of potential interest to you.

The information collected through this process does not enable us or them to identify your name, contact details or other details that directly identify you unless you choose to provide these.

How often will you update this Cookie Policy? We may update this Cookie Policy from time to time in order to reflect, for example, changes to the cookies we use or for other operational, legal or regulatory reasons. Please therefore re-visit this Cookie Policy regularly to stay informed about our use of cookies and related technologies. The date at the top of this Cookie Policy indicates when it was last updated. Where can I get further information? If you have any questions about our use of cookies or other technologies, please email us at info@bxmoutdoors.com.