TBCCI PRIVACY POLICY
1.Introduction:
1.1.This privacy policy gives you information about how Turkish-British Chamber of Commerce and Industry (“TBCCI”) collects, uses and protects your personal data through your use of this website, including any data you may provide when you register with us as our member or purchase a service from us.
1.2.This website is not intended for children and we do not knowingly collect data relating to children.
1.3.By visiting our website www.tbcci.org you are accepting the terms of this privacy policy (“Terms”).
1.4.Turkish-British Chamber of Commerce and Industry is the controller and responsible for your personal data and referred to as “Chamber“, “we”, “us” or “our” in this privacy policy.
1.5.If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the information set out in Clause 14.
2.Types of personal data:
2.1.Personal data means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
2.1.1. Identity Data includes first name, last name, title, date of birth and gender.
2.1.2. Contact Data includes billing address, delivery address, email address and telephone numbers.
2.1.3. Financial Data includes bank account details.
2.1.4. Transaction Data includes details about payments to us from you and other details of services you have purchased from us.
2.1.5. Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
2.1.6. Profile Data includes your purchases or orders made by you, your interests, preferences, and feedback.
2.1.7. Usage Data includes information about how you interact with and use our website and services.
2.1.8. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
2.2.We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.
We use different methods to collect and process data from and about you including through:
3.1.Your interactions with us. You may give us your personal data by filling in forms, by exchanging business cards at events and face to face meetings or by corresponding with us by email, phone, post or otherwise. This includes personal data you provide when you apply for our services; use our website; or contact us.
3.2.Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy for further details.
3.3.Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
3.3.1. Technical Data is collected from the following parties:
3.3.1.1. Analytics providers such as Google based outside the UK; and
3.3.1.2. Search information providers based inside and outside the UK.
3.3.2.Identity and Contact Data is collected from publicly available sources such as Companies House based inside the UK.
The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
4.1.Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
4.2.Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
4.3.Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
4.4.Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you register to join the Chamber as a member.
We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
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Purpose/Use
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Type of data
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Legal basis
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To register you as a new service customer or a member
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(a) Identity
(b) Contact
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Performance of a contract with you
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To provide our services and deliver your order including:
(a) Process our certification and documentation services
(b) Book an event or meeting with you
(c) Manage payments, fees and charges
(d) Collect and recover money owed to us
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(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
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(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
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To manage our relationship with you which will include:
(a) Notifying you about changes to our company policies and terms and conditions
(b) Dealing with your requests, complaints and queries
(c) Making referrals within or outside our members list for promoting your business
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(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
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(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and manage our relationship with you
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To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
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(a) Identity
(b) Contact
(c) Technical
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(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation)
(b) Necessary to comply with a legal obligation
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To deliver relevant website content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you
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(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
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Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
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To use data analytics to improve our website, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing
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(a) Technical
(b) Usage
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Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
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Other
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(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Technical
(f) Profile
(g) Usage
(h) Marketing and Communications
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Your prior informed consent
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We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.
7.Opting out of our marketing:
7.1.You can ask to stop sending you marketing communications including our activities, services, initiatives, news, past and future events, at any time by contacting us using the information set out in Clause 14.
7.2.If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to your order confirmations for our services, meeting or event reminders, updates to our company policies and terms and conditions, checking that your contact details are correct.
For more information about the cookies we use and how to change your cookie preferences, please see our Cookie Policy.
9.1. We may share your personal data where necessary with internal or external third parties for the purposes set out in Clause 5. This includes the 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.
9.2. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
10.International transfers:
10.1. We share your personal data within the Chamber staff or management team operating outside the UK; Chamber members; or service providers that carry out certain functions on our behalf. This will involve transferring your data outside the UK to other countries such as Turkiye.
10.2. Whenever we transfer your personal data out of the UK to countries which have laws that do not provide the same level of data protection as the UK law, we always ensure that a similar degree of protection is afforded to it by requiring all the parties who are the recipient of your personal data transfer to be bound by the same set of rules, our GDPR policies, including this Privacy Policy, when processing your personal data.
11.1. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
11.2. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
12.1. We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
12.2. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
12.3. By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers.
12.4. In some circumstances you can ask us to delete your data: see Clause 13 for further information.
13.1. Under data protection laws in relation to your personal data, you have the right to:
13.1.1. Request access to your personal data (commonly known as a “subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
13.1.2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
13.1.3. Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
13.1.4. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
13.1.5. Withdraw consent at any time where we are relying on consent to process your personal data However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you.
13.1.6. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data (including making the data unavailable to users to prevent any processing except storing the date or temporarily removing published data from our website), in one of the following scenarios:
13.1.6.1. If you want us to establish the data’s accuracy;
13.1.6.2. Where our use of the data is unlawful but you do not want us to erase it and requests restriction instead;
13.1.6.3. Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
13.1.6.4. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
13.2. If you wish to exercise any of the rights set out above, please contact us using the information set out in Clause 14.
13.3. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
13.4. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
If you have any questions about this privacy policy or about the use of your personal data or you would like to exercise your privacy rights, please contact us in the following ways:
Email address: info@tbcci.org
Postal address: 6th Floor 69 King William Street, London, England, EC4N 7HR
Telephone number: 07483155646
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
16.Changes to the privacy policy and your duty to inform us of changes:
16.1. We keep our privacy policy under regular review to reflect the changes in the new technologies, business practices, regulatory changes and Chamber and membership relations.
16.2. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
18.Miscellaneous:
18.1. These Terms constitute the entire agreement. Our failure to exercise or enforce any right or provision of these Terms shall not operate as a waiver of such right or provision.
18.2. These Terms operate to the fullest extent permissible by law. We may assign any or all of our rights and obligations to others at any time. We shall not be responsible or liable for any loss, damage, delay, or failure to act caused by any cause beyond our reasonable control.
18.3. If any provision or part of a provision of these Terms is determined to be unlawful, void, or unenforceable, that provision or part of the provision is deemed severable from these Terms and does not affect the validity and enforceability of any remaining provisions.
18.4. You hereby waive any and all defences you may have based on the electronic form of these Terms and the lack of signing by the parties hereto to execute these Terms.
18.5. These Terms, and any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with them or their subject matter or formation shall be governed by, and construed in accordance with the law of England and Wales. We both irrevocably agree to the exclusive jurisdiction of the courts of England and Wales to settle any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with these Conditions and the Contract or their subject matter or formation.
