BullGuard Reseller Privacy Policy

About this policy

This policy describes how we collect and use personal data via our Reseller Lounge at www.bullguard.com/rl

This policy applies to data which is collected about individuals using the Reseller Lounge. This includes resellers who operate as sole traders or partnerships, and also individual employees of resellers who operate as corporate entities.

As a reseller of BullGuard products, you will be automatically enrolled in the Revenue Share program as soon as you have purchased 10 Bullguard licences to ensure that you can claim additional revenue through licence renewals. We have provided this policy to ensure that you understand what personal data we may collect and hold about you, what we may use it for and how we keep it safe when you use the Reseller Lounge.  You have legal rights to access the personal data that we hold about you and to control how we use it which are also explained.

You can read and print this whole policy or click on the links below to see specific information about:
  Who we are and how you can contact us

We are BullGuard Limited, a company registered in England and Wales under registration number 04392368.  Our registered office address is at 9 Devonshire Square, London, EC2M 4YF. 

You can contact us:
 
  • in writing at BullGuard Limited, Data Team, 9 Devonshire Square, London, EC2M 4YF
  • by emailing to data@bullguard.com

Personal data we collect about you

We may collect your personal data as follows:
 
  • Registration.  When you place your first order with a BullGuard distributor, the BullGuard distributor will collect personal information about you.  They will share some of this information with us so that we can register you on the Reseller Lounge.  The information they provide may include: your name and contact details, the name of your employer, how long you have been trading for, information about the kind of business you run and products you are interested in, what other products you sell and how you heard about BullGuard.
  • Enquiries. If you contact us to enquire about becoming a BullGuard reseller we will collect your name and contact details so we can respond to your questions.  We may keep a record of the fact that we have spoken to you, including any details you share with us about your business and interest in becoming a BullGuard reseller. 
  • When you use the Reseller Lounge.  Once registered, we collect and display information about your order, activated licences and renewals (and the additional income this entitles you to claim) to provide you with a useful portal to track and monitor your performance.  We will also collect financial details from you so we are able to pay you the additional income you have earned. We also collect details of communications you make via the Reseller Lounge, such as exchanges between you and your local account manager and requests for marketing materials.  If you contact us with support or service requests or concerns we will keep a record of this.
  • Technical information. When you use the Reseller Lounge we may collect:
     
    • technical information, including the Internet protocol (IP) address used to connect your computer or mobile device to the Internet, your login information, browser type and version, devices used or which connect to your network from time to time, time zone setting, browser plug-in types and versions, operating system and platform; and
    • information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from the site (including date and time); page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

The information that we collect about you as described above falls into two broad categories: Personally Identifiable Information (“PII”) which is information that can be used to identify you as an individual and Non-Personally Identifiable Information (“NPII”) which is information that cannot be used to identify you as an individual.  In general, information listed under the headings “Registration” and “Enquiries” and “When you use the Reseller Lounge” will be PII whilst “Technical information” will be NPII.  Where “Technical information” contains any PII we will anonymise the information for statistical and analytics purposes. 

What we use your personal data for

We use your personal data in the following ways:

PII

We will use this information:
 
  • to pay you the additional income you are entitled to as a result of licence renewals;
  • to respond to your enquiries and requests for assistance;
  • to notify you about changes to our products or to our services or terms;
  • to ensure that content from the site is presented in the most effective manner for you and for your device;
  • to allow you to participate in interactive features of our service, when you choose to do so;
  • to manage and administer our business;
  • to review and improve our products and services;
  • to understand and improve our relationships with our resellers.

NPII

 We will use this information:
 
  • to test, develop and improve the Reseller Lounge;
  • to produce analytical, statistical and tracking data;
  • to understand how the Reseller Lounge is accessed and used;
  • to administer the Reseller Lounge and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • to improve the Reseller Lounge to ensure that content is presented in the most effective manner for users;
  • as part of our efforts to keep the Reseller Lounge safe and secure;

When we need your consent to use your personal data

Whilst we always want you to be aware of how we are using your personal data, this does not necessarily mean that we are required to ask for your consent before we can use it.  In the day to day running of our business we may use your personal data without asking for your consent because:
 
  • we are entering into and carrying out our obligations under a contract with you;
  • we need to use your personal data for our own legitimate purposes (such as the administration and management of our business and the improvement of our services) and our doing so will not interfere with your privacy rights.
  • We ask for consent only for marketing purposes. Please refer to the section on “How we use your personal data for marketing” to read about marketing consents.

Personal data you are legally obliged to provide

You are not under a legal obligation to provide us with any of your personal data but please note that if you elect not to provide us with your personal data we will be unable to pay you the additional income you can claim for licence renewals.

Your rights to know what personal data we hold and to control how we use it

You have a legal right to know what personal data we hold about you - this is called the right of subject access.  You can exercise this right by sending us a written request at any time. Please mark your letter “Subject Access Request” and send it to us by post or email using the details in the “Who we are and how you can contact us” section.

You also have rights to:
 
  • prevent your personal data being used for marketing purposes (see “How we use your personal data for marketing” for further details);
  • have inaccurate personal data corrected, blocked or erased;
  • object to decisions being made about you by automated means or to your personal data being used for profiling purposes (see “Automated decision making and profiling”;
  • object to our using your personal data in ways that are likely to cause you damage or distress;
  • restrict our use of your personal data;
  • require that we delete your personal data;
  • require that we provide you, or anyone that you nominate, with a copy of any personal data you have given us in a structured electronic form such as a CSV file.

You can find full details of your personal data rights and the circumstances in which you are able to exercise them on the Information Commissioner’s Office website at www.ico.org.uk .

Automated decision making and profiling

We do not make use of automated decision making or profiling as part of the Reseller Lounge programme.

When we will share your personal data with others

We may share your personal information with any other companies that are part of the BullGuard group.

We may also share your information with selected third parties outside of the BullGuard group including with:
 
  • any business partners, suppliers and sub-contractors we work with to run the Reseller Lounge including any other distributor or reseller of our products;
  • analytics and search engine providers that assist us in the improvement and optimisation of the site;

We may also share your personal data with third parties on a one-off basis, for example if:
 
  • we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
  • If BullGuard Limited or substantially all of its assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or in order to enforce or apply our terms and conditions and other agreements entered into with you or to protect the rights, property, or safety of BullGuard Limited and its staff, our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction. 

When we share your information with a third party it will be for a specific purpose which has been expressly agreed between us and the third party.  We do not permit third parties to use your information for any purpose other than the purpose specifically agreed between us and them.

How we keep your personal data safe

We take every care to ensure that your personal data is kept secure.  The security measures we take include:
 
  • only storing your personal data on our secure servers;
  • ensuring that our staff receive regular data security awareness training;
  • keeping paper records to a minimum and ensuring that those we do have are stored in our locked offices;
  • maintaining up to date firewalls and anti-virus software to minimise the risk of unauthorised access to our systems;

Please remember that you are responsible for keeping your passwords secure. If we have given you (or you have chosen) a password which enables you to access certain parts of our website (or log in to your Reseller Lounge account), you are responsible for keeping this password confidential. Please do not to share your passwords with anyone.

Unfortunately, sending information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of personal data sent to our website; you send us personal data at your own risk. Once we have received your personal data, we will use strict procedures and security features (some of which are described above) to try to prevent unauthorised access.

How we use your personal data for marketing

We will add your details to our marketing database if you have consented to receiving our marketing communications.

If your details are included on our marketing database we will send you marketing communications by email or telephone.

If you wish to change your marketing preferences at any time you can do so by:
 
Accessing and managing your data and preferences

You can view and update some of your personal data and preference settings through Communications Preference Centre and we encourage you to take the time to log in to your account periodically for this purpose.  If you have any questions about how to manage your data and settings through your account please contact us using the details set out in the “who we are and how to contact us” section of this policy.

When we will send your personal data to other countries

Your personal data may be transferred to, and stored at, a destination outside the European Economic Area ("EEA") by us or by our sub-contractors. Where we, or our sub-contractors, use IT systems or software that is provided by non-UK companies, your personal data may be stored on the servers of these non-UK companies outside the EEA. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.  If you would like more information about exactly where your data may be transferred or the safeguards we have in place please contact us.

How long we keep your personal data

We only keep your personal data for as long as we actually need it. In practice this means that we will keep your personal data whilst you continue to act as a reseller of Bullguard Products, and thereafter for such time as we may need it to comply with our legal obligations, to resolve disputes or to enforce agreements. If you contact us to advise that yo do not wish to particp;ate in the reseller lounge progamme after receivnign your welcome letter we will delete your details from our resller database within a reasonable period not exceeding one month of your contacting us.  If you would like more information about how long your data may be retained please contact us. 

Please note that we may anonymise your personal data or use it for statistical purposes.   We keep anonymised and statistical data indefinitely but we take care to ensure that such data can no longer identify or be connected to any individual.

What about … cookies

We use cookies to distinguish you from other users of the Reseller Lounge. This helps us to provide you with a good experience when you use the Reseller Lounge and also allows us to improve the Reseller Lounge. We also allow selected third parties to use cookies on the Reseller Lounge. For more detailed information on the use of cookies on the site including information about the purposes for which we and third parties use them see our Cookies policy.

How you can make a complaint

If you are unhappy with the way we have used your personal data please contact us to discuss this using the contact details set out in the “Who we are and how to contact us” section of this policy.

You are also entitled to make a complaint to the Information Commissioner’s Office which you can do by visiting www.ico.org.uk.  Whilst you are not required to do so, we encourage you to contact us directly to discuss any concerns that you may have and to allow us an opportunity to address these before you contact the Information Commissioner’s Office.

How we keep this policy up to date

We will review and update this policy from time to time. This may be to reflect a change in the products or services we offer or to our internal procedures or it may be to reflect a change in the law. 

The easiest way to check for updates is by looking for the latest version of this policy on the Reseller Lounge.

Each time we update our policy we will update the policy version number shown at the end of the policy and the date on which that version of the policy came into force.

This is policy version 1 which came into effect on 28 June 2019.
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