Bordeaux and Burgundy
External Privacy Notice
Last Updated: 28 September 2023
1. Who we are and what we do
Who we are
Bordeaux and Burgundy are a limited company registered in England and Wales under registration number 12712615 and we have our registered office at 85 Great Portland Street, London, England, W1W 7LT.
What we do
We are a marketing agency that carries out global marketing campaigns on behalf of commercial clients. Our clients provide us with access to their customer databases and systems so that we can design and distribute marketing materials on their behalf.
Bordeaux and Burgundy are committed to protecting the privacy and security of any personal data we process about you.
2. Purpose of this privacy notice
The purpose of this privacy notice is to explain what personal data we collect about you and how we process it. This privacy notice also explains your rights, so please read it carefully. If you have any questions, you can contact us using the information provided below under the ‘How to contact us’ section.
3. Who this privacy notice applies to
This privacy notice applies to personal data for which we are the data controller (being a data controller means that we decide what personal data to collect and how to process it.). The notice does not cover the personal data we hold on behalf of our clients as we are a ‘data processor’ for that information (meaning that we only act on our clients’ instructions regarding what information to collect and how to use it).
We may process personal data about you in our capacity as a data controller if:
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You are employed by a client who uses our products and services where your information has been shared with us in our capacity as a controller (for example, during the contracting process or to administer an existing client’s account).
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You visit our website
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You enquire about our products and/or services through our website.
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You otherwise communicate with us, including, but not limited to, emails, phone calls and texts.
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You apply for a job with us (this use of your personal data is covered separately in our Recruitment Privacy Notice found at www.bordeauxandburgundy.co.uk/recruitment-terms)
4. What Personal Data is
‘Personal Data’ means any information from which someone can be identified either directly or indirectly. For example, you can be identified by your name or an online identifier.
5. Personal Data we collect
The type of Personal Data we collect about you will depend on our relationship with you. For the type of Personal Data we collect see the table below in the section entitled ‘Our Purposes and Lawful Bases for Processing’
6. How we collect your Personal Data
We may collect personal data directly from you when you sign up as a client of Bordeaux and Burgundy and also when you communicate with us in person, by email, over the telephone or via our website,
7. Our Purposes and Lawful Bases for processing
We will only use your personal data when the law allows. Most commonly, we will use your personal data for the purposes set out in the table below:
8. Sharing your Personal Data
We may store your personal data with external software providers such as Google and Salesforce in the course of providing our services to you.
9. International Transfers
We work with contractors outside of the UK who require access to the personal data on our systems in order to help us run our client accounts. We also use record systems which may store personal data on servers outside of the UK (for example Saleforce and Google’s G-Suite).
We have taken appropriate steps to ensure that the Personal Data processed outside the UK has an essentially equivalent level of protection to that guaranteed in the UK. We do this by ensuring that:
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Your Personal Data is only processed in a country which the Secretary of State has confirmed has an adequate level of protection (an adequacy regulation), or
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We enter into an International Data Transfer Agreement (“IDTA”) with the receiving organisation and adopt supplementary measures, where necessary. (A copy of a template IDTA agreement can be found here international-data-transfer-agreement.pdf (ico.org.uk)).
10. Your rights and how to complain
You have certain rights in relation to the processing of your Personal Data, including to:
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Right to be informed
You have the right to know what personal data we collect about you, how we use it, for what purpose and in accordance with which lawful basis, who we share it with and how long we keep it. We use our privacy notice to explain this.
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Right of access (commonly known as a “Subject Access Request”)
You have the right to receive a copy of the Personal Data we hold about you.
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Right to rectification
You have the right to have any incomplete or inaccurate information we hold about you corrected.
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Right to erasure (commonly known as the right to be forgotten)
You have the right to ask us to delete your Personal Data.
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Right to object to processing
You have the right to object to us processing your Personal Data. If you object to us using your Personal Data for marketing purposes, we will stop sending you marketing material.
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Right to restrict processing
You have the right to restrict our use of your Personal Data.
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Right to portability
You have the right to ask us to transfer your Personal Data to another party.
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Automated decision-making.
You have the right not to be subject to a decision based solely on automated processing which will significantly affect you. We do not use automated decision-making.
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Right to withdraw consent
If you have provided your consent for us to process your Personal Data for a specific purpose, you have the right to withdraw your consent at any time. If you do withdraw your consent, we will no longer process your information for the purpose(s) you originally agreed to, unless we are permitted by law to do so.
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Right to lodge a complaint
You have the right to lodge a complaint with the relevant supervisory authority, if you are concerned about the way in which we are handling your Personal Data. The supervisory authority in the UK is the Information Commissioner’s Office who can be contacted online at:
Or by telephone on 0303 123 1113
How to exercise your rights
You will not usually need to pay a fee to exercise any of the above rights. However, we may charge a reasonable fee if your request is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
If you wish to exercise your rights, you may contact us using the details set out below within the section called ‘How to contact us and our Data Protection Officer’. We may need to request specific information from you to confirm your identity before we can process your request. Once in receipt of this, we will process your request without undue delay and within one month. In some cases, such as with complex requests, it may take us longer than this and, if so, we will keep you updated.
11. How to contact us and our Data Protection Officer
If you wish to contact us in relation to this privacy notice or if you wish to exercise any of your rights outlined above, please contact us as follows:
85 Great Portland Street, London, England, W1W 7LT.
george@bordeauxandburgundy.co.uk
We have also appointed a Data protection Officer (“DPO”). Our DPO is Evalian Ltd and they can be contacted as the address below:
dpo.evalian.co.uk
[Please mark your communications FAO the ‘Data Protection Officer’.]
12. Changes to this privacy notice
We may update this notice (and any supplemental privacy notice), from time to time as shown below. We will notify of the changes where required by applicable law to do so.
Last modified [28 September 2023]
Sources of Personal Data
Categories of Personal Data collected
Purpose of Processing
Lawful Basis
Our clients' employees
Name, job title, work telephone number, email address, company you work for
To provide us with points of contact within a client’s business for the purposes of setting up and administering the client’s account with us and providing our marketing services to the client.
Legitimate Interests – it is within our legitimate interests to have contact points within the client where this is necessary to administer their account with us and provide our services to them.
Website visitors
Information about your device and your usage of our websites or emails (such as Internet Protocol (IP) addresses or other identifiers), which may qualify as Personal Data
To operate and administer our site and analyse visitor trends in order to help us improve the website user experience.
Legitimate interests – it is within our legitimate interests to provide visitors with access to our website content and to analyse how visitors interact with the site in order to help us improve the performance and content of the site and the overall visitor experience.
Website enquiries and other correspondence
Name, company, email address, job title, telephone number
To enable us to follow up interest in our product from prospective clients.
To enable us to fulfil requests and enquiries from our existing clients.
Legitimate Interests – it is within our legitimate interests to follow up any expressions of interest in our product from prospective clients in order to generate new business.
It is also within our legitimate interests to communicate with our clients in order to resolve their queries and fulfil their requests.
Website enquiries and other correspondence (continued)
Name, company, email address, job title, telephone number
To send marketing materials including newsletters, surveys, emails, promotions and offers from time to time.
Marketing Consent - it is within a lawful basis with your consent to allow us to process your personal data for marketing purposes.
If you have provided your consent for us to process your Personal Data for a specific purpose, you have the right to withdraw your consent at any time. If you do withdraw your consent, we will no longer process your information for the purpose(s) you originally agreed to, unless we are permitted by law to do so.
