Privacy Policy

Every – Be Midhurst Devco Limited

Privacy Policy

Thank you for visiting our website. This privacy policy sets out how Every collects and processes your personal information and the rights you have in relation to that information. It also describes the cookies we may use and send to your computer or mobile device.

For the purposes of applicable privacy laws, BE Midhurst Devco Limited, trading as Every (“Every”, “we”, “us”, “our”) of 50 Hans Crescent, London, SW1X 0NA, United Kingdom is responsible for your personal information. Every is committed to maintaining the confidentiality and security of your personal information. This “Policy” establishes guidelines with respect to our collection, use and disclosure of personal information that you may provide to us. In this Policy, the term “personal information” means information about an identifiable individual or that allows an individual to be identified.

In handling your personal information, Every will comply with the EU General Data Protection Regulation 2016/679 of the European Parliament and of the European Council (“GDPR”) and any other applicable data protection laws in the United Kingdom.

By visiting our website, by using our products and/or services and/or by your provision of information to us, you acknowledge the terms of this Policy and the use and disclosure of your personal information as set out in this Policy.

Personal Information We Collect, Use and Disclose

We collect, use and disclose personal information from individuals for purposes permitted or required by applicable law, as described in this Policy or as we may indicate to you from time to time.

We may collect information about you by recording phone calls (if you contact us by phone), or keeping correspondence (if you contact us by email, post or via our website or social media pages). We will collect your IP address if you visit our website, and authentication details (if you have an account and access your account using details to verify your identity). We will not collect any special categories of data (which have special status under data protection law) unless you share this information yourself.

Every collects personal information directly from the individual to whom it relates, except where that individual has consented to Every collecting the personal information from a third party or the law otherwise permits Every to do so.

We will use and disclose personal information for a number of reasons, including:

  • to take steps at your request prior to entering into a contract with you;
  • to help us manage our business and to improve and offer our products and services;
  • to enable us to respond to any enquiries that you submit to us via our website;
  • to ensure that our website runs smoothly and to improve the functionality of the website to better serve your requirements;
  • to send you publications and marketing information; or
  • to meet legal, regulatory, industry, audit, security or ethical requirements.

Legal bases for processing your personal information

There are a number of different ways that we are lawfully able to process your personal information. We have described these below.

Legitimate interests

We are allowed to use your personal information where it is in our legitimate interests to do so and it is not unfair to you. We believe that we have a legitimate interest in:

  • taking steps prior to entering into a contract with you;
  • managing our business;
  • responding to enquiries that you submit to us;
  • administering our website for internal operations, including troubleshooting, data analysis, testing, research, and statistical and survey purposes;
  • ensuring that our systems run smoothly; and
  • keeping our systems secure.

Contractual obligations

We are allowed to use your personal information when it is necessary to do so for the performance of any contract we have with you.

Other legal obligations

As well as our obligations to you under any contract, we also have other legal obligations that we need to comply with, and we are allowed to use your personal information when we need to in order to comply with those other legal obligations.

Consent

We are allowed to use your personal information where you have specifically consented. For example, we will obtain your consent to send you email notifications where you have requested them. You have the right to withdraw your consent at any time.

Disclosure of your personal information

We may share your personal information with:

  • our affiliates;
  • third party service providers providing services on our behalf;
  • a regulator or law enforcement body;
  • legal advisors, auditors and other professional advisors; or
  • a prospective buyer or seller of our business assets.

We take reasonable contractual and other measures to require that the organisations with whom we share personal information maintain the confidentiality of personal information in accordance with applicable law and only use such information for the specific purpose for which we supply it to them.

Your rights

The GDPR grants you the following rights in relation to your personal information:

  • you can object to us processing your personal information in certain circumstances (for example, where we have done so on the assumption that it is in our legitimate interests to do so);
  • you can withdraw consent at any time;
  • you can ask what information we hold about you and be provided with a copy. We will also give you extra information, such as why we use this information about you, where it came from and what types of people we have sent it to;
  •  you can ask us to send you, or another organisation, certain types of information about you in a format that can be read by computer;
  •  you can ask us to delete the information that we hold about you in certain circumstances (for example, where we no longer need the information);
  • you may in some cases restrict our use of information about you (for example, if you tell us that the information is inaccurate we can only use it for limited purposes while we check its accuracy);
  • if information is incorrect you can ask us to correct it;
  • you may have the right to ask us to assist you in transferring your personal data to a third party; and
  • you can lodge a complaint with your local supervisory authority. Please contact us for details of that supervisory authority.

The file containing your personal information will be kept at our offices or on our servers or those of our service providers and will be accessible to employees who require it for the purposes of their duties.

If you wish to request access to, or correction of, your personal information in our custody or control, or if you wish to withdraw your consent to the collection, use and disclosure of your personal information, please make your request in writing to 50 Hans Crescent, London, SW1X 0NA, United Kingdom, Attention: Head of Compliance.. In some circumstances, we may not be able to provide you with access to your personal information or parts of it. We will advise you at the time of the request.

Inquiries or complaints about this Policy and our personal information practices may be directed to 50 Hans Crescent, London, SW1X 0NA, United Kingdom, Attention: Head of Compliance.

International transfers of personal information

In some circumstances, the sharing of personal information with third parties or other group companies may involve the storage or processing of personal information outside the United Kingdom. We will take appropriate steps to ensure that any international transfer of personal information is carried out in accordance with applicable privacy laws. The protection of such personal information will be subject to the legal requirements of the jurisdictions where the information is transferred, including lawful requirements to disclose information to government authorities in those countries. If you have any questions about the collection, use, disclosure or storage of personal information, please contact us as indicated below.

Retention

We do not keep your personal information for longer than is necessary for the purposes for which we collect it unless we believe that law or regulation requires us to preserve it.

When it is no longer necessary to retain your data, we will delete the personal information that we hold about you from our systems, or put it beyond use until it can be permanently deleted to the extent this becomes possible.

Security

We take all reasonable precautions necessary to protect your personal data from misuse, interference, loss, unauthorised access, modification or disclosure.

Cookies and IP Addresses

We may obtain information about your computer, which includes your IP address, browser type and operating system where available. This accumulation of data is used to assist system administration.

We may also collect information regarding your browsing activity and interests through use of a cookie file. This cookie file is stored on the hard drive of your computer, and contains information that is transferred to your computer’s hard drive. We use the collection of this data to help us improve the experience of users on our website, and to deliver a more personalised service with more relevant content. The collection of this data allows us to:

  • store data indicative of your preferences, allowing us to adjust our website to appeal to your individual interests;
  • estimate the size and usage patterns of our audience;
  • record the details of any transactions carried out by you through our website;
  • identify you upon your return to our website; and/or
  • increase the speed of your searches.

We use the following cookies:

  • Strictly necessary cookies.

    These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.

  • Analytical/performance cookies.

    They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works.

  • Functionality cookies.

    These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences.

  • Targeting cookies.

    These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it (if any) more relevant to your interests. We may also share this information with third parties for this purpose.

You can find more information about some of the individual cookies we use and the purposes for which we use them below. Example of cookies that we use:

Tool Cookie Purposes
Google Analytics We use Google Analytics to collect information about how visitors use the site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. For more information about Google’s privacy policy, please visit https://www.google.com/intl/en/policies/. If you do not wish to allow the use of Google Analytics cookies at all, Google provides an opt-out plug-in for most common website browsers https://tools.google.com/dlpage/gaoptout.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies. You remain entitled to refuse cookies by adjusting your browser settings accordingly. Doing so however may restrict your access to certain areas within our website. Unless you adjust your browser settings to refuse cookies, our system will issue cookies when you log on to our website.

Policy Changes

This Policy may be revised from time to time. You may contact us to obtain a current copy of this Policy. Your continued provision of personal information or use of our services following any changes to this Policy constitutes your acceptance of any such changes.