ENTREPRENEUR BOOTCAMP LIMITED

(Trading as “ The Chemistry Club”, The Chemistry Club-City”, “The Bruton Group”, “Bruton Digital” and “Networking Master Class”)

PRIVACY POLICY

Entrepreneur Bootcamp Limited registered in England and Wales with company number 03881289 whose registered address is Lawford House, Albert Place, London, England, N3 1QA (“We“, “Us”) is committed to protecting and respecting your privacy.

For the purpose of the United Kingdom’s General Data Protection Regulation, We are the controller of your information (which means we decide what information we collect and how it is used). We are registered with the Information Commissioner’s Office (ICO), the UK regulator for data protection matters, under number Z5107530.

This Privacy Policy (Policy) (together with and any other documents referred to herein) sets out the basis on which the personal data collected from you, or about you, or that you provide to Us will be processed by Us. Please read the following carefully to understand our views and practices regarding your personal data and how We will treat it.

YOUR PERSONAL INFORMATION

Information we collect from you

We collect and process some or all of the following types of information from you in the course of you attending our events:

• We will collect personal information such as name, email address, job title, employer name and telephone number(s).

• We will not record or process any information that falls into the “special categories of data” such as health or religious beliefs, even if you voluntarily provide this information.

• We process information that you provide to us by email or by filling in forms online or registering for further events or other communications.

• If you contact Us, We may keep a record of that communication.

Information we collect from other sources

We may also obtain personal data from other sources, such as the information that you publish on LinkedIn or include in press releases, or other information readily available in the public domain.

Where you provide data to a venue or service in order to attend an event your data will be governed by that organisation’s privacy policy

USES MADE OF YOUR INFORMATION

Under UK data protection law, we need a legal reason (known as a lawful basis) for holding, collecting and using your personal data. There are 6 main legal reasons which organisations can rely on. The most relevant are:

• pursue our legitimate interests (our justifiable business aims) but only if those interests are not outweighed by your other rights and freedoms (e.g. your right to privacy);
• to comply with a legal obligation that we have;
• to enter into and perform our contract with you;
• where you have consented to us using your personal data a certain way.

The following table sets out when we rely on each lawful basis.

Lawful Basis	Purpose for using your personal data
Contract	To administrate or perform any contract that we enter into with you directly. To process your payment information in connection with any contract we have with you. To send you updates about the events you have registered to attend.
Legitimate Interests	Where using your information is necessary to pursue our legitimate business interests to: To arrange and manage our events. To provide you with our services (where our contract for providing such services is with an organisation, rather than with you personally). To notify you about our events and other services that we believe may be of interest to you. To provide you with information that you request from us. To allow you to participate in networking with other attendees of our events, when you choose to do so. To provide a list of attendees, which is circulated to other attendees and prospective attendees in advance of each relevant event, and published on our website after each event. To carry out our obligations arising from any contracts entered into between you and Us and between Us and our other event attendees. To notify you about changes to our services. To protect our business and defend ourselves against legal claims. Where we use your information for our legitimate interests, we have assessed whether such use is necessary and that such use will not infringe on your other rights and freedoms.
Legal Obligation	Recording your preferences (e.g. marketing and option to restrict sharing of contact information) to ensure that we comply with data protection laws. Where we send you information to comply with a legal obligations (e.g. where we send you information about your legal rights). Where we retain information to enable us to bring or defend legal claims.

DISCLOSURE OF YOUR INFORMATION

We may disclose your personal data as follows:

• Event networking contacts: your name, job title and employer name may be provided to other attendees and prospective attendees of the events that you register to attend.
• Our personnel: our employees (or other types of workers) who have contracts containing confidentiality and data protection obligations in order to process your order.
• Our supply chain: other organisations that help us provide our services, including the operators of a venue at which an event is held.
• Our website hosting provider: the company who provides website hosting services to us may have access to some information (e.g. information from cookies and tracking technologies) to ensure that the website is working correctly.
• Our professional advisers: such as our accountants or legal advisors where we require specialist advice to help us conduct our business.
• Any actual or potential buyer of our business.

We may disclose your personal information to any third party:

• 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 any other agreements between us; or

• to protect the rights, property, or safety of Entrepreneur Bootcamp Limited, our members and guests and any third party We interact with to provide the services.

STORING YOUR PERSONAL DATA

Security

We take appropriate measures to ensure that any personal data are kept secure including security measures to prevent personal data from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. Where We process payment transactions, these will be encrypted using SSL technology.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where We are legally required to do so.

Unfortunately, the transmission of 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 your data transmitted to our email accounts; any transmission is at your own risk. Once We have received your information, We will use strict procedures and security features to try to prevent unauthorised access.

Keeping your personal data up to date

If your personal details change, you may update them by contacting us using the contact details below. If you have any questions about how We use data collected that relates to you, please contact us by sending a request by email to the contact details below.

We will endeavour to update your personal data within seven (7) working days of any new or updated personal data being provided to Us, in order to ensure that the personal data We hold about you is as accurate and up to date as possible.

How long we keep your personal data

• If you have registered to attend an event, We will hold your name, job title, employer name, event(s) attendence and related details, contact details and related correspondence for 7 days from the date of the last event you attended or registered to attend.
• If you have been invited to an event and not attended, We will hold your name, job title, employer name, event(s) invited to, contact details and related correspondence for 18 months from the date of the last communication received from you or sent to you

Where we store your personal data

All information We hold about you is stored on secure servers within the United Kingdom (UK) and/or European Economic Area (EEA).

We will only transfer information outside the UK where we have a valid legal mechanism in place (e.g. by using contracts approved by the UK Secretary of State).

YOUR RIGHTS

You have specific legal rights in relation to your personal data.

It is usually free for you exercise your rights and we aim to respond within one month (although we may ask you if we can extend this deadline up to a maximum of two months if your request is particularly complex or we receive multiple requests at once).

We can decide not to take any action in relation to a request where we have been unable to confirm your identity (this is one of our security processes to make sure we keep information safe) or if we feel the request is unfounded or excessive. We may charge a fee where we decide to proceed with a request that we believe is unfounded or excessive. If this happens we will always inform you in writing.

Your legal rights are as follows:

• access to your personal data and to certain other supplementary information that this Policy is already designed to address
• require Us to correct any mistakes in your information which We hold
• require the erasure of personal data concerning you in certain situations
• receive the personal data concerning you which you have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
• object at any time to processing of personal data concerning you for direct marketing
• object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
• object in certain other situations to our continued processing of your personal data
• otherwise restrict our processing of your personal data in certain circumstances
• claim compensation for damages caused by our breach of any data protection laws.
  
  

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the UK General Data Protection Regulation

If you would like to exercise any of those rights, please:

• email Us at the email address provided below; and
• let Us have enough information to identify you; and
• let Us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
• let Us know the information to which your request relates.

HOW TO COMPLAIN

We hope that We can resolve any query or concern you raise about our use of your information.

The UK General Data Protection Regulation also gives you right to lodge a complaint with the UK Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.

CHANGES TO OUR PRIVACY POLICY

We reserve the right to modify this Policy at any time. Any changes We may make to our Policy in the future will be made available on our Website. Your continued use of the services shall be deemed your acceptance of the varied privacy policy.

CONTACT

All questions, comments and requests regarding this Privacy Policy should be addressed to info@thebrutongroup.com or write to us at 73 Watling Street, London EC4M 9BJ