{"id":21207,"date":"2019-01-18T12:56:04","date_gmt":"2019-01-18T12:56:04","guid":{"rendered":"https:\/\/www.bluefinfitness.com\/privacy-policy\/"},"modified":"2019-01-18T12:56:04","modified_gmt":"2019-01-18T12:56:04","slug":"privacy-policy","status":"publish","type":"page","link":"https:\/\/last.bluefinfitness.com\/us\/privacy-policy\/","title":{"rendered":"Privacy Policy"},"content":{"rendered":"

Your privacy is important to us and Bluefin\u00a0 takes this issue very seriously.<\/h3>\n

Click here<\/a> to download and read our full Privacy Policy.<\/h4>\n

Data Privacy Statement
\nv2.0_14\/05\/18
\nBluefin Trading Ltd. is committed to being transparent about how it collects and uses personal data
\nand to meeting its data protection obligations. This statement sets out its commitment to data
\nprotection. This statement applies to the personal data of clients, suppliers, contacts, third
\nparties or other personal data processed for business purposes. The personal data of job
\napplicants, employees, contractors, interns, apprentices and former employees, referred to as
\nHR-related personal data is covered by our HR Data Protection Policy. The wording in this statement
\nreflects the requirements of the General Data Protection Regulation (GDPR), which comes into effect
\non 25 May 2018.<\/p>\n

Bluefin has appointed the Data Manager as the person with responsibility for data protection
\ncompliance. Questions about this statement, or requests for further information, should be directed
\nto the Data Manager, Bluefin Trading Ltd, Keelham Farm, Hebden Bridge, HX7 8TG.
\n1. Interpretation
\nAutomated Decision-Making (ADM): when a decision is made which is based solely on
\nAutomated Processing (including profiling) which produces legal effects or significantly affects
\nan individual. The GDPR prohibits Automated Decision-Making (unless certain conditions are met) but
\nnot Automated Processing.
\nAutomated Processing: any form of automated processing of Personal Data consisting of the use of
\nPersonal Data to evaluate certain personal aspects relating to an individual, in particular to
\nanalyse or predict aspects concerning that individual\u2019s performance at work, health, preferences,
\ninterests, reliability, behaviour, location or movements. Profiling is an example of Automated
\nProcessing.
\nOrganisation: Bluefin Trading Ltd
\nConsent: agreement which must be freely given, specific, informed and be an unambiguous
\nindication of the Data Subject\u2019s wishes by which they, by a statement or by a clear
\npositive action, signify agreement to the processing of Personal Data relating to them.
\nData Controller: the person or organisation that determines when, why and how to
\nprocess Personal Data. It is responsible for establishing practices and policies in line with
\nthe GDPR. We are the Data Controller of all Personal Data used in our business for our own business
\npurposes.
\nData Subject: a living, identified or identifiable individual about whom we hold Personal Data.
\nData Subjects may be nationals or residents of any country and may have legal rights regarding
\ntheir Personal Data.
\nData Privacy Impact Assessment (DPIA): assessments used to identify and reduce risks of a data
\nprocessing activity. DPIA can be carried out as part of Privacy by Design and should be conducted
\nfor all major system or business change programs involving the processing of Personal Data.
\nEEA: the 28 countries in the EU and Iceland, Liechtenstein and Norway.
\nExplicit Consent: consent which requires a very clear and specific statement.
\nGeneral Data Protection Regulation (GDPR): the General Data Protection Regulation. Personal Data is
\nsubject to the legal safeguards specified in the GDPR.
\nPersonal Data: any information identifying a Data Subject or information relating to a Data Subject
\nthat we can identify (directly or indirectly) from that data alone or in combination with
\nother identifiers we possess or can reasonably access. Personal Data includes Sensitive
\nPersonal Data and Pseudonymised Personal Data but excludes anonymous data or data that has had the
\nidentity of an individual permanently removed. Personal data can be factual (for example, a
\nname, email address, location or date of birth) or an opinion about that person\u2019s actions or
\nbehaviour.<\/p>\n

Personal Data Breach: any act or omission that compromises the security,
\nconfidentiality, integrity or availability of Personal Data or the physical, technical,
\nadministrative or organisational safeguards that we or our third-party service providers put in
\nplace to protect it. The loss, or unauthorised access, disclosure or acquisition, of
\nPersonal Data is a Personal Data Breach.
\nPrivacy by Design: implementing appropriate technical and organisational measures in an effective
\nmanner to ensure compliance with the GDPR.
\nPrivacy Notices or Statements: separate notices setting out information that may be provided to
\nData Subjects when the organisation collects information about them.
\nProcessing or process: any activity that involves the use of Personal Data. It includes obtaining,
\nrecording or holding the data, or carrying out any operation or set of operations on the data
\nincluding organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing
\nalso includes transmitting or transferring Personal Data to third parties.
\nPseudonymisation: replacing information that directly or indirectly identifies an individual with
\none or more artificial identifiers or pseudonyms so that the person, to whom the data
\nrelates, cannot be identified without the use of additional information which is meant to be
\nkept separately and secure.
\nRelated Policies: the organisation\u2019s policies, operating procedures or processes related to this
\nPrivacy Statement and designed to protect Personal Data.
\nSensitive Personal Data: information revealing racial or ethnic origin, political
\nopinions, religious or similar beliefs, trade union membership, physical or mental health
\nconditions, sexual life, sexual orientation, biometric or genetic data, and Personal Data relating
\nto criminal offences and convictions.<\/p>\n

2. Scope<\/p>\n

We recognise that the correct and lawful treatment of Personal Data will maintain confidence in the
\norganisation and will provide for successful business operations. Protecting the confidentiality
\nand integrity of Personal Data is a critical responsibility that we take seriously at all times.<\/p>\n

The Data Manager is responsible for overseeing this Privacy Statement and, as applicable,
\ndeveloping Related Policies and guidelines. Please contact the Data Manager with any questions
\nabout the operation of this Privacy Statement or the GDPR or if you have any concerns that this
\nPrivacy Statement is not being or has not been followed.<\/p>\n

We adhere to the principles relating to processing of Personal Data set out in the GDPR which
\nrequire Personal Data to be:<\/p>\n

(a) Processed lawfully, fairly and in a transparent manner (Lawfulness, Fairness and
\nTransparency).
\n(b) Collected only for specified, explicit and legitimate purposes (Purpose Limitation).
\n(c) Adequate, relevant and limited to what is necessary in relation to the
\npurposes for which it is processed (Data Minimisation).
\n(d) Accurate and where necessary kept up to date (Accuracy).
\n(e) Not kept in a form which permits identification of Data Subjects for longer than is
\nnecessary for the purposes for which the data is processed (Storage Limitation).
\n(f) Processed in a manner that ensures its security using appropriate technical and
\norganisational measures to protect against unauthorised or unlawful Processing and against
\naccidental loss, destruction or damage (Security, Integrity and Confidentiality).
\n(g) Not transferred to another country without appropriate safeguards being in place
\n(Transfer Limitation).
\n(h) Made available to Data Subjects who are allowed to exercise certain rights in relation to
\ntheir Personal Data (Data Subject\u2019s Rights and Requests).<\/p>\n

We will demonstrate compliance with the data protection principles listed above (Accountability).<\/p>\n

3. Lawfulness, fairness, transparency<\/p>\n

3.1 Lawfulness and fairness<\/p>\n

Personal data will be processed lawfully, fairly and in a transparent manner in relation to the
\nData Subject. We will only collect, process and share Personal Data fairly and lawfully and for
\nspecified purposes. The GDPR restricts our actions regarding Personal Data to specified lawful
\npurposes. These restrictions are not intended to prevent processing but to ensure that we process
\nPersonal Data fairly and without adversely affecting the Data Subject.<\/p>\n

The GDPR allows processing for specific purposes, some of which are set out below:
\n(a) where the Data Subject has given Consent;
\n(b) if the processing is necessary for the performance of a contract with the Data Subject;
\n(c) to meet our legal compliance obligations;
\n(d) to protect the Data Subject\u2019s vital interests;
\n(e) to pursue our legitimate interests for purposes where they are not overridden
\nbecause the processing prejudices the interests or fundamental rights and freedoms of Data
\nSubjects. The purposes will be set out in applicable Privacy Notices.<\/p>\n

We identify and document the legal ground being relied on for each processing activity.
\n3.2 Consent<\/p>\n

We will only process Personal Data on the basis of one or more of the lawful bases set out in the
\nGDPR, which include Consent. A Data Subject consents to processing of their Personal Data if they
\nindicate agreement clearly either by a statement or positive action. Consent requires affirmative
\naction so silence, pre-ticked boxes or inactivity are unlikely to be sufficient. If Consent is
\ngiven in a document which deals with other matters, then the Consent will be kept separate from
\nthose other matters. Data Subjects can withdraw Consent to processing at any time and
\nwithdrawal will be promptly honoured. Consent may need to be refreshed if we intend to
\nprocess Personal Data for a different and incompatible purpose which was not disclosed when
\nthe Data Subject first consented.<\/p>\n

Unless we can rely on another legal basis of processing, Explicit Consent will be
\nrequired for processing Sensitive Personal Data, for Automated Decision-Making and for
\ncross border data transfers. Usually we will be relying on another legal basis (and not
\nrequire Explicit Consent) to process Sensitive Data. Where Explicit Consent is required, we will
\nissue a notice to the Data Subject.<\/p>\n

We will keep records of all Consents so that we can demonstrate compliance with Consent
\nrequirements.
\n3.3 Transparency (notifying data subjects)<\/p>\n

The GDPR requires Data Controllers to provide detailed, specific information to Data
\nSubjects. Whenever we collect Personal Data directly from Data Subjects, including for human
\nresources or employment purposes, we will provide the Data Subject with all the information
\nrequired by the GDPR including the identity of the Data Controller, how and why we will use,
\nprocess, disclose, protect and retain that Personal Data.<\/p>\n

When Personal Data is collected indirectly (for example, from a third party or publicly available
\nsource), we will provide the Data Subject with all the information required by the GDPR as soon as
\npossible after collecting\/receiving the data. We will check that the Personal Data was collected by
\nthe third party in accordance with the GDPR and on a basis which contemplates our proposed
\nprocessing of that Personal Data.<\/p>\n

4. Purpose limitation<\/p>\n

Personal Data will be collected only for specified, explicit and legitimate purposes. It will not
\nbe further processed in any manner incompatible with those purposes. We will not use
\nPersonal Data for new, different or incompatible purposes from that disclosed when it was
\nfirst obtained unless we have informed the Data Subject of the new purposes and they have Consented
\nwhere necessary.<\/p>\n

5. Data minimisation<\/p>\n

Personal Data will be adequate, relevant and limited to what is necessary in relation
\nto the purposes for which it is processed. Our personnel will not process Personal Data for any
\nreason unrelated to their job duties. When Personal Data is no longer needed for specified
\npurposes, it will be deleted or anonymised in accordance with our data retention guidelines.<\/p>\n

6. Accuracy<\/p>\n

Personal Data will be accurate and, where necessary, kept up to date. It will be
\ncorrected or deleted without delay when inaccurate. We will ensure that the Personal Data we
\nuse and hold is accurate, complete, kept up to date and relevant to the purpose for which we
\ncollected it. We will take all reasonable steps to destroy or amend inaccurate or out-of-date
\nPersonal Data.<\/p>\n

7. Storage limitation<\/p>\n

Personal Data will not be kept in an identifiable form for longer than is necessary for the
\npurposes for which the data is processed. We will not keep Personal Data in a form which permits
\nthe identification of the Data Subject for longer than needed for the legitimate business
\npurposes for which we originally collected it including for the purpose of satisfying
\nany legal, accounting or reporting requirements. We will take all reasonable steps to destroy or
\nerase from our systems all Personal Data that we no longer require in accordance with our records\u2019
\nretention policies. This includes requiring third parties to delete such data where applicable. We
\nwill inform Data Subjects of the period data is stored and how that period is determined.<\/p>\n

8. Security integrity and confidentiality<\/p>\n

8.1 Protecting Personal Data<\/p>\n

Personal Data will be secured by appropriate technical and organisational measures against
\nunauthorised or unlawful processing, and against accidental loss, destruction or damage. We will
\ndevelop, implement and maintain safeguards appropriate to our size, scope and business, available
\nresources, amount of Personal Data that we own or maintain on behalf of others and identified
\nrisks (including use of encryption and Pseudonymisation where applicable). We will
\nregularly evaluate and test the effectiveness of those safeguards to ensure security of our
\nprocessing of Personal Data.<\/p>\n

We will maintain data security by protecting the confidentiality, integrity and availability of the
\nPersonal Data, defined as follows:
\n(a) Confidentiality means that only people who have a need to know and are
\nauthorised to use the Personal Data can access it.
\n(b) Integrity means that Personal Data is accurate and suitable for the purpose for which it
\nis processed.
\n(c) Availability means that authorised users are only able to access the Personal
\nData when they need it for authorised purposes.<\/p>\n

8.2 Reporting a Personal Data Breach<\/p>\n

The GDPR requires Data Controllers to notify any Personal Data Breach to the
\napplicable regulator and, in certain instances, the Data Subject. We have put in place
\nprocedures to deal with any suspected Personal Data Breach and will notify Data Subjects or any
\napplicable regulator where we are legally required to do so.<\/p>\n

9. Transfer limitation<\/p>\n

The GDPR restricts data transfers to countries outside the EEA in order to ensure
\nthat the level of data protection afforded to individuals is not undermined. We will only
\ntransfer Personal Data outside the EEA if one of the following conditions applies:<\/p>\n

(a) the European Commission has issued a decision confirming that the country to
\nwhich we transfer the Personal Data ensures an adequate level of protection for the Data
\nSubjects\u2019 rights and freedoms;
\n(b) appropriate safeguards are in place;
\n(c) the Data Subject has provided Explicit Consent to the proposed transfer after being
\ninformed of any potential risks, or
\n(d) the transfer is necessary for one of the other reasons set out in the GDPR including the
\nperformance of a contract between us and the Data Subject; public interest; to establish, exercise
\nor defend legal claims, or to protect the vital interests of the Data Subject where the
\nData Subject is physically or legally incapable of giving Consent, and in some limited
\ncases, for our legitimate interest.<\/p>\n

10. Data Subject\u2019s rights<\/p>\n

Data Subjects have rights when it comes to how we handle their Personal Data. These include rights
\nto:
\n(a) withdraw Consent to processing at any time;
\n(b) receive certain information about the Data Controller\u2019s processing activities;
\n(c) request access to their Personal Data that we hold;
\n(d) prevent our use of their Personal Data for direct marketing purposes;
\n(e) ask us to erase Personal Data if it is no longer necessary in relation to the purposes
\nfor which it was collected or processed or to rectify inaccurate data\/complete incomplete data;
\n(f) restrict processing in specific circumstances;
\n(g) challenge processing which has been justified on the basis of our legitimate interests
\nor in the public interest;
\n(h) request a copy of an agreement under which Personal Data is transferred outside of the
\nEEA;
\n(i) object to decisions based solely on Automated Processing, including profiling (ADM);
\n(j) prevent processing that is likely to cause damage or distress to the Data Subject or
\nanyone else;
\n(k) be notified of a Personal Data Breach which is likely to result in high risk to their
\nrights and freedoms;
\n(l) make a complaint to the supervisory authority, and
\n(m) in limited circumstances, receive or ask for their Personal Data to be
\ntransferred to a third party in a structured, commonly used and machine readable format.<\/p>\n

We will verify the identity of an individual requesting data under any of the rights listed above.<\/p>\n

11. Accountability<\/p>\n

11.1 We will implement appropriate technical and organisational measures in an
\neffective manner, to ensure compliance with data protection principles. We have adequate
\nresources and controls in place to ensure and to document GDPR compliance including:
\n(a) appointing a suitably qualified manager accountable for data privacy;
\n(b) implementing Privacy by Design when processing Personal Data and completing
\nDPIAs where processing presents a high risk to rights and freedoms of Data Subjects;
\n(c) integrating data protection into internal documents;
\n(d) regularly training our personnel on the GDPR and data protection matters
\nincluding Data Subject\u2019s rights,
\nConsent, legal bases, DPIA and Personal Data Breaches, and
\n(e) regularly testing privacy measures and conducting reviews to assess compliance.
\n11.2 Record keeping<\/p>\n

The GDPR requires us to keep full and accurate records of our data processing
\nactivities. These records include the name and contact details of the Data Controller,
\nclear descriptions of the Personal Data types, Data Subject types, processing activities,
\nprocessing purposes, third-party recipients of the Personal Data, storage locations,
\ntransfers, retention periods and a description of security measures in place.
\n11.3 Training<\/p>\n

We will ensure all personnel have undergone adequate training to enable them to comply with data
\nprivacy laws.<\/p>\n

6
\n11.4 Privacy By Design and Data Protection Impact Assessment (DPIA)<\/p>\n

We are required to implement Privacy by Design measures when processing
\nPersonal Data by implementing appropriate technical and organisational measures
\n(like Pseudonymisation) in an effective manner, to ensure compliance with data
\nprivacy principles. We will take into account the following:
\n(a) the state of the art;
\n(b) the cost of implementation;
\n(c) the nature, scope, context and purposes of processing, and
\n(d) the risks, likelihood and severity for rights and freedoms of Data Subjects posed by the
\nprocessing.<\/p>\n

We will also conduct DPIAs in respect to high risk processing.
\n11.5 Automated Processing (including profiling) and Automated Decision-Making<\/p>\n

Generally, ADM is prohibited when a decision has a legal or similar significant effect on an
\nindividual unless:
\n(a) a Data Subject has Explicitly Consented;
\n(b) the processing is authorised by law, or
\n(c) the processing is necessary for the performance of or entering into a contract.<\/p>\n

If certain types of Sensitive Data are being processed, then grounds (b) or (c) will not be allowed
\nbut such Sensitive Data can be processed where it is necessary for substantial public interest like
\nfraud prevention. If a decision is to be based solely on Automated Processing (including
\nprofiling), then Data Subjects will be informed of their right to object. Suitable
\nmeasures will be put in place to safeguard the Data Subject\u2019s rights, freedoms and legitimate
\ninterests. We will inform the Data Subject of the logic involved in the decision making
\nor profiling, the significance and envisaged consequences and give the Data Subject the
\nright to request human intervention, express their point of view or challenge the
\ndecision. A DPIA will be carried out before any Automated Processing (including
\nprofiling) or ADM activities are undertaken.
\n11.6 Direct marketing<\/p>\n

We will specifically offer the right to object to direct marketing. A Data Subject\u2019s objection to
\ndirect marketing will be promptly honoured. If a client opts out at any time, their details will be
\nsuppressed as soon as possible. Suppression involves retaining just enough information to ensure
\nthat marketing preferences are respected in the future.
\n11.7 Sharing Personal Data<\/p>\n

Generally we are not allowed to share Personal Data with third parties unless certain
\nsafeguards and contractual arrangements have been put in place. We will only share the Personal
\nData we hold if the recipient has a job-related need to know the information and the transfer
\ncomplies with any applicable cross-border transfer restrictions. We will only share the Personal
\nData we hold with third parties, such as our service providers, if:
\n(a) they have a need to know the information for the purposes of providing the contracted
\nservices;
\n(b) sharing the Personal Data complies with a Privacy Notice provided to the Data Subject
\nand, if required, the Data Subject\u2019s Consent has been obtained;
\n(c) the third party has agreed to comply with required data security;
\n(d) the transfer complies with any applicable cross border transfer restrictions, and
\n(e) a fully executed written contract that contains GDPR approved third party clauses has
\nbeen obtained.<\/p>\n

12. Changes to this Privacy Statement<\/p>\n

any time so please check back regularly to obtain the latest
\ncopy of this Statement. This Privacy Statement does not override any applicable data privacy laws
\nand regulations.<\/p>\n","protected":false},"excerpt":{"rendered":"

Your privacy is important to us and Bluefin\u00a0 takes this issue very seriously. Click here to download and read our full Privacy Policy. Data Privacy Statement v2.0_14\/05\/18 Bluefin Trading Ltd. is committed to being transparent about how it collects and uses personal data and to meeting its data protection obligations. This statement sets out its […]\n","protected":false},"author":308,"featured_media":0,"parent":0,"menu_order":0,"comment_status":"closed","ping_status":"closed","template":"","meta":{"footnotes":""},"_links":{"self":[{"href":"https:\/\/last.bluefinfitness.com\/us\/wp-json\/wp\/v2\/pages\/21207"}],"collection":[{"href":"https:\/\/last.bluefinfitness.com\/us\/wp-json\/wp\/v2\/pages"}],"about":[{"href":"https:\/\/last.bluefinfitness.com\/us\/wp-json\/wp\/v2\/types\/page"}],"author":[{"embeddable":true,"href":"https:\/\/last.bluefinfitness.com\/us\/wp-json\/wp\/v2\/users\/308"}],"replies":[{"embeddable":true,"href":"https:\/\/last.bluefinfitness.com\/us\/wp-json\/wp\/v2\/comments?post=21207"}],"version-history":[{"count":0,"href":"https:\/\/last.bluefinfitness.com\/us\/wp-json\/wp\/v2\/pages\/21207\/revisions"}],"wp:attachment":[{"href":"https:\/\/last.bluefinfitness.com\/us\/wp-json\/wp\/v2\/media?parent=21207"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}