Barbourne Brook Limited’s Privacy Policy

Who We Are

Our website address is https://www.barbournebrook.co.uk.

Introduction

This Privacy Policy outlines Barbourne Brook Ltd’s practices regarding information collected from users who access our website at www.barbournebrook.co.uk or otherwise share personal information with us (collectively, “Users”). 

Grounds for data collection

Processing of your personal information (i.e. any information which may allow your identification through reasonable means; hereinafter “Personal Information “) is necessary for providing you with our services, to protect our legitimate interests, and to comply with legal and financial regulatory obligations to which we are subject. When you use the Site, you consent to the collection, storage, use, disclosure, and other uses of your Personal Information as described in this Privacy Policy.We encourage our Users to carefully read the Privacy Policy and use it to make informed decisions.

Third Party Processors

Our carefully selected partners and service providers may process personal information about you on our behalf as described below:

Digital Marketing Service Providers

We periodically appoint digital marketing agents to conduct marketing activity on our behalf. Such activity may result in the compliant processing of personal information. Our appointed data processors include Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here. Sopro is registered with the ICO Reg: ZA346877. Their Data Protection Officer can be emailed at [email protected].

What information do we collect?

We collect two types of data and information from Users. The first type of information is un-identified and non-identifiable information about a User(s), which may be made available or gathered via your use of the Site (“Non-personal Information”). We are not aware of the identity of a User from which the Non-personal Information was collected. Non-personal Information, which is being collected, may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time, etc.) to enhance the functionality of our Site. We may also collect information about your activity on the Site (e.g. pages viewed, online browsing, clicks, actions, etc.).The second type of information is Personal Information, which is individually identifiable information that identifies an individual or may, with reasonable effort, identify an individual. Such information includes:

How do we receive information about you?

We receive your Personal Information from various sources:

How do we safeguard your information?

We do not rent, sell or share Users’ information with third parties, except as described in this Privacy Policy. We may use the information for the following:

• Communicating with you – sending you notices regarding our services, providing you with technical information and responding to any customer service issue you may have;
  
• To communicate with you and to keep you informed about our latest updates and services;
• To market our websites and products (see more under “Marketing”); 
• For statistical and analytical purposes, intended to improve the Site.
• Hosting and operating our Site;
• Providing you with our services, including providing a personalised display of our Site;
• Storing and processing such information on our behalf; 
• Providing you with marketing offers and promotional materials related to our Site and services; 
• Performing research, technical diagnostics or analytics;

We may also disclose information if we have good reason to believe that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies (including our Agreement), including investigations of potential violations thereof; (iii) investigate, detect, prevent or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our users, yourself or any third party; or (vi) to collaborate with law enforcement agencies and/or in case we find it necessary to enforce intellectual property or other legal rights.

In addition to the different uses listed above, we may transfer or disclose Personal Information to our subsidiaries, affiliated companies and subcontractors.

Use of Our Software Platform CAT360

When you use CAT360, our cloud-based customs analytics platform, we process additional information beyond that collected via our website. This includes both business data uploaded to the platform and user account information required to access and operate the service.

Types of Data Collected and Processed

We process the following categories of data:

• Account data: such as names, email addresses, roles and permissions of platform users.
• Uploaded customs data: including import/export declarations, tariff classifications, currency values, declarant information, and audit notes.
• Usage data: such as login timestamps, tracked changes, activity logs, and file uploads/downloads.
• Metadata: including file names, time of upload, and system-generated identifiers.

Lawful Basis for Processing

We rely on the following lawful bases for processing this data:

• Contractual necessity: to provide access to CAT360 and its core features.
• Legitimate interests: to improve and monitor platform performance, ensure compliance with our terms of use, and provide customer support.
• Legal obligation: where processing is required to meet record-keeping or tax compliance responsibilities.

Data Hosting and Security

All CAT360 data is stored securely using UK- or EU-based cloud infrastructure. We implement appropriate technical and organisational measures, including encryption, access controls, and regular backups, to safeguard the confidentiality and integrity of your data.Access to platform data is limited to authorised personnel at Barbourne Brook and is monitored to prevent unauthorised access or misuse.

Data Sharing

We do not share or sell your CAT360 data to third parties. Your data may be shared with trusted service providers who help us operate the platform, under strict contractual terms ensuring your data is protected and not used for other purposes.We will only disclose data when required by law, regulation, or a lawful request by public authorities.

Data Retention

Unless otherwise agreed, your uploaded data will be retained for as long as your organisation maintains an active subscription to CAT360. Data may be retained for a limited period upon termination to allow for export, dispute resolution, or legal compliance. You may request deletion of your data at any time, subject to legal obligations.

International Transfers

If any data is transferred outside the UK or EEA (e.g. to sub-processors in the United States), we ensure appropriate safeguards are in place, such as Standard Contractual Clauses or adequacy decisions, in line with UK GDPR requirements.

Your Rights

As a data subject, you retain full rights over your personal data as outlined in this policy’s “Your Rights” section. Platform users may also request access to or deletion of any personal data held within CAT360, subject to our legal and contractual obligations. For more details on acceptable use and service terms, please see our CAT360 Software Services Agreement.

User Rights

You may request to: 

• Receive confirmation as to whether or not personal information concerning you is being processed and access your stored personal information, together with supplementary information.
• Receive a copy of personal information you directly volunteer to us in a structured, commonly used, machine-readable format.
• Request the rectification of your personal information, which is under our control.
• Request erasure of your personal information.
• Object to the processing of personal information by us.
• Request to restrict the processing of your personal information by us.
• Complain with a supervisory authority.

However, please note that these rights are not absolute and may be subject to our legitimate interests and regulatory requirements. If you wish to exercise any of the above rights or receive more information, please get in touch with our Data Protection Officer (“DPO”) using the details provided below: [email protected].

Retention

We will retain your personal information for as long as necessary to provide our services, and as required to comply with our legal obligations, resolve disputes and enforce our policies. Retention periods will be determined taking into account the type of information collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable opportunity. Under applicable regulations, we will keep records containing client personal data, account opening documents, communications and anything else as required by relevant laws and regulations. 

We may rectify, replenish or remove incomplete or inaccurate information at any time and our own discretion.

Cookies

We and our trusted partners use cookies and other technologies in our related services, including when you visit our Site or access our services. A “cookie” is a small piece of information that a website assigns to your device while you are viewing a website. Cookies are very helpful and can be used for various purposes. These purposes include allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier. Cookies are also used to help ensure that the advertisements you see are relevant to you and your interests and to compile statistical data on your use of our Services. 

The Site uses the following types of cookies:

a. ‘session cookies’ which are stored only temporarily during a browsing session to allow normal use of the system and are deleted from your device when the browser is closed;

b. ‘persistent cookies ‘ which are read only by the Site, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next sign-in; 

c. ‘third-party cookies’ are set by other online services that run content on the page you are viewing, for example, by third-party analytics companies who monitor and analyse our web access.

Cookies do not contain any information that personally identifies you, but Personal Information that we store about you may be linked, by us, to the information stored in and obtained from cookies. You may remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our Site may not operate properly, and your online experience may be limited. We also use a tool called “Google Analytics” to collect information about your site use. Google Analytics collects information such as how often users access the Site, which pages they visit, when they do so, etc. We use the information we obtain from Google Analytics only to improve our Site and services. Google Analytics collects the IP address assigned to you on the date you visit sites, rather than your name or other identifying information. We do not combine the information collected through Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

Third-party collection of information

Our policy only addresses the use and disclosure of information we collect from you. To the extent you disclose your information to other parties or sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose. Accordingly, we encourage you to read the terms and conditions and privacy policy of each third party you disclose information to. This Privacy Policy does not apply to the practices of companies we do not own or control, nor to individuals whom we do not employ or manage, including any of the third parties to whom we may disclose information as set out in this Privacy Policy. 

How do we safeguard your information?

We take great care in implementing and maintaining the security of the Site and your information. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorised access or abuse our Site, and we make no warranty, express, implied or otherwise, that we will prevent such access.

Transfer of data outside the EEA 

Please note that some data recipients may be located outside the EEA. In such cases, we will transfer your data only to countries approved by the European Commission as providing an adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection.

Marketing

We may use your Personal Information, such as your name, email address, telephone number, etc., ourselves or by using our third-party subcontractors, for the purpose of providing you with promotional materials concerning our services which we believe may interest you. To respect your right to privacy, within such marketing materials we provide you with the means to opt out of receiving further marketing offers from us. If you unsubscribe, we will remove your email address or telephone number from our marketing distribution lists. Please note that even if you have unsubscribed from receiving marketing emails from us, we may send you other important email communications without allowing you to opt out of receiving them. These may include customer service announcements or administrative notices.

Corporate transaction

We may share information in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, the transferee or acquiring company will assume the rights and obligations described in this Privacy Policy.

Updates or amendments to this Privacy Policy

How to contact us