BMW Collaboration Lab 2018 – PRIVACY POLICY

INTRODUCTION
1. This is the privacy policy for “BMW Collaboration Lab 2018 USA” (the Programme) and website.
2. The Programme is organised by L Marks Limited (the Administrator of the Programme), in conjunction with BMW Group Financial Services North America (the Sponsor of the Programme). Any reference to we, us, or our in this policy is a reference to only the Administrator, unless otherwise stated.
3. We are committed to respecting the privacy of users of the Programme website (www.bmwcollaborationlab.com) (the Website) and applicants to the Programme. The following statement explains our policy regarding the personal data we collect from you about your use of our Website and the application process.
4. The Administrator is the data controller for your personal data. We are registered in England and Wales with company number 7756651. The Administrator’s registered office address is 20 Broad Lane, Hale, Altrincham, Cheshire, WA15 0DF.
5. The Sponsor is located at 5550 Britton Pkwy, Hilliard, OH 43026, USA.
6. By using our Website or participating in the application process, you consent to us using your personal data as described in this privacy policy.
APPLICABILITY OF THIS POLICY
1. This policy applies to any person accessing our Website and to any person submitting an application to participate in the Programme. This policy does not apply to participation in the Programme itself, which is governed by separate terms which will be notified to you if you are invited to participate.
2. The Administrator and the Sponsor are separate entities, and only the Administrator will collect and store your personal data.
3. Where you submit an application, this privacy policy applies in addition to our application terms. When you submit an application, you agree to the terms of this privacy policy.
4. Applications are made through the F6S website. The F6S website has its own privacy policy which describes how F6S may use your personal data. If you decide to use the F6S website you should review F6S’s policy in addition to our own policy. Please note that the Administrator and Sponsor are not responsible for the user account that you have registered with F6S.
PERSONAL DATA
1. We may collect your contact information, such as your name, address, telephone numbers (including mobile number) and email address, when you use our website to submit an application or participate in the selection process. If you choose to provide it, we may also collect contact information about other individuals, such as your team members or associates, for the same purposes.
2. We are committed to protecting your privacy, and will only use your personal data in accordance with applicable data protection legislation, including the Data Protection Act 1998 and (once applicable) the General Data Protection Regulation.
3. To properly complete our application form, we require you to provide some basic data about yourself. This is information that we consider necessary or desirable so that we can properly consider your application. If you do not agree to us holding this information about you, please do not complete an application.
PERSONAL DATA FOR OTHERS
1. It is possible that during the application process, for example whilst completing the application form or participating in pitch day, you may provide us with personal data relating to other individuals, such as team members or other people involved in your business or business idea.
2. Where you do provide us with personal data relating to other people, it is essential that you:
  1. inform those people that you will be providing their personal data to us;
  2. provide them with a copy of these terms so that they are aware of how their personal data may be used and their rights in respect of it; and
  3. obtain their written consent (for example by way of email) to you providing the information to us.
USE OF DATA
1. We may use your personal data for the purposes of:
  1. responding to any enquiry that you submit to us (whether via our Website enquiry form or otherwise);
  2. considering your application to participate in the Programme;
  3. conducting due diligence about you and your application;
  4. making arrangements with you to attend and participate in pitch day;
  5. promoting the Programme;
  6. ensuring that our Website is presented in the most effective manner for you and your computer;
  7. notifying you about a change to our Website or the application process; and
  8. record-keeping and tracking your use of the Website through use of cookies and log files (see paragraph 10 below).
2. We may also contact you regarding investment or commercial opportunities that we consider may be of interest to you. The Administrator works with a wide range of companies and investors and, where it considers that a company or investor it is working with might be interested in learning more about you and your business or business idea it may pass data (such as information about your business) onto that company or investor.
3. If that company or investor is interested in learning more about you, then the Administrator may request your permission to pass your personal data onto that company or investor, but will not pass your personal data on unless and until you have agreed to this.
4. If you do not want us to contact you or pass your personal data on in the way set out at paragraph 5.2 you can “opt out” by contacting us as described in paragraph 14.
5. We may use aggregate or anonymous data derived from your personal data for analytical or reporting purposes, publish them or share them with third parties.
6. Please be aware that any part of pitch day, including the pitches and the interviews, may be recorded and a copy of any recordings we make may be publicised and shared as we consider appropriate. You hereby consent to such recording.
7. Our legal bases for processing your personal data for the purposes for providing you our services and processing your application is consent, the performance of a contract, and to further the Sponsor or Administrator’s legitimate business interests. Our legitimate business interests may relate to promoting our product or services, improving of our products and services, fraud detection and prevention, risk assessment, or legal in compliance obligations in each jurisdiction where the Administrator, Sponsor, Sponsor’s parent, affiliates, or subsidiaries are located. If you choose not to provide your personal data where it is required as part of a contract for our products or services or to create your website account, we may be unable to provide you with our products or services. For example, if you choose not to provide your information for the purposes of an application to the program, we will be unable to consider you.
SHARING OF DATA
1. We may share your personal data in the following manner:
  1. with the Sponsor, its parent, affiliates, and subsidiaries for reviewing your application and your participation on pitch day;
  2. for completing due diligence on you (and your team or company, as appropriate) and your business or business idea;
  3. to help find investment and commercial opportunities for you, as described in paragraph 5.2 and 5.3;
  4. in publicity material, as described in the application terms;
  5. to suppliers involved in the operation of the Programme, for example the operator of the venue where pitch day is held to make arrangements regarding your attendance or a creative agency involved in publicising the Programme;
  6. 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 such other terms as apply to our relationship, or to protect the rights, property, or safety of our customers, ourselves or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction;
  7. if we determine that such disclosure is necessary for any investigation or complaint regarding your use of the Website or your application; and
  8. in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
INTERNATIONAL TRANSFERS
1. Please note that the Sponsor is located in, and governed by the laws of, the United States of America. USA is not an adequate jurisdiction under the EU Data Protection Directive nor the General Data Protection Regulation. By submitting your data to us, you consent to the transfer of our personal data to the USA for the purposes described in this privacy policy. We may store, access, or use your personal data in the United States, United Kingdom, Germany, or in any other country where Sponsor or its parent, affiliates, subsidiaries, or service providers maintain facilities. We may transfer personal data between different jurisdictions as a result of this storage, access, or use. We rely on your consent and performance of a contract for the transfers of personal data between the Sponsor and the Administrator and between the Sponsor and its parent, affiliates, subsidiaries, or service providers.
INCOMPLETE APPLICATIONS
1. The F6S website offers you the opportunity to save incomplete applications prior to submission. It is important to be aware that where you save an incomplete application we can access that application and the information within it, even if you have not submitted it. It is therefore important that you do not save any information in the application form that you would not be comfortable with us seeing.
ACCESS, CORRECTION, AND OTHER RIGHTS
1. You may have the right to access, correct, object, or delete your personal data. Please contact us using the details in paragraph 14.
2. We may need to verify your identity before we grant your right to object, access, correct, or delete. Once we do, we will provide you with a copy of the personal data that you request access to as soon as practically possible. As permitted by applicable law, we may limit these rights. For example, we may limit them where they adversely affect other individuals’ personal data, trade secrets, or intellectual property, among other reasons. We will tell you the reasons for any denial of your request. We may charge you a fee to exercise these right, which will not exceed $15.
3. You have the right to withdraw this consent at any time, which you may do by contacting us as described in paragraph 14. Please note however that the withdrawal of your consent will not affect any use of the data made before you withdrew your consent.
4. Where you provide us with personal data during your usage of the Website, in the application form or during the application process we may retain this information for future use, including:
  1. to speed up your future use of the Website and application form;
  2. for record keeping and compliance purposes;
  3. for exercising our rights set out in the application terms; or
  4. to contact you about investment and commercial opportunities that may arise in future.
5. The duration for which we retain your personal data will differ depending on the type of information and the reason why it was submitted. However, in some cases personal data may be retained on a long-term basis: for example, personal data that we need to retain for legal purposes will normally be retained for at least six years in accordance with usual commercial practice, regulatory requirements, and our data retention policies and procedures.
6. You are responsible for ensuring that the personal data that we hold about you is accurate and up-to-date, and you should check it on a regular basis. Until the closing date you will be able to update information via the application form on the F6S website, so where this personal data changes you can update it yourself. Following closure of the application process, or if you are otherwise unable to do this, you can contact us using the details in paragraph 14 and, where appropriate, we will update the relevant personal data for you.
7. If you want to withdraw your application at any time please contact us. Your withdrawal will result in the deletion of some of the personal data that we hold about you, but we may still retain some personal data, for example for record keeping purposes. Please note that we do not have the ability to close your F6S account or to delete all of the information that F6S may hold about you. You should contact F6S with any queries in this regard.
8. You may in certain circumstances be entitled to request the erasure of personal data that we hold on you. To make a request of this nature, please contact us, providing full details of the personal data you want to be erased and the reason(s) for your request. We will consider all requests upon receipt and confirm to you whether we are able to agree to your request.
9. Please be aware that the erasure of personal data that we hold about you may affect our ability to provide the Website and/or process your application and in some cases our acceptance of an erasure request may require us to cease considering your application.
COOKIES AND SIMILAR TECHNOLOGIES
1. We may use “cookies”, web beacons, or similar technologies on our website.
2. A cookie is a piece of data stored on a website visitor’s device to help us improve s, use, and security of our website and identify repeat visitors to our website. For instance, when we use a cookie to identify you, you would not have to enter a password more than once, thereby saving time while on our website. Web beacons are objects embedded into webpages that allow us to monitor site activity. Cookies, web beacons, and similar technologies can also help us track and target your interests so that we can enhance your experience on our website, conduct analytics, determine the effectiveness of promotional campaigns, and direct advertisements or other marketing activities.
3. We may also collect other automated information from you, such as your browser type and language, your operating system, your Internet Protocol address, the URLs of websites you visited before and after visiting our website, the web search that landed you on our website, and web pages and advertisements you view and links you click on within our website.
4. Some of our business partners, such as analytics providers, may also use cookies, web beacons, or similar technologies on our website. We may use cookies and similar technologies from Google Tag Manager and others. You may opt out of such collection by using the hyperlinks included above.
5. You may also accept or reject those cookies or block those technologies. Your browser’s help section should explain how to configure your browser’s cookie handling. Your browser may also have add-ons that may help you manage web beacons and similar technologies. However, please note that some portions of our websites require the use of cookies to function properly.
6. We may also include integration or links to social media platforms such as Facebook, Twitter, YouTube, Instagram, and others. These features for the social media platforms may also use cookies or similar technologies. They may collect your information, such as your IP address, device and browser type, and the web page you visited. You may also wish to review the privacy policies for those social media platforms to learn how they treat your information. We may collect information about you from those platforms when you access our website using those platforms. This information may include your user ID, username, and other information you choose to share with us, such as your profile picture or email address.
7. We have no control over cookies placed on your device by F6S or other third-party websites you may be linked to from this Website.
THIRD-PARTY WEBSITES
1. This privacy policy does not apply to F6S where you may submit your application. Please note that we do not control F6S and we are not responsible for its website in any way. If you do choose to submit an application via the F6S website you should ensure that you are agreeable to its terms of use and privacy policy and that you are comfortable with the security features that it has in place.
2. Our Website may, from time to time, contain links to and from other websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
ISSUES AND COMPLAINTS
1. If you have any questions or concerns about how your personal data is being used, please contact us as described in paragraph 14. This includes situations where you want to request the rectification or erasure of your personal data, restrictions to be placed around how we use your personal data, or to object to a particular use.
2. If you make a complaint about our handling of your personal data, it will be addressed in accordance with our complaints handling procedure.
3. In the first instance your complaint will be reviewed by an employee of the Administrator within 28 days.
4. If you are dissatisfied with the response to our initial review you may request that your complaint be escalated, in which case it will be passed to a senior person within the relevant business who will review your complaint and the initial response and provide a further response within 28 days of your request to escalate the matter.
5. We will endeavour to provide a full response within the relevant review period. However, in some cases further investigation may be necessary (for example, you may submit a complaint to the Administrator but it may have to discuss certain aspects of your complaint with the Sponsor).
6. If we cannot provide a final response within the relevant review period then we will provide an initial response acknowledging your complaint, explaining the reason for the delay and giving an estimate as to when a full response can be provided, and will aim to provide that full response as soon as we reasonably can following the expiry of the relevant review period.
7. If we are unable to resolve your complaint after you have escalated it to a senior person as described in paragraph 12.4 you may make a complaint to the Information Commissioner’s Office. Please see https://ico.org.uk/for-the-public/raising-concerns/ for more information.
CHANGES TO THE PRIVACY POLICY
1. We may revise this privacy policy from time to time, as permitted by law. When we revise this privacy policy, we will provide you with notice on the Website or by notifying you using email if you submitted an application.
2. Please review our policies and website frequently to learn about how we process your personal data. Please contact us as described in paragraph 14 if with any questions or concerns.
CONTACTING US
1. If you have a general query about this policy or the handling of your personal data, or if you have an issue regarding the use or retention of your personal data by the Administrator, please contact the Administrator at Ben Thomas, L Marks, Headland House 72 Acton Street, London, WC1X 9NB or by email at ben@lmarks.com.