Privacy Policy

This Privacy Policy for Benchmark International describes how and why we might collect, store, use and/or share (‘process’) your information when you use our services such as when you visit benchmarkintl.com or any website of ours that links to this Privacy Policy (collectively, “Our Site”) or engage with us in other related ways, including sales and/or marketing (“Services”).

This Policy is primarily aimed at EEA, EU and the UK. If you are accessing Our Site from any of the below mentioned States of the USA, please click on the link next to relevant State:

California https://www.benchmarkintl.com/landing/california
Connecticut https://www.benchmarkintl.com/landing/connecticut
Colorado https://www.benchmarkintl.com/landing/colorado
Utah https://www.benchmarkintl.com/landing/utah
Virginia https://www.benchmarkintl.com/landing/virginia

Please read this Privacy Policy carefully and ensure that you understand it. If you do not agree with our practices and policies, please do not use Our Site of Services.

Definitions and Interpretation
- In this Policy the following terms shall have the following meanings:
  "Contact Form"means an online contact form completion of which is required to register for access and/or use certain areas and features of Our Site
  
  "Cookie"means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and in our Cookie Policy available here https://www.benchmarkintl.com/cookie-policy
  
  "Cookie Law"means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
Information About Us
What Does This Policy Cover?
- This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
What Is Personal Data?
- If you are in the EU or UK, personal data is defined by the General Data Protection Regulation (GDPR), UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
- Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
What Are My Rights?
What Data Do You Collect and How?
Depending upon your use of Our Site, we may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. Please also see Part 14 for more information about our use of Cookies and similar technologies and our Cookie Policy https://www.benchmarkintl.com/cookie-policy. We do not collect any ‘special category’ or ‘sensitive’ personal data.

Data Collected How We Collect the Data

IP address; Log and Usage data (e.g. page and files viewed, searches, information requested, date and time of request); Browser type and version; device data and characteristics (e.g. hardware model, operating system and configuration and internet service provider); Location data (e.g. GPS and other technologies to collect geolocation data); Automatically when you visit and/or navigate our Site and/or use our Services.

Contact information including email address, telephone number, identity information including name, date of birth, title, gender profile information Completion of our online contact form; when you email or telephone us (we collect your telephone number and, in the UK, record any information during your conversation with us). By post, where you contact us; or when you interact with us on a social media platform using your social media account. When you sign up for our blogs or similar marketing activities.

Business information including business name, your job title, profession Completion of our online contact form and/or when you contact us by telephone and/or email.

Mailing addresses, job titles, phone numbers, intent data (or user behaviour data), IP addresses, social media profiles and URLs, custom profiles for the purposes of targeted advertising. Public databases, business directories, media publications, websites, joint marketing partners, affiliate programs, subscription and data providers, third party service providers, social media platforms and other third parties.
How and on what basis do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data.
The GDPR and UK GDPR require us to explain the valid legal bases upon which we rely in order to process your personal information. We may rely on the following legal bases:
- Consent. We may process your information when you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Please refer to section 5(g).
- Performance of a Contract We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
- Legal Obligations We may process your information where we believe it is necessary for compliance with our legal obligations e.g. to cooperate with a law enforcement body or regulatory agency, or to defend our legal rights. We may also need to disclose your personal information as evidence in litigation.
- Legimitate Interests Where we believe it is reasonably necessary to achieve our legitimate business interests, we may process your personal information for some of (but not limited to) the following purposes:
  - o Send you information on our Services (including special offers and discounts)
  - o Support our marketing activities
  - o Analyse how Our Site is being used in order that we may improve it to engage and retain users
  - o Understand how our users use Our Site and Services so we can improve the user experience
  - o Develop and display relevant and personalised advertising content for visitors to Our Site
  - o Diagnose problems and/or prevent fraudulent activities.
Vital Interests: We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party e.g. situations involving potential threats to the safety of a person.
The following table describes how we may use your personal data, and our lawful bases for doing so:

What We Do What Data We Use Our Lawful Basis

Registering you on Our Site via our online contact form Name, address, contact details Consent

Process your completed online contact form Name, address, contact details Consent and/or legitimate interests in offering the facility of online registration, authenticating and managing the same.

Providing and managing your access to Our Site. Name, address, contact details Consent and/or legitimate interests to facilitate your access to Our Site and opportunities of interest on Our Site.

Personalising and tailoring your experience on Our Site. Name, email address, your search criteria Consent and/or legitimate interests in maximising your experience on Our Site and customising it in accordance with your preferences.

Administering Our Site. Name, email address Consent and/or legitimate interests in maximising user experience on Our Site.

Administering our business. Name, email address Consent and/or legitimate interests in maximising our service offering and your experience on Our Site.

Supplying our services to you. Name, address, contact details. Consent and/or legitimate interests where we consider our Services may be of interest to you.

Personalising and tailoring our Services for you. Name, email address, analytics info etc Name, email address, analytics info etc. Consent and/or legitimate interests in maximising our service offering to you.

Communicating with you. Name, email address, telephone number(s) and postal address(es) Consent and/or legitimate interests to ensure that we respond to your enquiries and so you are provided with the information requested and/or such other information which we consider may be of interest to you.

Supplying you with information (including marketing and promotional communications) by email that you have opted-in-to (you may opt-out at any time by unsubscribing to our emails). Name, email address(es) Consent and/or legitimate interests in delivering information requested and/or information which we consider may be of interest to you.

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and/or telephone, text message or post with information, news, and offers on our Services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.

We use automated systems for carrying out certain kinds of decision-making and/or profiling. Please refer to our Cookie Policy: https://www.benchmarkintl.com/cookie-policy. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the Data Protection Legislation gives you the right to do so. Please contact us to find out more using the details in Part 15.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as for tax, accounting or other legal requirements). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (e.g. because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
How and Where Do You Store or Transfer My Personal Data?
We store some or all of your personal data within the UK and European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the GDPR and UK GDPR and/or to equivalent standards by law. Transfers of personal data to the EEA from the UK are permitted without additional safeguards.

We may also store some or all of your personal data in countries outside of the UK, including at our offices in the United States and South Africa. These are known as “third countries”. We will take all necessary measures to protect your personal data in accordance with this Privacy Policy and applicable law.

To protect your personal data when transferred between our group companies and between us and our third-party providers and partners, we use Binding Corporate Rules and the European Commission’s Standard Contractual Clauses, which can be provided upon request. For further information, please refer to the Information Commissioner’s Office.

Please contact us using the details below in Part 15 for further information about the particular data protection safeguard(s) used by us when transferring your personal data to a third country.

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
- limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality.
- implementing appropriate and reasonable technical and organisational security measures and procedures to protect the security of your personal data (e.g. by use of Secure Sockets Layer (SSL) software to encrypt any information you submit to us via the online contact form on Our Site and by only transferring your information via closed system or encrypted data transfers). However, no electronic transmission over the Internet or information storage technology can be 100% guaranteed and whilst we will do our best to protect your personal data, transmission of your personal data to and from Our Site and/or Services is at your own risk.
- procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so;
Do You Share My Personal Data?
We will not share any of your personal data with any third parties, subject to the following exceptions.

If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.

We may share your personal data with third parties which are either related to or associated with the running of our business, where it is necessary or appropriate for us to do so. These third parties include our holding company and subsidiaries, international offices, affiliates, service providers, accountants, advisors, business partners, independent contractors, third party marketing resources and insurers.

For reasons of security and competition, we do not display (by name), the identities of the third parties with whom we may share your information. If you would like further information about the identities of such third parties, please contact us directly at [email protected] and we shall provide you with such information where you have a reasonable and legitimate reason for requesting it e.g. where we have shared your information with such third parties.

If any of your personal data is shared with a third party, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.

If any personal data is transferred outside of the UK, we will take suitable steps to ensure that your personal data is treated just as safely and securely as it would be within the EU and UK and under the Data Protection Legislation, as explained above in Part 9.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
How Can I Control My Personal Data?
1. In addition to your rights under the Data Protection Legislation, set out in Part 5, when you visit and/or submit personal data via Our Site, you may be given options to restrict our use of your personal data. We aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails.
2. You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
Can I Withhold Information?
You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.

You may restrict our use of Cookies. For more information, see Part 14 and our Cookie Policy: https://www.benchmarkintl.com/cookie-policy.
How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request normally within 21 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date your request. You will be kept fully informed of our progress.
How Do You Use Cookies?
Our Site uses Cookies and other tracking technologies to collect and store information. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve our Services. We place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. By using Our Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used, for example, to maximise the efficacy of marketing campaigns. Our Site also uses widgets and analytics services provided by Hubspot and Google Analytics, which also uses Cookies. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling us to better understand how people use Our Site. For more details, please refer to our Cookie Policy: https://www.benchmarkintl.com/landing/cookies
How Do We Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:
For the UK and EU
- For the attention of: Michael Lawrie
- Email address: [email protected]
- Telephone: 0161 359 4400
- Postal address: One New Bailey, 4 Stanley Street, Manchester, United Kingdom, M3 5JL
For Africa
- For the attention of: Andre Bresler
- Email address: [email protected]
- Telephone: +27 (21) 300 2055
- Postal address: Benchmark International CSS ZA Pty, Airport Office Park, Freight Road, Ground Floor, Runway 01, International Airport, Cape Town 7525
For the USA
- For the attention of: Leo Vanderschuur
- Email address: [email protected]
- Telephone: +1 813 898 6044
- Postal address: Benchmark Capital Markets LLC, 4030 W Boy Scout Blvd, Suite 500, Tampa, Florida
Changes to this Privacy Policy
We may update this Privacy Policy from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any updated version will be indicated by an updated ‘Revised’ date and the updated version will be effective as soon as it is accessible. You will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.

This Privacy Policy was last updated on 11 October 2023

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