1. Introduction and General Terms
- what personal data BLUE BEAR may collect about you;
- how BLUE BEAR will use the personal data we collect about you;
- the reason and lawful basis for BLUE BEAR using your personal data;
- when BLUE BEAR may use your personal data to contact you;
- whether BLUE BEAR will disclose your personal data to anyone else;
- how long BLUE BEAR will retain your personal data;
- your rights in respect of the personal data you have provided to BLUE BEAR; and
As set out above, BLUE BEAR is committed to safeguarding your personal data.
2.What information will BLUE BEAR collect about me?
When you request to receive a storage price from BLUE BEAR, become a storage customer, use our other storage related services or communicate with BLUE BEAR through the Website, we will collect certain personal data about you.
Here are all of the different ways you can engage with BLUE BEAR and what information we collect about you for each one:
2.1 When obtaining a price for storage
If you are requesting a price through the BLUE BEAR website or over the telephone, we collect the following personal data from you; your title, first name, surname, email address, Company details, telephone number and postcode.
We also ask which site you are wishing to receive a price from, the type of customer you are (i.e. a domestic, business or student customer), when you want your storage to start and an approximation of how long you want the storage for. We ask the reason you need storage, for example moving home, decluttering, home improvements etc., and what storage container size you are obtaining a price for.
If you are a business and are requesting a storage price from us, we will also ask you the reason you need storage, for example, archiving, stock or as a distribution hub.
2.2 When making a storage reservation
If you are reserving a storage container with BLUE BEAR through the website, over the telephone, via email or face to face on site, in addition to the information we have collected from you when obtaining a price (see above section), we also collect your full postal address and ask if you would like extended hours access to your container.
2.3 When moving into storage
When you are about to move into BLUE BEAR as a customer, we require additional personal information about you.
This personal information includes: Your name, address, date of birth, an emergency contact name, an emergency contact telephone number, direct debit card details via Stripe and two forms of ID e.g driving licence and recent bill.
When providing information about an emergency contact, we will assume you have obtained their consent to provide their personal data to BLUE BEAR. Please note any personal data supplied about your emergency contact will not be used for direct marketing purposes or shared/sold to third parties.
2.4 When moving out of storage
The only additional information we ask for when you move out from BLUE BEAR, is your reason for leaving.
2.5 When buying packing materials online
If you buy packing materials from BLUE BEAR, you can do this in online.
The website also collects your payment card details, although this service is provided by a third party Stripe.
Stripe ask for your name, type of payment card, the card number, the card expiry date and the card’s CVC security number. These payment details are not stored with BLUE BEAR.
2.6 When using our LIVE CHAT service
In order to use our Live Chat service on our websites, we ask for a first name and an email address. We also record the transcript of the chat conversation.
2.7 When completing a customer feedback survey
Customer feedback surveys may be sent via email to our customers who have just moved in to storage, just moved out of storage, or who obtained a price from us but chose not to move in. Filling out these surveys is completely optional.
We use this feedback to help improve our service offering and the questions are therefore based on the user experience with the Website, the site and site teams. Your full name and email address are the only personally identifiable pieces if data that are used to email out the feedback surveys. The only other personal information collected about you, should you choose to complete these surveys, is gender and age.
2.8 Website information
3. How will BLUE BEAR use my personal data?
BLUE BEAR will use your personal information for the following purposes:
3.1 When requesting an online price for storage and obtaining services in relation to that price:
- to locate your nearest site, matching your requirements;
- to provide you with an online price and prices of similar containers at nearby sites (if applicable)
- to provide you with an automatic copy of the price by email;
- to provide you with an automatic copy of the price by text message (if requested)
- to contact you by telephone in order to discuss the price;
- to provide you with additional information in relation to your price (including by way of up to three follow up emails and three follow up telephone calls )
- to invite you to complete an online survey in relation to your experience when using BLUE BEAR;
- for compliance with legal, regulatory and other good governance obligations; and
- for administrative and any similar related purposes, including to ensure we have a record of your price (which will be held in accordance with the data retention periods noted in section 11 of this Policy), should you chose to order services at a later date.
3.2 When obtaining services following receipt of a price:
- to provide the requested services to you and receive payment for those services;
- to send you a reservation email and other details necessary for the services requested;
- to contact you by telephone to confirm any reservations made and to discuss the next steps
- to keep a record of your emergency/alternative contacts so that they can be contacted in accordance with section 7, below;
- to provide a price for storage insurance
- to email you a copy of the Step by Step Guide to Self Storage and Customer Licence before move-in
- to keep a record of your marketing preferences
- to provide information in relation to similar services (including promotions and offers), unless you have opted out of receiving such information (see section 8, below);
- for compliance with legal, regulatory and other good governance obligations;
- for administrative and any similar related purposes, or where we have a legal right or duty to use or disclose your information (including for crime and fraud prevention and related purposes).
3.3 When finalising your move-out:
- to email you a notice to move out confirmation (this confirms your move out date) and instructions on the move out procedure
- to email you a final invoice and process any refund due
- to email confirmation of your effective move out
- to request payment details for any refund
3.4 When collecting feedback/reviews on your BLUE BEAR experience:
- to email you a BLUE BEAR customer survey/review when you move out.
- to post your customer review/survey on the BLUE BEAR website from the customer survey but only if you have provided permission via the customer survey for this to happen.
- to use your feedback to improve our services
- to contact you, on your request in regards to your user experience expressed through these surveys
3.5 When servicing any online orders
- to email you a confirmation of your online order
- to deliver your order or to have it waiting for you on site
- to call to inform you of any problems or stock issues with your orders and to arrange suitable alternatives
3.6 When contacting BLUE BEAR via our “Live Chat” service on our Website
- to deal with any questions, comments or complaints you may have;
- to email you a transcript of the Live Chat with our Customer Support but only if you request it
3.8 When requesting we recommend local removal companies to you
- Only with your consent, we will pass on your name, email and/or phone number, to one of our recommended removal companies the sites work with, who will contact you in regards to removal services.
3.9 When signing up to receive BLUE BEAR promotional material.
- BLUE BEAR may wish to provide you with information about new products, services, promotions, offers, lifestyle features and competitions which may be of interest to you.
- We will only contact you on this basis if you have opted in to receive additional marketing information from us.
- You can exercise your right to prevent such processing by either not opting in to receive such communications or by unsubscribing from the emails at any time after you have opted in.
3.10 When using the Website generally:
- IP addresses are used to identify your location, the number of visits from different countries and also to block disruptive use;
- to analyse and improve the services offered on the Website e.g. to provide you with the most user-friendly navigation experience; and
- if you post or send offensive, inappropriate or objectionable content anywhere on or to the Website, or otherwise engage in any disruptive behaviour on the Website, BLUE BEAR may use your personal information to stop such behaviour and, where BLUE BEAR reasonably believes that you are or may be in breach of any of the laws of England or Wales (e.g. because content you have posted may be defamatory), BLUE BEAR may use your personal information to inform relevant third parties, including law enforcement agencies about the content and your behaviour.
- Inappropriate content within customer reviews will not be displayed on the BLUE BEAR website. This includes: off topic reviews not related to the service provided, content that contains links to other websites, email addresses and telephone numbers, content that contains obscene, profane or offensive language, hate speech or any content that discriminates or is offensive to individuals or groups based on race, ethnic origin, religion, disability, gender, age, nationality, sexual orientation or gender identity.
- This list of processing activities and the personal data we process, may be updated from time to time. Where BLUE BEAR proposes using your personal information for any other uses we will ensure that we notify you first.
In addition to the above, we may convert your personal data into statistical or aggregated data in such a way as to ensure that you are not identified or identifiable from that data. We may use this anonymised aggregated data or we may share it with our trade association to conduct market research and analysis, including to produce statistical research and reports. For example, we may produce reports on which of our products and services are most popular.
4. What is the lawful basis for BLUE BEAR to use my personal data?
Except as described below, the processing of your personal data as set out above, is done on the lawful basis that it is necessary for the legitimate interests pursued by BLUE BEAR, which do not unfairly prejudice your rights and freedoms or personal legitimate interests
4.1 Our basis for processing your personal data is based on legitimate interests for the enquirer. Here are the reasons for using legitimate Interest:
- 80% of our new customers have never used self storage before. (source: BLUE BEAR)
- As a consequence they misunderstand how much storage space they need to rent. For example, few people know what a 90 sq foot container looks like and how to use that space effectively.
- 75% of say they would find it helpful to have some professional advice in order to estimate the correct amount of storage space needed for their personal possessions. (source: BLUE BEAR)
- In fact, 40% of our customers since May 2016, moved into a different container size than they originally selected online to be quoted for, illustrating the need for professional advice on container size and space selection. (source: BLUE BEAR)
- Enquirers will often pick a storage size too large for their requirements, therefore incurring them unnecessary additional costs, or too small for their requirements therefore incurring additional inconvenience on their move in day. Enquirers do not think about the height of the storage unit or how to pack and stack up a storage container efficiently.
- Many people use self storage when they are going through key events in their lives. These are often stressful events such as moving home, divorce and separation, dealing with bereavement, starting a business, having building work or home improvements. We understand this and do not wish for our customers to have additional stress by arriving at the storage unit to find their container is not the right size.
Speaking with the potential customer at enquiry stage to understand their storage needs and make recommendations on the best storage size is therefore in the legitimate interest of our enquirers.
4.2 This is supported by ensuring our follow up contact is proportional and limited for a short period of time.
4.3 No personal data collected is ever used for any ongoing direct marketing by BLUE BEAR outside of the limited time after a storage enquiry has been made. Personal data is never exchanged or sold to third parties.
4.4 Our excellent customer feedback also highlights the benefit for us and our customers to understand the individual customer’s situation and help us make their lives easier.
When we have a contract with you for services, some processing of your personal data (for example, ensuring that you receive the service) may also be on the lawful basis that it is necessary to comply with our contractual obligations to you, in respect of those services.
Where we send certain marketing communications to you (please see section 8, below), we are required to obtain your consent.
Should you choose to withhold or withdraw your consent, BLUE BEAR will not process the affected personal data.
Finally, the processing of your personal data for administrative and record keeping purposes will be based on our legitimate interest (as described above) but may also be necessary for compliance with our legal obligations laid down by European Union law (where relevant) and by English Law.
5. How does BLUE BEAR protect your information?
BLUE BEAR applies appropriate technical and organisational measures to protect your data against unauthorised or unlawful processing and against accidental loss or destruction of, or damage to, personal data and to comply with the data protection laws. These procedures include that we shall permit only authorised employees, who are trained in the proper handling of customer information, to have access to that information.
Our customer feedback company, should you decide to complete an online survey uses passwords, encryption, AD authentication, network authentication, access control list and physical storage protection to protect any voluntary data they collect on you.
See section 11, How long will BLUE BEAR keep my personal information? For more details on when personal data is deleted.
6. When will BLUE BEAR contact me?
BLUE BEAR may contact you:
- In relation to an online price (as described in Section 3)
- In relation to the provision of any service you have signed up for, in order to ensure that BLUE BEAR can deliver the services to you e.g. reserving a storage container
- In relation to moving out of your storage container, when you give notice and arranging your refund
- Through regular emailed invoices
- Where you have opted-in to receive specific marketing correspondence (see Section 8)
- To invite you to participate in customer feedback surveys about BLUE BEAR services (participation is always voluntary);
- We might also contact you in response to customer feedback you have presented to us. This could be as a response to a complaint, issue or feedback on our service.
- In relation to our customer surveys where you have requested us to contact you as a response to a complaint, an issue or feedback on our service.
7. When will BLUE BEAR contact my Emergency/Alternative Contacts?
BLUE BEAR may contact your emergency/alternative contacts:
- Where you have purchased services from BLUE BEAR and you cannot be contacted at the details provided by you in respect of those services (for example where the storage period has expired but you have not reclaimed your items from storage); and/or
- Where you have authorised us (as your agent) to disclose, discuss and provide access to your account details to persons authorised by you in writing or otherwise identified by you to us as your alternative contact person(s), in accordance with, and to the extent of, your instructions.
- In providing emergency/alternative contact details, it is the customer’s responsibility to inform those individuals they are doing so. This is made clear to the customer at the point that any emergency/alternative contact details are asked for either through our initial online process or face to face on site.
7.1. Will I be contacted for marketing purposes?
- BLUE BEAR may wish to provide you with information by email about new products, services, promotions, offers, lifestyle features and competitions which may be of interest to you. These communications will only ever be sent with your consent, which we obtain at the point you actually move in. Therefore should you not become a customer of BLUE BEAR, you will not receive any marketing communications from us.
- You can of course choose not to receive direct marketing communications or opt-out/unsubscribe at any time by following the instructions contained in any marketing emails received.
- Please note that marketing communications are separate from any factual communications in relation to services that you receive or have requested from BLUE BEAR, including follow up calls or emails relating to your price request. Such factual communications will be sent on the lawful basis of it being in our legitimate interest, as set out in more detail above.
8. Will BLUE BEAR share my personal information with anyone else?
We will keep your information confidential except where disclosure is required or permitted by law (for example to HMRC, government bodies and law enforcement agencies) or as described in section 10 below.
BLUE BEAR also uses third parties to process your information on our behalf (for example, third party payment providers, professional advisors).
BLUE BEAR also use a number of independent measurement and research companies to gather information regarding the visitors to the Website on our behalf using cookies, log file data and code which is embedded on our Website (please see section 14, below). BLUE BEAR use this type of information to help improve the services it provides to its users.
BLUE BEAR will require these third parties to only process your personal data on the instructions of BLUE BEAR and will require that they do not use your personal information for their own business purposes.
BLUE BEAR may also transfer your personal data to a third party (where lawful to do so) in relation to any sale or restructuring of our business.
These third party companies include:
Customer Survey Companies
- A customer feedback company who send feedback surveys via email to our customers who have just moved in to storage, just moved out of storage, or who obtained a price from us, but chose not to move in to storage. We share the email address and the full name of the customer or prospect to send the customer survey to. Filling out these surveys is optional.
- Any customer who has given consent for their review to be published on the Website may also have their review removed by emailing [email protected]and submitting a request to do so. Details of the review and the reviewer will be deleted by BLUE BEAR within 72 hours of receiving the request.
Email services provider
- For any customers who have opted in to receive marketing communications from BLUE BEAR, their email address, first name and surname are transferred securely to our third party email provider who send the BLUE BEAR marketing emails on our behalf. These emails are currently limited to our “Big Ideas” quarterly email newsletter featuring lifestyle features and competitions and up to two marketing emails after a customer has moved out.
- All of these emails contain an Unsubscribe link, allowing the recipient to unsubscribe from any future marketing. Customer requests for unsubscribing are fed back into the BLUE BEAR database to ensure the customer record is then deleted and the recipient receives no further communications.
Auction Houses & Intermediaries for the Sale of Goods
Should a customer fail to pay their invoices (in breach of their contract) after our required reasonable time period, we are permitted to retrieve the storage costs, in accordance with our Customer Licence and may pass the debtors possessions onto an auction house.
When we collect online payments from you for self storage or for online purchases, we use a third party payment system called Stripe. Stripe will collect the following information from you; first name, surname, email address, phone number, IP address, postal address, postcode, credit card/debit card details. For more details on online shopping with Stripe click here.
Recommended Removal Companies
Only with your request and consent do we pass on your name, email and/or phone number, to one of our recommended removal companies our sites work with, who will contact you in regard to removal services.
10. Will BLUE BEAR transfer my personal data abroad?
BLUE BEAR does not process any personal data in jurisdictions other than the UK. However, some of our service providers may (from time to time) hold personal data on data centres located in other jurisdictions or otherwise rely on sub-contractors located in other jurisdictions. Where this is the case, please be aware that some jurisdictions outside the European Economic Area may not offer the same level of protection to your personal data as it is afforded in the UK.
If your personal data is to be transferred from within to outside the European Economic Area, we will only make that transfer if:
- the country to which the personal data is to be transferred ensures an adequate level of protection for personal data;
- we have put in place appropriate safeguards to protect your personal data, such as an appropriate contract with the recipient;
- the transfer is necessary for one of the reasons specified in data protection legislation, such as the performance of a contract between us and you;
- if the provider is based in the USA and is part of the Privacy Shield which requires them to provide similar protection to personal data to that which applies in Europe; or
- you explicitly consent to the transfer.
11. How long will BLUE BEAR keep my personal information?
Any data we do hold onto will be anonymous. Any personally identifiable information such as your name, address, date of birth and telephone number will be deleted after a defined period.
The anonymised data will be used to analyse general market and website trends.
For avoidance of doubt, here are the data retention periods for each of the circumstances where we would hold personal data:
11.1 When requesting a storage price
If you have requested an online price from us or over the telephone and we have created an enquirer record of you, we will delete your personal data 12 months after the date of your last contact with us.
11.2 When reserving storage (but you don’t take up storage)
If you have reserved storage space with us, but never actually taken it up, we will keep your personal data for 12 months from the date of your reservation.
11.3 When moving in and becoming a storage customer
If you moved in to storage, regardless of what period of time you moved in for, we will keep your personal data for the entire period you are a customer.
11.4 When moving out and becoming an ex-customer
We will keep your details for up to 7 years after you move out of our storage. Some personal information will be deleted earlier than this.
11.5 Online shop customers
All of your personal, identifiable information will be deleted 12 months from our customer database after the date the order was placed. Your name and address may still appear on archived invoices and credit notes issued and payments received and will be kept for seven years after the date of your purchase, which is compliant with HMRC requirements other statutory authorities. After which time all personal identifiable information on these records will be anonymised.
11.6 Customer Feedback Surveys
Any personal identifiable information submitted when providing a customer review through our customer feedback survey company and which is limited to full name and email, will be deleted after 12 months.
Any written customer reviews that the customer has given permission to be published on the BLUE BEAR website will remain on the BLUE BEAR website unless the individual requests they are removed. The customer can do this by emailing [email protected] with their details and the review will be deleted.
11.7 Live Chat
Your name, email address and the transcript of the conversation will be held for 12 months and then be deleted.
11.8 Retention for a debtor
A debtor is one who has an outstanding payment with BLUE BEAR and who may no longer be able to be contacted. We will retain the personal data of any debtor for 7 years.
11.9 Retention in case of legal claims
We may retain your personal data for the period in which you might legally bring claims against us (in the UK this means we will retain it for 7 years) if and to the extent this is relevant.
11.10 Retention in case of insurance claims
We may retain your personal data for the period in which you might legally bring claims against us (in the UK this means we will retain it for 7 years) if and to the extent this is relevant.
11.11 Retention in accordance with legal and regulatory requirements
We will consider whether we need to retain your personal data after the period of retention in the case of claims (above) because of a legal or regulatory requirement. Some or all of these criteria may be relevant to retention of your personal data collected in connection with our products and services.
11.13 Retention of customers who have opted in to receive marketing communications
We will delete all personal details including email addresses of customers who have opted in to receive ongoing marketing communications from BLUE BEAR after 10 years from the date they opted in, and who haven’t unsubscribed from such communications in that time frame.
If you would like further information about our data retention practices please contact us.
12. What are my rights in relation to the personal data processed by BLUE BEAR?
You have the right to request access to the personal data BLUE BEAR holds about you. In order for us to comply with such a request, you will have to submit a Subject Access Request (SAR). We may require you to prove your identity with two pieces of approved identification. We will respond to a SAR within 30 days.
As well as the right to access the personal data BLUE BEAR holds about you, you have a number of other rights in respect of your personal data under the data protection laws. These may include (as relevant):
- the right to rectification, including to require us to correct inaccurate personal data;
- the right to request restriction of processing concerning you or to object to processing of your personal data;
- the right to request the erasure of your personal data where it is no longer necessary for us to retain it;
- the right to data portability including to obtain personal data in a commonly used machine readable format in certain circumstances such as where our processing of it is based on a consent;
- the right to object to automated decision making including profiling (if any) that has a legal or significant effect on you as an individual;
- where you have an option to provide us with your personal data or not in connection with your use of our Website or in connection with any of our products or services, you have the right to be informed about the possible consequences of not giving it to us; and
- the right to withdraw your consent to any processing for which you have previously given that consent.
Should you wish to exercise any of your rights (or if you have questions about your rights), please address your request and/or questions to us [email protected]
We have installed CCTV on all of our storage premises covering all areas. This is for the purpose of staff and public safety, building security, crime prevention/detection & for the security of our premises and our customers’ possessions. We consider CCTV is a key selling point for self storage.
We have CCTV monitors on all our sites which relay CCTV feeds. These monitors can be viewed by BLUE BEAR site employees.
In accordance with the ICO CCTV Guide, we ensure the CCTV pictures are appropriately zoomed out so that individuals cannot be identified.
CCTV privacy notices are on display all around our sites and on perimeter fencing and gates alerting people to the fact that CCTV is in use throughout the site.
Images captured on CCTV will not be kept for longer than necessary, typically this is up to 60 days and is then automatically overwritten. However on occasions there may be a need to keep images for longer, for example where an incident is being investigated.
CCTV footage is stored within BLUE BEAR services and can be viewed/reviewed by the following:-
- Site staff may view CCTV only within their own site location
- Specified head office staff may access CCTV for any site
- Our CCTV maintenance company
You have the right to view CCTV images of yourself which can be actioned by placing a Subject Access Request (SAR) directly with the site. We will only disclose images to other authorised bodies for the purposes stated above i.e. to aid a police investigation.
We operate CCTV and disclose in accordance with the codes of practice issued by the Information Commissioner and the Home Office.
14. Cookies Policy – Information the BLUE BEAR website collects from you
What is a cookie?
A cookie is a small amount of data, which often includes a unique identifier that is sent to your computer or mobile phone (referred to here as a “device”) browser from a website’s computer and is stored on your device’s hard drive. Each website can send its own cookie to your browser if your browser’s preferences allow it, but (to protect your privacy) your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other sites. Many sites do this whenever a user visits their website in order to track online traffic flows.
15. Do I have a right to complain about the processing of my personal data by BLUE BEAR
Yes. If you would like to ask any questions or raise any concerns with the way in which BLUE BEAR processes your personal data or complies with your legal rights under the data protection laws, please feel free to contact us in the first instance, using the contact details set out below.
Notwithstanding the above and without prejudice to any other administrative or judicial remedy you might have, you have the right to lodge a complaint with the UK’s Information Commissioner’s Office directly, if you consider that we have infringed applicable data protection laws when processing your personal data. The Information Commissioner is the UK supervisory authority for data protection issues and may be contacted at https://ico.org.uk or telephone 0303 123 1113.