1. Information about us
Limited company registered in England under company number 09240956.
Registered address: Kemp House, 152 City Road, London EC1V 2NX.
Address: 21A Noel Street, Soho, London, W1F 8GR.
VAT number: 196611582.
Data Protection Officer: Randal Pinto.
Email address: firstname.lastname@example.org.
Telephone number: +44 (0) 2081440852.
Postal Address: c/o Data Protection Officer, 21A Noel Street, Soho, London, W1F 8GR
2. What does this notice cover?
3. What is personal data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) 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.
The personal data that we use is set out in Part 5, below.
4. What are my rights?
Under the GDPR, if you are a resident in the EEA, you have the following rights, which we will always work to uphold:
- The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 13.
- The right to access the personal data we hold about you. Part 10 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 13 to find out more.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 13 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes
- The right to data portability. This means that you can ask us for a copy of your personal data held by us to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
5. What personal data you collect?
We may collect some or all of the following personal data (this may vary according to your relationship with us):
- Email address;
- Telephone number;
- Business name;
- Job title;
- Payment information;
- Location information;
- Information provided by third parties;
- Information about how you access and use our services (e.g.: pages visited, referral website);
- Information about your device (e.g.: anonymized IP address, type of device);
- Comments and opinions that you express when you contact us via email, phone or chat.
If you decide that you wish to apply for a job with us, you may submit your contact information and your resume online. We will collect the information you choose to provide on your resume, such as your education and employment experience.
6. How do you use my personal data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data will be used for the following purposes:
- Providing and managing your account (legal basis: contractual).
- Supplying our products and services to you. Your personal details are required in order for us to enter into a contract with you (legal basis: contractual).
- Personalising, improving and tailoring our products and services for you (legal basis: legitimate interests).
- Communicating with you. This may include responding to emails or calls from you (legal basis: contractual and legitimate interests).
- Supplying you with information by email or post that you have opted-in to. You may unsubscribe or opt-out at any time by updating your communication preferences in the user profile page of your product or by clicking the unsubscribe link in our emails to you (legal basis: legitimate interests).
- Finding and preventing fraud, and responding to trust and safety issues that may arise (legal basis: legitimate interests).
- For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency (legal basis: legitimate interests and compliance with legal obligations).
- For other purposes for which we provide specific notice at the time the information is collected (legal basis: contractual and legitimate interests).
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 or telephone or post with information, news, and offers on our products and services. We will not send you any unlawful marketing or spam. We work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you have the opportunity to opt-out.
7. How long will you keep my personal data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
- We will use and store your personal data for as long as it is necessary to provide our service to you and for the purpose of satisfying any legal, accounting or reporting requirements. Thereafter we will only keep data in anonymised form so that it can no longer be associated with you to help improve our products and services;
- If you are not a customer and we have your personal data for the purpose of communicating with you we will use it and store it until either you let us know that you no longer want to receive communications from us or for a period of up to 24 months.
8. How and where do you store or transfer my personal data?
We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR including:
- Having a GDPR-compatible Data Processing Addendum with sub-processors in third countries;
- Making sure that such sub-processors have adequate security procedures in place.
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:
- Encrypting your data while it is in transit;
- Where possible, encrypting your data when it is stored;
- Yearly independent reviews of our security processes and procedures via our ISO27001 certification.
However, as our products and services are hosted electronically, we can make no guarantees as to the security or privacy of your information.
9. Do you share my personal data?
We may sometimes contract with the following third parties to supply products and services to you on our behalf. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold. You can check the list of sub processors here.
If any of your personal data is required by a third party, as described above, 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.
We may sometimes contract with third parties (as described above) that are located outside of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). If any personal data is transferred to a third party outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 8.
We use analytics services such as Google Analytics to collect and process certain analytics data. These services may also collect information about your use of other websites, apps, and online resources. You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/, and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
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.
We may disclose and transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our business or assets.
We may also disclose information from or about you or your devices with your permission.
10. 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”.
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 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 we receive your request. You will be kept fully informed of our progress.
11. Third parties
12. Children's privacy
13. How do I 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 attention of the Data Protection Officer):
Email address: email@example.com.
Telephone number: +44 (0) 2081440852.
Postal Address: 21A Noel Street, Soho, London, W1F 8GR.
Any changes will be made available here and where applicable we might also notify you via email and/or in our products.