This notice describes how we collect and use personal data about you, in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act (2018) and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (‘Data Protection Legislation’). Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
Creative Company (“we”, “us”, “our” and “ours”) is a creative marketing company. Our registered office is at:
50 Liverpool Street
London EC2M 7PY
For the purpose of the Data Protection Legislation and this notice, we are the ‘data controller’. This means that we are responsible for deciding how we hold and use personal data about you. We are required under the Data Protection Legislation to notify you of the information contained in this privacy notice.
We have appointed a Data Protection Lead. Our Data Protection Lead is our Data Protection Point of Contact and is responsible for assisting with enquiries about this privacy notice or our treatment of your personal data. Should you wish to contact our Data Protection Point of Contact, you can do so using the contact details noted at paragraph 12 (Contact Us), below.
How we may collect your personal data
We may obtain personal data about you, for example, when:
- you request a proposal from us in respect of the services we provide
- you or your employer or our clients engage us to deliver our services and also during the provision of those services
- you contact us by email, telephone, post, our website or social media (for example when you have a query about our services), or
- from third parties and publicly available resources (for example, from your employer or Companies House).
The kind of information we hold about you
The information we hold about you may include the following:
- your personal details (such as your name and address, telephone number)
- details of contact we have had with you about the provision, or the proposed provision, of our services
- details of any services you have received from us
- our correspondence and communications with you
- information about any complaints and enquiries you make to us
- information from research, surveys, and marketing activities
- pseudonymised information about the usage of our website and social media services such as session tracking cookies
- information we receive from other sources, such as publicly available information, the information provided by third-party companies and agencies.
How we use the personal data we hold about you
We may process your personal data for purposes necessary for the performance of our contract with you and to comply with our legal obligations.
We may process your personal data for the purposes necessary for the performance of our contract with our clients. This may include processing your personal data where you are an employee, subcontractor, supplier or customer.
We may process your personal data for our legitimate interests provided that those interests do not override any of your interests, rights and freedoms which require the protection of personal data. This includes processing for marketing, business development, statistical and management purposes.
We may process your personal data for specific additional purposes with your consent, and in these limited circumstances where your consent is required for the processing of your personal data then you have the right to withdraw your consent to the processing for such specific purposes.
Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.
Situations in which we will use your personal data
We may use your personal data to:
- carry out our obligations arising from any agreements entered into between you or our clients and us (which will most usually be for the provision of our services)
- carry out our obligations arising from any agreements entered into between our clients and us (which will most often be for the provision of our services) where you may be a subcontractor, supplier or customer of our client
- provide you with information related to our services and our events and activities that you request from us or which we feel may interest you, provided you have consented to be contacted for such purposes
- seek your thoughts and opinions on the services we provide, and
- notify you about any changes to our services.
In some circumstances, we may anonymise or pseudonymise the personal data so that it can no longer be associated with you, in which case we may use it without further notice to you.
If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered into with you. Alternatively, we may be unable to comply with our legal or regulatory obligations.
We may also process your personal data without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.
We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected.
When assessing what retention period is appropriate for your personal data, we take into consideration:
- the requirements of our business and the services provided
- any statutory or legal obligations
- the purposes for which we originally collected the personal data
- the lawful grounds on which we based our processing
- the types of personal information we have collected
- the amount and categories of your personal data, and
- whether the purpose of the processing could reasonably be fulfilled by other means.
Change of purpose
Where we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal data where that reason is compatible with the original purpose.
Should it be necessary to use your personal data for a new purpose, we will notify you and communicate the legal basis, which allows us to do so before starting any further processing.
— Why might you share my personal data with third parties?
We will share your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so.
— Which third-party service providers process my personal data?
“Third parties” includes third-party service providers and other entities members of our firm’s professional networks. The following activities are carried out by third-party service providers: IT and cloud services, professional advisory services, administration services, marketing services, insurance and banking services.
All of our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.
— What about other third parties?
We may share your personal data with other third parties, for example, in the context of contracts, compliance, marketing or professional services. We may also need to share your personal data with a regulator or to otherwise comply with the law.
Transferring personal data outside the European Economic Area (EEA)
Personal information in the EEA (which means all the EU countries plus Norway, Iceland and Liechtenstein) (“EEA”) is protected by data protection laws, but other countries do not necessarily protect your personal information in the same way.
We may use service providers based outside of the EEA to help us provide our services to you, and this means that we may transfer your information to service providers outside the EEA to deliver our services to you. For example, we utilise cloud services and online storage solutions, parts of this service may, for example, be hosted on servers located within the United States or managed and supported from outside the EEA to for example to ensure service availability and security around the clock.
We take steps to ensure that where your information is transferred outside of the EEA by our service providers and hosting providers, appropriate measures and controls in place to protect that information in accordance with applicable data protection laws and regulations. This may be that there is an adequacy decision by the European Commission in relation to these countries and therefore they will be deemed to provide an adequate level of protection for your personal information. In each case, such transfers are made in accordance with the requirements of Regulations (EU) 2016/679 (the General Data Protection Regulations or “GDPR”) and may be based on the use of the European Commission’s Standard Model Clauses for transfers of personal data outside the EEA.
By using our website, products or services or by interacting with us in the ways described in this Privacy Notice, you consent to the transfer of your information outside the EEA in the circumstances set out in this Privacy Notice where necessary for the delivery of our services. If you do not want your information to be transferred outside the EEA, you may not be able to use all our services.
Should you require further information about these protective measures, or confirmation as to if the services we deliver to you involve such transfers, please contact us using the contact details outlined in the section below.
We have put in place commercially reasonable and appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Also, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Rights of access, correction, erasure and restriction
Under certain circumstances, by law, you have the right to:
- Request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully
- Request correction of the personal data that we hold about you
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below)
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party), and there is something about your particular situation which makes you want to object to processing on this basis. You also have the right to object where we are processing your personal information for direct marketing purposes
- Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example, if you want us to establish its accuracy or the reason for processing it
- Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible.
If you want to exercise any of the above rights, please email our data protection point of contact email@example.com
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose (for example, in relation to direct marketing that you have indicated you would like to receive from us), you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email our data protection point of contact firstname.lastname@example.org
Once we have received notification that you have withdrawn your consent, we will no longer process your personal information (personal data) for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Changes to this notice
We may make changes to this Privacy Notice from time to time. Any changes we may make to our privacy notice in the future will be provided to you by being updated on our website at www.thisiscreative.co, which will always contain the latest version.
This privacy notice was last updated on June 17, 2019.
If you have any questions regarding this notice or if you would like to speak to us about how we process your personal data, please email our Data Point of Contact at email@example.com or telephone our Data Protection Point of Contact on 0800 678 5634.
You also have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, at any time. The ICO’scontact details are as follows:
Information Commissioner’s Office Wycliffe House
Cheshire SK9 5AF
Telephone: 0303 123 1113