Creative Castle Services Ltd understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, www.thecreativecastle.co.uk (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with Our obligations and your rights under the law.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
- “Account” means an account required to 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 13, below; and
- “Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
2. Information About Us
Our Site is owned and operated by Creative Castle Services Ltd , a Limited Company.
- Registered in England under company number 11065294.
- Registered address: 119 Greenbank Road, Watford, United Kingdom, WD17 4JL.
- Main trading address: 119 Greenbank Road, Watford, United Kingdom, WD17 4JL.
- Data Protection Officer: Claire Huggins
- Email address: email@example.com
- Telephone number: +44 (0)204 513 97703
- Postal address: The Creative Castle, 119 Greenbank Road, Watford, United Kingdom, WD17 4JL.
3. What Does This Policy Cover?
4. What Is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “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.
5. What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
- b) The right to access the personal data We hold about you. Part 13 will tell you how to do this.
- c) 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 12 to find out more.
- d) 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 hold. Please contact Us using the details in Part 14 to find out more.
- e) The right to restrict (i.e. prevent) the processing of your personal data.
- f) The right to object to Us using your personal data for a particular purpose or purposes.
- g) The right to withdraw consent. This means that, if We are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
- h) The right to data portability. This means that, if you have provided personal data to us directly, We are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask Us for a copy of that personal data to re-use with another service or business in many cases.
- i) Rights relating to automated decision-making and profiling. [We do not use your personal data in this way].
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 14.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
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. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 14.
6. What Data Do You Collect and How?
Depending upon your use of our sites, we may collect some or all of the following personal data:
- Date of birth
- Business/company name
- Job title
- Contact information such as email addresses and telephone numbers
- Demographic information such as post code, preferences and interests
- IP address
- Web browser type and version
- Operating system
7. How Do You Use My Personal Data?
Under the Data Protection Legislation, We must always have a lawful basis for using personal data. The following table describes how We [will] OR [may] use your personal data, and our lawful bases for doing so:
7.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 8, below.
7.2 Our use of your personal data will always have a lawful basis, either because it is necessary for our performance of a contract with you, because you have consented to our use of your personal data (e.g. by subscribing to emails), or because it is in our legitimate interests. Specifically, we may use your data for the following purposes:
7.2.1 Providing and managing your Account
7.2.2 Providing and managing your access to Our Site
7.2.3 Personalising and tailoring your experience on Our Site
7.2.4 Supplying Our Products and services to you
7.2.5 Personalising and tailoring Our Products for you
7.2.6 Replying to emails from you
7.2.7 Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time)
7.2.8 Market research
7.2.9 Analysing your use of Our Site to enable us to continually improve Our Sites and your user experience
7.3 With your permission and/or where permitted by law, we may also use your data for marketing purposes which may include contacting you by email telephone, text message or post with information, news and offers on our products. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
7.4 You have the right to withdraw your consent to us using your personal data at any time, and to request that we delete it.
7.5 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. We will retain Customer Data in accordance with a Customer’s instructions, including any applicable terms in the Customer Agreement and as required by applicable law. This may include keeping your Other Information after you have deactivated your account for the period of time needed for Contagious to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.
8. How and Where Do You Store Data?
8.1 We only keep your personal data for as long as We need to in order to use it as described above in section 7, and/or for as long as We have your permission to keep it.
8.2 Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). If We do store data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR.
8.3 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
9. Do You Share My Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject to the following exception[s].
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.
10. How Can I Control My Personal Data?
10.1 In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict Our use of your personal data. In particular, 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 OR, at the point of providing your details [and by managing your Account]).
10.2 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.
11. 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.]
12. 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 within 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.
13. Cookies Policy
13.2 A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
13.3 We use the following cookies:
a) Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
b) Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
c) Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
d) Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
13.4 You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Site.
13.5 Except for essential cookies, all cookies have a pre-designated lifespan after which they will expire.
14. 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 Claire Huggins):
- Email address: firstname.lastname@example.org.
- Telephone number: +44 (0)204 513 97703.
- Postal Address: The Creative Castle, 119 Greenbank Road, Watford, United Kingdom, WD17 4JL.
We may change this Privacy Notice 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.