Last updated: 17/05/2018
1. Who we are
We are a company called Createful Limited, incorporated in England and Wales and registered with Companies House. Our registered office is at 3 Durrant Road, Bournemouth BH2 6NE. Our contact address is 99 Holdenhurst Road, Bournemouth BH8 8DY.
In this notice, references to ‘we’ or ‘us’ means Createful. A reference to ‘you’ or ‘your’ means clients, prospective clients, job applicants, work placement applicants and general website visitors.
2. What information we collect
The type of business relationship you have with us will determine the specific information we will need to collect from you. The records will be created during the course of us providing a service to you.
This is typically the information you voluntarily provide to us which is necessary to perform the service that you are accessing (whether by telephone, online or in person). Depending on the type of service accessed, the information requested may include your name, your email address, your postal address, your telephone number or employment details. If you are applying for a job, work placement, internship or work experience you will also need to provide your CV (and relevant information in it) or details of your education or your qualifications transcripts.
Sensitive personal information
Our website does not collect sensitive personal information. Sensitive personal information includes information relating to:
- your ethnic origin;
- your political opinions;
- your religious beliefs;
- whether you belong to a trade union;
- your physical or mental health or condition;
- your sexual life; and
- whether you have committed a criminal offence.
3. How we collect information
To the extent permissible under applicable data protection and privacy laws, we collect information about you and any other party whose details you provide to us when you:
- register with us, fill out enquiry form, apply for a job, internship or work placement. We also collect information when you send us feedback, post comments to our website, complete customer surveys or participate in competitions or participate in any other interactive areas that appear on our website. This may contain all or any of the information described in Section 2 above;
- interact with us using social media; and
- contact us offline, for example by telephone, fax, SMS, email or post.
We will also collect your information where you only partially complete and/or abandon any information inputted into our website and/or other online forms and may use this information to contact you to remind you to complete any outstanding information and/or for marketing and after-sales purposes.
Our websites may contain technology that enables us to:
- obtain information relating to any technical errors or other issues with our website;
- collect information about how you and users use the functions of the features of our website; and
- gather statistical information about the operating system and environment from which you access our services.
You can manage your privacy settings within your web browser such as Google Chrome or Firefox at any time by following their instructions.
4. How we use your information
We limit the collection of personal information to what is necessary to provide you with high quality services, to support your specific needs and requests, and to meet our legitimate business interests in connection with the services. Below we have highlighted the reasons for the collection of your information:
- to respond adequately to your requests for services or information;
- to provide a safe, healthy, and successful environment for our staff, volunteers and employees;
- to provide resource material/information regarding our services and areas of interest to our clients;
- to aid in the administration of our services to our clients;
- to comply with laws, and government regulations/standards;
- to support our business purposes and functions related to the services, such as visual design, development, communication, administration, and record-keeping;
- to fulfil tax, reporting, and other financial requirements and obligations;
- to compare information for accuracy and to verify it with third parties;
- to administer employee payroll, benefits, tax/regulatory compliance and other record keeping and administration requirements;
- to consider applications for employment, volunteer positions and internships;
- to manage our relationship with you (for example, customer services and support activities);
- to monitor, measure, improve and protect our content, website, applications and services and provide an enhanced, personal, user experience for you;
- to undertake internal testing of our website, applications, systems and services to test and improve their security and performance. In these circumstances, we would anonymise any information used for such testing purposes;
- to contact you to see if you would like to take part in our customer research (for example, feedback on your use of our products and services);
- to deliver targeted advertising, marketing or information to you which may be useful to you, based on your use of our services see ‘Marketing’ section below; and
- to deliver joint content and services with third parties with whom you have a separate relationship (for example, social media providers).
We may monitor and record our communications with you, including e-mails and phone conversations. Information which we collect may then be used for training purposes, quality assurance, to record details about our website and services you order from us or ask us about.
5. What are our lawful means of collecting data
6. Your information and your rights
When you give us your information or when we process your data, you have the following rights under applicable laws:
- the right to be told how we use your information and obtain access to your information;
- the right to have your information rectified or erased or place restrictions on processing of your information;
- the right to object to the processing of your information e.g. for direct marketing purposes;
- the right to have any information you provided to us returned to you in a structured, commonly used and machine-readable format, or sent directly to another company, where technically feasible (“data portability”);
- where the processing of your information is based on your consent, you have the right to withdraw that consent at any time and in the same manner used to gain you consent;
- the right to object to any decisions based on the automated processing of your personal data, including profiling; and
- the right to lodge a complaint with the supervisory authority responsible for data protection matters. In the UK, this would be with the Information Commissioner’s Office.
If you request a copy of your information in a ‘Subject Access Request’ you may be required to pay a statutory fee depending on the volume of information you are requesting.
If we hold any information about you which is incorrect or if there are any changes to your details, please let us know so that we can keep our records accurate and up to date.
Please remember that if you withdraw your consent to the use of your personal information for purposes set out in this policy, we may not be able to provide you with access to all or parts of our website or services.
7. Sharing your information
We may share your information with:
- our software service providers and agents (including their sub-contractors) which process information on our behalf (e.g. internet service and cloud based platform providers, payment processing providers and those organisations we engage to help us send communications to you such as MailChimp), so that they may help us to provide you with the services you have requested or which we believe is of interest to you;
- third parties where you have a relationship with that third party and you have consented to us sending information (for example social media sites or other third party application providers);
- regulators to meet our legal and regulatory obligations;
- law enforcement agencies so that they may detect or prevent crime or prosecute offenders;
- any third party in the context of actual or threatened legal proceedings, provided we can do so lawfully (for example in response to a court order);
- our own professional legal advisors, accountants and auditors for the purpose of seeking professional advice or to meet our audit responsibilities;
- another organisation if we sell or buy (or negotiate to sell or buy) any business or assets;
- another organisation to whom we may transfer our agreement with you; and
- Government departments where reporting is mandatory under applicable law.
We may share non-personally identifiable information about the use of our website, products or services publicly or with third parties but this will not include information that can be used to identify you.
8. Social media and other websites
If you follow a link from our website to another site or service, this notice will no longer apply. We are not responsible for the information handling practices of third party sites or services and we encourage you to read the privacy notices appearing on those sites or services.
Our websites may enable you to share information with social media sites or to connect your social media account. Those social media sites may automatically provide us with access to certain personal information retained by them about you (for example any content you have viewed). You should be able to manage your privacy settings from within your own third party social media account(s) to manage what personal information you enable us to access from that account.
From time to time, we may use your information to contact you with details about our products and services which we feel may be of interest or benefit to you. We may also share your information with our group companies and carefully selected affiliates third parties so that they (or we) may contact you with information about products or services which we feel may be of interest or benefit to you.
We may wish to contact you for this purpose by telephone, post, SMS or email. You have the right at any time to object and stop us from contacting you for marketing purposes. You may also request at any time that we do not share your information with third parties referred to in this paragraph.
If you wish to exercise these rights you can do so by contacting us via email to email@example.com. Or you can call or write to us using the contact details provided on this website. You can also unsubscribe from any marketing emails using the links provided in the emails we send to you.
10. Internet service providers and search engines
Your information may be inadvertently shared with third party internet service providers and search engines such as Google and Bing, as a consequence of our use of those platforms to run our website. You can control your privacy setting on the relevant provider’s platform and you should consult the third party’s help/support centre for more information.
11. How long we keep your information
We will retain your personal information for the duration of our business or contractual relationship and afterwards for as long as is necessary and relevant for our legitimate business purposes, or in accordance with the laws which are applicable to our service industry. Where we no longer need your personal information, we will dispose of it in a secure manner.
12. Security and storage of information
although some information may remain on electronic storage data systems at the group company where originally provided, the electronic personal information we collect may also be stored at in the cloud or at dedicated hosting centres in the United Kingdom. These hosting centres are also subject to applicable data protection laws and standards.
the hardcopy of personal information we collect will be stored securely and in accordance to applicable industry standards and safeguards.
We will keep your information secure by taking appropriate technical and organisational measures against unauthorised or unlawful processing and against accidental loss, destruction or damage. We will do our best to protect your personal information but we cannot guarantee the security of your information which is transmitted to our website or services or to other website, applications and services via the internet or similar connection.
If you believe your information has been compromised, please contact us at firstname.lastname@example.org. Or Contact the Information Commissioner’s Office directly.
13. Google Analytics and ‘cookies’
Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyse how users use the websites. The information generated by the cookie about your use of the websites (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the websites, report on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google.
For further information on cookies generally visit www.aboutcookies.org or www.allaboutcookies.org.
14. Transfers outside of the European Union and European Economic Area
Personal information in the European Union is protected by data protection laws but other countries do not necessarily protect your personal information in the same way.
Our website and some of our services or parts of them may also be hosted in the outside of the European Union or EEA and this means that we may transfer any information which is submitted by you through the website outside the European Union and EEA to other territories.
We may use service providers based outside of the European Union or EEA to help us provide our website and services to you (for example, platform who help us execute mass communication). We take steps to ensure that where your information is transferred outside of the European Union or EEA by our service providers and hosting providers, appropriate measures and controls are in place to protect that information in accordance with the requirements of General Data Protection Regulations 2016/679.
By using our website, products or services or by interacting with us in the ways described in this policy, you consent to the transfer of your information outside the European Union or EEA in the circumstances set out in this policy. If you do not want your information to be transferred outside the European Union or EEA please contact us to let us know your wishes.
15. Changes to our privacy notice
We may change our Privacy Notice from time to time. However we will not reduce your rights under this Privacy Notice. We will always update this Privacy Notice on our website, so please try to read it when you visit the website (the ‘last updated’ reference tells you when we last updated our Privacy Notice).