PRIVACY POLICY

 
 

INTRODUCTION  

The Craftory Limited respects your privacy and is committed to protecting your personal data. This privacy notice will tell you how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

1.  IMPORTANT INFORMATION AND WHO WE ARE  

Purpose of this privacy notice

This privacy notice aims to give you information on how The Craftory Limited collects and processes your personal data through your use of this website, including any data you may provide through this website when you connect with us and tell us about you and your company.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller 

The Craftory Limited (“we”, “us” or “our”) is the controller and is responsible for your personal data.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below. 

Contact details

The Craftory Limited
Atkins Dondo
Email address:atkins@thecraftory.io
Postal address: The Craftory, Egyptian House, 170 Piccadilly, London W1J 9EJ
Telephone number: +44 (0)207 491 7103

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. 

Changes to the privacy notice and your duty to inform us of changes  

This version was last updated in July 2018.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2.  THE DATA WE COLLECT ABOUT YOU  

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

  • Contact Data includes home address, delivery address, email address and telephone numbers.

  • Financial Data includes bank account and payment card details.

  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

  • Profile Data includes your username and password, your interests, preferences, feedback and any survey responses.

  • Usage Data includes information about how you use our website.

  • Communications Data includes your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have with you or are trying to enter into with you

3.  HOW IS YOUR PERSONAL DATA COLLECTED?  

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

    • request details about our company and what we do; or

    • give us some feedback.

  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.

4.  HOW WE USE YOUR PERSONAL DATA  

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

  • Where we need to comply with a legal or regulatory obligation. 

Generally, we do not rely on consent as a legal basis for processing your personal data.

Purposes for which we will use your personal data 

We will process your personal data:

1)     As necessary for the performance of our contract with you when providing you with services:

a)     To manage and perform the contract; and

b)     To update our records.

2)     As necessary for our own legitimate interests:

a)     For good governance, accounting, and managing and auditing our business operations;

b)     To monitor emails, calls, other communications and activities; and

c)     To send you marketing communications. 

3)     As necessary to comply with a legal obligation:

a)     When you exercise your rights under data protection law and make requests;

b)     For compliance with legal and regulatory requirements and related disclosures;

c)     For establishment and defence of legal rights;

d)     For activities relating to the prevention, detection and investigation of crime;

e)     To verify your identity, make fraud prevention and anti-money laundering checks; and

f)      To monitor emails, calls, other communications and activities relating to your company.

4)     Based on your consent:

a)     When you request the disclosure of your personal data to other people or organisations;

b)     If we process any special categories of personal data at your request (e.g. racial or ethnic origin, data concerning health, religious or philosophical beliefs); and 

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.   

Contact list

We may use your Identity, Contact, Technical, Usage and Profile Data to maintain a list of parties interested in our company. We may also use this information in the future to contact you in order to explore what we can do for you.

Opting out

If you do not want us to contact you in the future, you can specifically ask us to remove your details from our contact list at any time by emailing us.

Where you do so, this will not apply to personal data provided to us as a result of any other transaction such as the provision of services under a contract.

Cookies  

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please click here.

 Change of purpose 

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5.  DISCLOSURES OF YOUR PERSONAL DATA  

We may share your personal data with third parties as set out below:

  • Sub-contractors and other persons who help us to provide services to you;

  • Our legal and professional advisers, including auditors, lawyers and insurers;

  • Fraud prevention agencies, personal search agencies;

  • Government bodies and agencies in the UK (e.g. tax authorities, the Information Commissioner’s Office);

  • Courts, to comply with legal requirements and for the administration of justice;

  • Other parties where necessary to protect the security and integrity of our business operations; and

  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6.  INTERNATIONAL TRANSFERS  

We may transfer your data outside of the European Economic Area (EEA) in instances where our employees, service providers or advisers are based outside of the EEA. Whenever we transfer your personal data to such parties we will try to ensure that your personal data is provided a similar degree of protection. Please contact us if you would like further information about this.   

7.  DATA SECURITY  

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, 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 and are subject to a duty of confidentiality. 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8.  DATA RETENTION  

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. The minimum period is 1 week. The maximum period is 6 years from the expiry or termination of any long-term contract The Craftory Ltd may enter into with you.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9.  YOUR LEGAL RIGHTS   

You have the right to:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
     

  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

  • 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 to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
     

  • 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 ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
     

  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
     

  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to contact you to explore any possible opportunities that we can provide you with. We will advise you if this is the case at the time you withdraw your consent. If you wish to exercise any of the rights set out above, please contact our DPO. 

No fee usually required

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 is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you 

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond  

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Last updated: 15 January 2019