1.1 We are committed to safeguarding the privacy of individuals ("you", "your") whose personal data we collect and use. In this Privacy Statement, we explain how we handle your personal data. For example, what personal data we collect and how, or that you provide to us, what we do with it and who we share it with. It also describes your privacy rights and controls such as your choices regarding use, access and correction of your personal data.
1.2 Our Privacy Statement is part of, and is subject to, our Cookies Policy and our Website Terms. By visiting you are accepting and consenting to the practices described in this policy.
1.3 For the purpose of the Data Protection Act 1998 (the "Act"), the data controller is Red Badger of 4th Floor, 2 Old Street Yard, London, England, EC1Y 8AF
02 Your privacy rights
2.1 We have summarised below your privacy rights. Some of these rights are complex, and not all of the details have been included in our summaries below. For this reason, you should read the applicable data protection laws and guidance from the UK Information Commissioner for a fuller explanation of these rights. You can do so by using this link https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
2.2 You may exercise any of your rights below in relation to your personal data by contacting us at: email@example.com.
2.3 Your principal rights under the applicable data protection laws are:
- the right to access;
- the right to rectification;
- the right to erasure;
- the right to restrict processing;
- the right to object to processing;
- the right to data portability;
- the right to complain to the UK Information Commissioner; and
- the right to withdraw consent.
2.4 Right to access: You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
2.5 Right to rectification: You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed. You can ask us to make any necessary changes to ensure that your personal data is accurate and kept up to date.
2.6 Right to erasure: In some circumstances, you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; the processing is for direct marketing purposes, and the personal data has been unlawfully processed. However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary for: exercising the right of freedom of expression and information; compliance with a legal obligation; for the establishment, exercise or defence of legal claims. The consequences of erasing your personal data are, for example, that you will be unable to access some content on our Website and will be excluded from marketing communication communications including (for example) newsletters, event information, blogs etc.
2.7 Right to restrict processing: In some circumstances, you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful, but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another individual or legal person; or for reasons of important public interest.
2.8 Right to object to processing: You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
2.9 Right to object to processing (direct marketing): You have the right to object to our processing of your personal data for direct marketing purposes (including, for example, profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose. You may exercise this right at any time by (a) hitting the unsubscribe button in the email footer of the newsletter we send you, or (b) by contacting our Data Compliance Manager in writing using the following contact details firstname.lastname@example.org.
2.10 Right to object to processing (scientific, historical research or statistics): You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
2.11 Right to data portability: To the extent that the legal basis for our processing of your personal data is consent, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
2.12 Right to complain to the UK Information Commissioner: If you consider that our processing of your personal data infringes the applicable data protection laws, you have a legal right to lodge a complaint with the UK Information Commissioner (www.ico.org.uk) which is the UK data protection regulatory body.
2.13 Right to withdraw consent: To the extent that the legal basis for our processing of your personal data is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
03 Changes to the Privacy Statement
3.2 If you continue accessing and/or using of our Website, receiving our communications, contacting us, and/or signing up etc. this will constitute acceptance of the revised Privacy Statement.
04 What personal data we collect
4.1 We use many different kinds of personal data. They are grouped together as in the table below. The groups are all listed here so that you can see what we may know about you. We don't use all this personal data in the same way. Some of it is useful for marketing, or for providing services to you.
This is data on how you use our Website and may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and Website navigation paths, as well as information about the timing, frequency and pattern of your use of our Websites.
This may include billing data, your name and contact details such as your email address contained in/relating to services we provide (if you enquired to hire us or you decided to hire us).
This may include personal data contained in or relating to any communication that you send to us or that we use to communicate with you.
This may include personal data you provide to us if you sign up to receive our newsletters and choose whether you wish to receive promotional communications (e.g. offers, invitations to promotional activities such as events, webinars etc.) from us by email, post, telephone and social media.
Cookies & similar technology data
This includes personal data that we obtain about you through cookies and similar technologies. For more information, see our Cookies Policy.
This may include your name and contact details and some of the other personal data set out in this table e.g. Third-Party data, registration data.
This may include information you provide to register for events, webinars, surveys, etc. and may include your name and contact details e.g. an email address.
This may include your name and contact details and any other additional personal information as well as a CV.
This may include your name and contact details we obtain from third parties such as third-party services providers, lead generation companies, social media etc.
This is personal data other than the ones set out in the table above.
05 How we collect your personal data
We collect your personal data from various sources. These are as follows:
5.1 Personal data you provide us about you: We collect and process the following data about you:
- This is information about you that you give us by filling in a form on our site https://sharethyme.co.uk ("our site") or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register as someone who is interested in becoming a beta tester ' of services we may offer in the future and when you report a problem with our site. The information you give us may include all names, address, e-mail address, and date of birth.
5.2 Data we collect about you automatically:
With regard to each of your visits to our site we will automatically collect the following information:
- Technical information
- Information about your visit
5.3 Data we collect about you from others: We also collect personal data about you from others such as (for example):
- Information we receive from other sources. This is information we receive about you if you use any of the other websites we operate or the other goods/services we provide. We are working closely with third parties (including, for example, business partners, trusted clients, third party vendors and service providers). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.
06 How we use your personal data
6.1 Below, you find a list of the ways that we may use your data:
Information you give to us. We will use this information:
to ascertain market demand for the goods/services featured on our site and to analyse and extrapolate your requirements and likely desire to receive goods/services and the cost that they should be offered at;
to provide you with information about goods and services that may become available from us in the future or that you request from us;
to provide you with information about other goods and services we offer that are similar to those that you have already enquired about;
to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. We will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which you have previously enquired about. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data (the registration form);
to notify you about changes to the goods/services featured on the site; and
to ensure that content from our site is presented in the most effective manner for you and for your computer.
Information we collect about you. We will use this information:
1. to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of our service, when you choose to do so;
- as part of our efforts to keep our site safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
2. Information we receive from other sources. We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
07 Providing your personal data to others
7.1 You agree that we have the right to share your personal information with:
- Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
We will disclose your personal information to third parties:
In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
If Red Badger or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
08 International transfers of your personal data
8.1 We may transfer your personal data to countries outside the EEA. This may happen as follows:
Our Website is hosted in eu-west-1 (Dublin, Ireland)
The business software we use (e.g. Slack, HubSpot etc.) may be hosted outside the EEA e.g. the US. If that is the case, we rely on the adequate safeguards they have put in place to keep this personal data safe and secure.
These legal safeguards vary depending on which country the data is transferred to. For example, if the personal data is transferred outside the EEA, then they could, for example, be (a) part of the E.U.-U.S. Privacy Shield (www.privacyshield.gov) for data transfers to the US, or (b) using what is called 'Standard Contractual Clauses' put in place by the EU, or (c) the EU has decided that a particular non-EEA country provides the same/equivalent level of data protection as in the EU.
8.2 You acknowledge and agree that if you submit personal data for publication through our Websites or social media accounts, this data may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
09 Security of personal data
9.1 We maintain administrative, technical and physical safeguards designed to protect your personal data provided to us. While no system or process is full-proof (e.g. hacking), we believe the measures implemented reduce our vulnerability to security problems to a level appropriate to the type of personal data involved and the current state of technology.
10 Your Rights
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at email@example.com.
11 Access to Information
The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act.
12 Third Party websites
12.1 Our Websites may contain links to third party websites. Please note that if you follow a link to any such website, we do not accept any liability and/or responsibility, because these websites have their own terms & conditions and Privacy Policies.