1.1 Intro Creative are committed to safeguarding the privacy of persons for whom we process Personal Data. In this policy we explain how we will treat Personal Data processed by us, in accordance with data protection legislation, including the Data Protection Act 2018, the Privacy and Electronic Communications Regulation (‘PECR’), and the General Data Protection Regulation (‘GDPR’).
1.2 Personal Data includes any information relating to an identified or identifiable natural person (‘Data Subject’) who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
1.3 Processing, for the purpose of this Privacy Notice, means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaption or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
1.4 Before you disclose to us the Personal Data, Special Category Personal Data or Personal Data relating to criminal convictions and offences of another person, you must obtain that person’s consent, or have another lawful basis for such disclosure.
2. Processing Personal Data – Lawful Bases
2.1 We will only process Personal Data that is adequate, relevant and limited to what is necessary to achieve the purpose of the processing.
2.2 We may process Personal Data for the following lawful purposes: (a) Legitimate interests of our organisation. These include processing accounts and payroll, the use of surveillance cameras, internal vehicle tracking devices and electronic marketing to members of business membership organisations of which the data controller is a member or attendee; (b) Performance of a contract or to enter into pre-contractual negotiations; (c) Compliance with a legal obligation placed on us; (d) To protect the vital interests of either yourself or another person; and/or (e) For other reasons with your consent, which can be withdrawn at any time.Withdrawal of your consent does not affect the lawfulness of processing up to the time of the time of your withdrawal.
3. Processing Personal Data – How We Obtain and Collect Personal Data
3.1 We generally primarily process Personal Data that you provide us with.
3.2 We may also obtain your Personal Data through membership organisations of which we are a member.
3.3 If you apply for credit, we will also obtain data regarding your credit-worthiness and credit reference. Such data may include your name, address, date of birth, qualifications, creditworthiness, credit reference, bank details and images, including the use of surveillance cameras. If we obtain any other personal data from third-party sources, we will tell you about this.
3.4 We may also process the following kinds of Personal Data from your visit to our website: (a) information about your computer and about your visits to and use of this website (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths); (b) information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (including your name and email address). You can inform us at any time you no longer require our email notifications/newsletter; (c) information that you provide to us when using the services on our website, or that is generated in the course of the use of those services(including the timing, frequency and pattern of service use); (d) information contained in, or relating to, any communication that you send to us or send through our website (including the communication content and metadata associated with the communication); (e) information necessary to provide third parties with statistical information about our users; (f) information required to deal with enquiries and complaints made by or about you relating to our website; (g) information required to keep our website secure and prevent fraud; (h) information required to verify compliance with the terms and conditions governing the use of our website (including monitoring private messages sent through our ‘Contact Us’ page on our website); and (i) any other personal information that you choose to send to us.
4. Processing Special Category Personal Data
In the event that we need to obtain and process Special Category Personal Data from you, other than as required by law, we will always tell you why, and how the information will be used and obtain your consent for this. Special Category Personal Data is Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health, or data concerning a natural person’s sex life or sexual orientation.
5. Processing Personal Data Relating to Criminal Convictions and Offences
All processing of Personal Data relating to criminal convictions and offences or related security measures, including Personal Data relating to the commission of offences or proceedings for an offence committed or alleged to have been committed by the Data Subject or the disposal of such proceedings including sentencing, will be processed either by consent or when processing is authorised by law.
6. When, and with whom, will we share your Personal Data?
6.1 We may disclose your Personal Data to any of our employees, officers,insurers, professional advisers, agents, suppliers, or subcontractors insofar as reasonably necessary for the purposes set out in this policy.
6.2 We may disclose your Personal Data: (a) to the extent that we are required to do so by law; (b) to protect rights, property, the safety of us, our customers, users of our website or other persons; (c) in connection with any ongoing or prospective legal proceedings; (d) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk); (e) to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; (f) to another organisation if we enter into a joint venture or merge with another organisation
6.3 We will not, without your express consent, supply your Personal Data to any third party for the purpose of their, or any other third party’s, marketing.
6.4 Except as provided in this policy, we will not provide your Personal Data to third parties without first obtaining your consent.
6.5 If we wish to pass your Special Category Personal Data or your Personal Data Relating to Criminal Convictions and Offences on to a third party, we will only do so once we have obtained your explicit consent, unless we are required to do so by law.
6.6 Any third party who we share your Personal Data with are obliged to keep your details securely and when no longer needed, to dispose of them securely or to return the Personal Data to us.
7. For how long will we keep your Personal Data?
7.1 Personal Data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
7.2 Unless we advise you otherwise, we will retain your Personal Data in accordance with legal requirements and best practice.
8. How we ensure your Personal Data is kept securely
8.1 We will take reasonable organisational and technical precautions to prevent the loss, misuse or alteration of your personal information.
8.2 We will store all the personal information you provide on our secure cloud servers.
8.3 You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
You have the following rights regarding the Personal Data which we hold about you:
9.1 Right of access – you have the right to request a copy of the information that we hold about you, and to whom it has been disclosed;
9.2 right of rectification – You have a right to correct Personal Data that we hold about you that you think is inaccurate or incomplete;
9.3 right to erasure (‘right to be forgotten’) – in certain circumstances you can ask for the Personal Data which we hold about you to be erased from our records;
9.4 right to restriction of processing – in certain circumstances you have a right to restrict the processing of Personal Data;
9.5 right to data portability – You have a right to have the Personal Data we hold about you provided to you in a machine-readable format, and the right to have that transferred to another organisation;
9.6 right to object – you have the right to object to direct marketing, which is an absolute right to object and cannot be refused;
9.7 right to object – you have the right to object to processing which is based on the legitimate interests of Intro Creative. Such objections will be assessed on their respective legal merits; and
9.8 right not to be subject to automated profiling – you have the right not to be subject to a decision based solely on automated processing or profiling.
10. What if you are not happy?
10.1 In the event that we refuse your request to exercise any of your rights, we will provide you with a reason why.
10.2 If you wish to make a complaint about how your Personal Data is being processed by us, or any third party on our behalf, we would be grateful if you would in the first instance contact our Data Protection Officer, who will endeavour to resolve your issue to your satisfaction.
10.3 You also have the right to complain directly to the Information Commissioner’s Office and seek other legal remedies.
11. Links to other websites
11.1 Our website may include hyperlinks to, and details of, third-party websites.
11.2 We have no control over and are not responsible for, the privacy policies and practices of third parties.
12. Updating Personal Data
Please let us know if any of your details change, need to be corrected or updated. We will then be able to change our records, we cannot do so unless you notify us of any alterations. You can contact us by post, email, telephone, or via our website using the contact details provided in paragraph 15 below.
13. Transfers of Personal Data to a Country Outside of the UK, Europe or EEA
If we need to transfer Personal Data for processing to a country outside of the UK,EU or EEA, we will generally only do so where: (a)the European Commission have taken an adequacy decision in respect of the country; (b)lawful binding corporate rules are in place; (c)lawful model contract clauses are in place; (d)we have obtained your specific consent to the proposed transfer, and you have been advised of the possible risks of such transfers;(e)the transfer is necessary for the performance of a contract between ourselves, or are part of the implementation of pre-contractual measures taken at your requests;(f)the transfer is necessary for the conclusion or performance of a contract concluded in the interests of us, if acting as data controllers, and another natural or legal person;(g)the transfer is necessary for important reasons of public interest; (h)the transfer is necessary for the establishment, exercise or defence of legal claims; and/ or(i)the transfer is necessary in order to protect the vital interests of you or others, where you are physically or legally incapable of giving legal consent.
15. About Us
15.1 Our name is Intro Creative and our website address is www.introcreative.co.uk.
15.2 Our principal place of business is at Unit 4, 1 Kirkhill Place, Dyce, Aberdeen, AB21 0GU.
15.3 You can contact us:
(a) by post, using the postal address, given above;
(b) using our website contact form;
(c) by telephone on 01224 722224; and/ or
(d) by email [email protected]
15.4 Our Data Protection Officer is Matthew Smith, who can be contacted using
the details referred to in the above clause.
16. How we will notify you of any changes to our Privacy Notice
16.1 We may update this policy from time to time by publishing a new version on
16.2 You should check this page occasionally to ensure you are happy with any
changes to this policy.
16.3 We may also notify you of changes to this policy, by email or through the
private messaging system on our website.
This Policy is generally available to clients / customers and third parties on our website. If a hard copy or email version of this policy is required by any person, it will be sent to them without delay.