PinkGreen Creative Limited 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 our website 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.
Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
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 14, below; and
means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;]
1. Information About Us
Our Site is owned and operated by PinkGreen Creative Limited, a company registered in England and Wales under company number 5937485
Registered address: Griffins Court, 24-32 London Road, Newbury, Berkshire, RG14 1JX
Main trading address: 40 Northbrook Street, Newbury, Berkshire, RG14 1DT
VAT number: 897202792
Data Protection Officer: Simon Hooley
Email address: email@example.com
Telephone number: +44 1635 521 855
Postal address: Pink Green Studio, 40 Northbrook Street, Newbury, Berkshire, RG14 1DT
2. What Does This Policy Cover?
3. 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.
4. What Are Your 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.
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 15 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 15 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.
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 15.
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.
5. What Data Do We Collect and How?
i) Data We May Collect
Identity Information including First Name, Surname, Date of Birth Contact information including Address, Email Address and contact telephone numbers.
Business information including Business Name, Job Title and Profession.
Technical information including IP Address, Browser Type and Version & Operating System.
Data from third parties including technical information, contact information, profile information.
ii) How We Collect the Data
We use different methods to collect data from you. You may correspond with us by post, phone or email, chat with us at an event or complete online forms.
You may provide us with personal data when you:
• enquire about one of our services via the website or by telephone or email;
• attend an event which we attend;
• arrange a meeting;
• subscribe to our mailing list, newsletter or other marketing communications or request a proposal;
• agree to provide us with services;
• enter a promotion or survey;
• provide feedback;
• submit a CV or recruitment enquiry.
We may receive personal data about you from various third parties and publicly available sources as set out below:
• IT Data from analytics providers;
• Information to identify and contact you from publicly available sources;
• Information to identify and contact you from events which we have sponsored, attended or will attend;
• Information to identify and contact you from industry or professional referrals
6. How Do We Use Your Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:
Purpose A: To add you to our database and/or mailing list.
Type of Data: Contact information
a) Consent (where appropriate).
b) necessary for legitimate interest (to ensure that interested parties are kept up to date with relevant information about our services.
Purpose B: Providing and managing your Account and our relationship which will include:
a) notifying you of important changes or development
b) asking you to provide feedback and respond to surveys
c) inviting you to events/sending you newsletters.
Type of Data: Contact information. Information about your preferences. Marketing & Comms data
a) Necessary to comply with the legal obligations
b) Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)
Purpose C: To respond to specific requests for information about services and other enquiries and to progress your interest in our services
Type of Data: Contact information. Marketing and Comms data
Lawful Basis: (a) Performance of a contract with you (b) Necessary for our legitimate interests (c) Consent (where appropriate)
Purpose D: To administer our contract with you (in the case of suppliers)
Type of Data: Contact information. Financial details
Lawful Basis: Performance of our contract with you
Purpose E: To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance and reporting)
Type of Data: Contact Information. IT data
Lawful Basis: (a) Necessary for our legitimate interests (provision of administration and IT services, to prevent fraud and protect network security)
(b) Necessary to comply with a legal obligation
Purpose F: To deliver relevant website content and advertisements to you
Type of Data: Contact information • IT data • Information about your preferences • Usage data • Marketing and Comms data
Lawful Basis: (a) Necessary for our legitimate interests (to understand how customers and potential customers use our services and so that we can improve, support and develop those services) (b) Consent
Purpose G: To improve our website, products/services, marketing, customer relationships and experiences using data analytics
Type of Data: IT data • Usage data
Lawful Basis: Necessary for our legitimate interests (to improve user experience, to identify potential new customers, to keep our website updated and for training and quality purposes)
Purpose H: To make suggestions and recommendations about other goods or services that may be of interest to you
Type of Data:
• Contact information
• IT data
• Information about your preferences
• Usage data
Lawful Basis: (a) Consent (b) Necessary for our legitimate interests (to develop our products/services and grow our business)
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and/or telephone and/or text message and/or post with information, news, and offers on our products and/or services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.
Third Parties (including Lead Forensics, HubSpot, Google Analytics) whose content/products appears on our site may use third-party Cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.
We will only use your personal data for the purpose for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
7. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason for which it was first collected.
By law we have to keep basic information about our customers (including Contact details and Financial data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see below for further information.
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.
8. How and Where Do You Store My Personal Data?
We will only store or transfer your personal data within the UK. This means that it will be fully protected under the Data Protection Legislation.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
• limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
• procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so;
9. Do You Share My Personal Data?
We may sometimes contract with third parties to supply certain products and services.
The following third-party service providers may process personal information about you for the following purposes:
• Marketing agencies/consultants – for the purposes of marketing campaigns and/or market research.
• Financial services & payroll providers – to deal with billing, payment of invoices etc.
• Providers of data analytics services – to help us with compiling statistical or demographic data.
• IT service providers – for trouble shooting, system maintenance and IT issues.
• Professional advisers (e.g. auditors, tax advisers, lawyers) – as required to enable them to provide professional services to us to allow us to comply with our legal and regulatory requirements.
If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation.
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?
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 and at the point of providing your details.
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.
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 my progress.
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.
By using our site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on our site for data gathering on contact forms. These Cookies are not integral to the functioning of our site and your use and experience of our site will not be impaired by refusing consent to them.
All Cookies used by us and on our site are used in accordance with current Cookie Law.
By using our site you consent to Cookies being placed on your computer or device, and you will be shown a message on the page informing you of this. . By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you.
You may be able to block certain Cookies by changing your internet browser’s settings, but please be aware that our site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
Our site also uses analytics services provided by Lead Forensics and Google. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how our site is used. This, in turn, enables us to improve our site and services offered through it.
In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access our site more quickly and efficiently.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
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 The Data Protection Officer
Email address: firstname.lastname@example.org
Postal Address: PinkGreen Creative, 40 Northbrook Street, Newbury, Berkshire, RG14 1DT
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 however welcome the opportunity to resolve your concerns with us directly first.
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.
Last Updated July 19.