Framework Creative Limited (“we” “us” “our”) are committed to protecting and respecting your privacy. For the purposes of data protection legislation, we are the data controller and we will process your personal data in accordance with the General Data Protection Regulation (EU) 2016/679 and national laws which relate to the processing of personal data. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
2. VISITORS TO OUR WEBSITE
2.1 We may collect and process personal data about you in the following circumstances:
2.1.1 whenever you provide information to us when reporting a problem with our Site, making a complaint, making an enquiry or contacting us for any other reason. If you contact us, we may keep a record of that correspondence;
2.1.2 details of your visits to our Site including, but not limited to, traffic data, location data, weblogs and other communication data;
2.2 We may use your personal data for our legitimate interests in order to:
2.2.1 provide you with information, or services that you requested from us;
2.2.2 ensure that content from our Site is presented in the most effective manner for you and for your device;
2.2.3 improve our Site and services;
2.2.4 process and deal with any complaints or enquiries made by you; and
2.2.5 contact you for marketing purposes where you have signed up for these (see section 6 for further details).
2.3 Our Site may, from time to time, contain links to and from the websites of third parties. Please note that if you follow a link to any of these websites, such websites will apply different terms to the collection and privacy of your personal data and we do not accept any responsibility or liability for these policies. When you leave our Site, we encourage you to read the privacy notice/policy of every website you visit.
3.1 We will collect details such as contact names, email addresses and telephone numbers when you instruct us. We will use this information to process your order and comply with our contractual obligations.
3.2 In order to perform our contract with you, we may also need to share personal data with third party providers in line with the agreed scope of work, including but not limited to photographers, illustrators, payment providers and postal service organisations to assist in the delivery of our services to you.
3.3 We may also advertise your feedback on our website and marketing materials (subject to obtaining your prior consent where necessary);
3.4 We will retain your information as long as we require it to provide our services to you and then for a period of twelve years from our last substantial engagement. Where you have subscribed to receive marketing correspondence from us we will keep your personal data for the period of time described in section 6 below.
We will collect details such as contact names, email addresses, postal address and telephone numbers in order to contact you about goods or services ordered with you, to place further orders and to pay you for the goods and/or services supplied. We will keep the personal data for six years further to being provided with the goods/services.
5. 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 the data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example to provide you with our goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
6.1 In addition to the uses described in sections 2-4 above, we may use your personal data for our legitimate interests in order to provide you with details about our services and events which we think may be of interest.
6.2 You have the right to opt-out of receiving the information detailed in section 6.1 at any time. To opt-out of receiving such information you can:
6.2.1 clicking the unsubscribe button contained in any such communication received; or
6.2.2 email us at GDPR@elmwood.com providing us with your name and contact details.
7. AUTOMATED PROCESSING
8.1 We do not undertake automated decision making with your personal data.
8. LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA
8.1 We will only use your personal data where the law allows us to. Most commonly, we will use your personal data in the following circumstances:
8.1.1 for performance of a contract we enter into with you;
8.1.2 where necessary for compliance with a legal or regulatory obligation we are subject to; and
8.1.3 for our legitimate interests (as described within this policy) where your interests and fundamental rights do not override these interests.
9. DISCLOSURE OF PERSONAL DATA to third parties
9.1 In addition to the third parties mentioned above, we may disclose your information to third parties for our legitimate interests as follows:
9.1.1 to staff members in order to facilitate the provision of goods or services to you;
9.1.2 to our affiliated entities to support internal administration;
9.1.3 IT providers
9.1.4 freelance and agency staff;
9.1.5 professional advisers including accountants, consultants, lawyers, bankers and insurers who provide us with consultancy, banking, legal, insurance and accounting services;
9.1.6 HM Revenue and Customs, regulators and other authorities who require reporting of processing activities in certain circumstances; and
9.2 We may disclose personal data to the police, regulatory bodies, legal advisors or similar third parties where we are under a legal duty to disclose or share personal data in order to comply with any legal obligation, or in order to enforce or apply our
website terms and conditions and other agreements; or to protect our rights, property, or safety of our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
9.3 We will not sell or distribute personal data to other organisations without your approval.
10. CROSS-BORDER DATA TRANSFERS
11. DATA SECURITY
11.1 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your information transmitted to our Site; any transmission is at your own risk.
11.2 Information you provide to us is shared on our secure servers. We have implemented appropriate physical, technical and organisational measures designed to secure your information against accidental loss and unauthorised access, use, alteration or disclosure. In addition, we limit access to personal data to those employees, agents, contractors and other third parties that have a legitimate business need for such access.
12. ACCESS TO, UPDATING, DELETING AND RESTRICTING USE OF PERSONAL DATA
12.1 It is important that the personal data we hold about you is accurate and current. Please keep us informed if the personal data we hold about you changes.
12.2 Data protection legislation gives you the right to object to the processing of your personal data in certain circumstances or withdraw your consent to the processing of your personal data where this has been provided. You also have the right to access information held about you and for this to be provided in an intelligible form. If you would like a copy of some or all of your personal information, please send an email to GDPR@elmwood.com. In certain circumstances we reserve the right to charge a reasonable fee to comply with your request.
12.3 You can also ask us to undertake the following:
12.3.1 update or amend your personal data if you feel this is inaccurate;
12.3.2 remove your personal data from our database entirely;
12.3.3 send you copies of your personal data in a commonly used format and transfer your information to another entity; or
12.3.4 restrict the use of your personal data.
12.4 We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal data that we hold about you or make your requested changes. Data protection legislation may allow or require us to refuse to provide you with access to some or all the personal data that we hold about you or to comply with any requests made in accordance with your rights referred to above. If we cannot provide you with access to your personal data, or process any other request we receive, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
12.5 Please send any requests relating to the above to GDPR@elmwood.com specifying your name and the action you would like us to undertake.
13. RIGHT TO WITHDRAW CONSENT
Where you have provided your consent to the collection, processing and transfer of your personal data, you have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, please contact us at GDPR@elmwood.com.
15. CONTACT US
Last updated: 22nd May 2018.