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PRIVACY POLICY

This notice intends to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it.

If for any reason any part of this Privacy Notice is not clear enough for you, please do get in touch with our Legal & Compliance Team on [email protected] as we welcome any feedback to make it even better for you. We care about data privacy and we know that when you share your information with us, it’s because you trust us, and we are committed to maintaining that trust.

1. A short summary on us

We are a digital marketing agency providing various marketing and advertising services to our clients. Our company is incorporated in England & Wales under Resident North Limited with the company number 14520808. This Privacy Notice applies to Resident North Limited and covers all website users, candidates and prospective and existing clients and suppliers that engage with us.

2. Legal information

Our team keep up to date with Data Protection Laws and have read the full 261 pages of the European Union’s General Data Protection Regulation 2016/679 (“EU GDPR”) in order to make sure that we comply with all of our obligations in it as well as those now subsequently in the UK GDPR. The UK GDPR is the UK’s version of the EU GDPR and comprises of the Data Protection Act 2018 and the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 (SI 2019/419)).

Data Protection Laws have created the concepts of a “Data Controller” and a “Data Processor” and Resident North fits into each concept albeit in different circumstances. For example, we are a Data Controller when candidates are applying to join us and a Data Processor when we are performing some of our services for our clients. To keep us (and all other organisations) in check, we are supervised by the Information Commissioner’s Office (“ICO”) which is the data protection supervisory authority in England & Wales.

3. Different types of personal data

We collect, use, store and transfer different kinds of Personal Data depending on our relationship with you. In general, we collect the following types:

  • Identity Data (e.g., first name, maiden name, last name, title, data of birth).
  • Contact Data (e.g., phone number, email address, business address and billing address).
  • Communications & Marketing Data (e.g., your preferences in respect of cookies and marketing).
  • Financial Data (e.g., bank account details, value added tax numbers).
  • Profile Data (e.g., agreements you have entered into with us such as our terms and conditions).
  • Transaction Data (e.g., invoices, payment details).
  • Technical Data (e.g., internet protocol addresses, browser type and version, time zone settings and location).
  • Usage Data (e.g., information about how you use our website).

We also collect, use and share “Aggregated Data” such as statistical or demographic data for other purposes including research and analysis. Aggregated Data could be derived from your Personal Data but is not considered Personal Data under Data Protection Laws as this data will 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.

4. For our website users

We collect Technical Data and Usage Data (for tracking purposes). We also collect Identity Data, Contact Data and Communications & Marketing Data (if you decide to contact us)

As you interact with our website, we automatically collect this data about you by using cookies and similar technologies (check out our Cookies Notice. We also collect this data through our direct interactions with you such as when you contact us through our website.

One or more of the following apply:

  • Consent (i.e., in that you are choosing to provide us with your details so that we can contact you).
  • Legitimate Interests (i.e., its necessary for our Legitimate Interests in running and developing our business including our marketing strategy).
  • Legal obligation (i.e., its necessary for us to comply with a legal obligation such as in the instance where you no longer wish to be contacted for direct marketing purposes).

5. Sharing your personal data

We will only share your Personal Data when necessary and have outlined examples of the types of organisations with whom we would share it with:

  • Technology companies that provide us with desktop and cloud-based products, solutions and services (as we will need their support in order to communicate with you and/or deliver our services, e.g., Google, Facebook).
  • Professional advisers such as law firms, banks and accountancy firms (as we need to engage with them for the purposes of our business).
  • Third parties to whom we may be in contact with to sell, transfer or merge parts of our business or assets, or to attempt to acquire or merge with other companies (as we may need to disclose some of your Personal Data).
  • Regulators and other governmental authorities (as we need to engage with them for the purposes of our business).

We require all third parties to respect the security of your Personal Data and to treat it in accordance with Data Protection Laws. We enter into contractual agreements with all of our third parties (with the exception of regulators and governmental authorities) which include the appropriate data protection clauses.

6. Data across borders

Whenever your Personal Data travels outside of the UK and/or the EEA, we ensure that it’s protected by putting in one of the following safeguards:

  • We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission.
  • We will only transfer your Personal Data where we have entered into specific contracts with an organisation outside of the UK and/or the EEA which states that they will ensure that your Personal Data has the same level of protection as if it were in the UK and/or the EEA.

If you want to find out the specific mechanism used when transferring your Personal Data out of the UK and/or the EEA, please contact us.

7. Data retention

We will only keep your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

As a note, in some circumstances we will 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 without further notice to you.

8. Your rights

Under certain circumstances, you have specific rights in respect of the Personal Data that we Process about you. Your rights include:

  • the right of access to the Personal Data we hold about you.
  • the right to rectify (i.e., correct) your Personal Data where it is inaccurate or incomplete.
  • the right to delete your Personal Data, but only in specific circumstances, for example where the Personal Data is no longer necessary in relation to the purpose for which it was originally collected or Processed. It may not therefore always be possible for us to delete all of the information we hold about you if you request this, for example, if we have an ongoing contractual relationship with you.
  • the right to restrict Processing in specific circumstances, for example while we are reviewing the accuracy or completeness of data or deciding on whether any request for erasure is valid.
  • the right to object to Processing in cases where Processing is based upon our Legitimate Interests or where Processing is for direct marketing purposes (including profiling).
  • the right to data portability which means the right to receive, move, copy or transfer your Personal Data to another Data Controller. You have the right to this when we are Processing your Personal Data based on Consent or on a contract and the Processing is carried out by automated means.
  • the right to lodge a complaint with the ICO.

If you wish to exercise any of the rights set out above, please contact us. 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 could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity. This is a security measure also in your own interest 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.

We try to respond to all legitimate requests within 30 days. Occasionally it could take us longer than 30 days 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.

9. Data security

We have put in place appropriate technical and organisational security measures to prevent your Personal Data from being accidentally lost, falsified, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, contractors and other third-parties who have a business need to know. We have put in place policies, plans and procedures to deal with any suspected or actual personal data breaches (although we hope not to ever be in that position).

 

10. Third party links and social plugins

Our 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 documentation of every website you visit.

11. Marketing

We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising. We may use your Identity Data, Contact Data, Technical Data, Usage Data and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.

You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing. We will get your express opt-in Consent before we share your Personal Data with any third-party for marketing purposes. You can ask us or third parties to stop sending you marketing messages at any time by contacting our Legal & Compliance Team and withdrawing your Consent. Where you opt out of receiving these marketing messages, this will not apply to messages that we need to send you a result of performing a contract that we have with you (e.g., as we may be required to contact you about a payment due).

12. Contact us

To get in touch with team, please contact [email protected]

We also need to let you know that if you have any concerns and/or you’re not happy with our approach, you have the right to make a complaint to the ICO which can be contacted on www.ico.org.uk Data Protection Laws are constantly evolving, and we endeavour to maintain best practice. However, we recognise that we may not always get it right and if you are not satisfied in the way we handle your Personal Data, or you wish to discuss our processes then we would like to hear from you and recommend that you contact us in the first instance.

13. Glossary

Consent: refers to when an individual gives agreement which is freely given, specific, informed and is an unambiguous indication of their wishes. It is done by a statement or by a clear positive action in respect of the Processing of any Personal Data relating to them.

Data Controller: refers to an organisation that determines when, why and how to Process Personal Data. It is responsible for establishing practices and policies in line with Data Protection Laws. There are certain circumstances where we act as a Data Controller.

Data Protection Laws: refers to the European Union’s General Data Protection Regulation 2016/679 and the UK GDPR. The UK GDPR is the UK’s version of the EU GDPR and comprises of the Data Protection Act 2018 and the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 (SI 2019/419)).

Data Processor: refers to an organisation that Processes Personal Data on behalf of a Data Controller. It is also responsible for establishing practices and policies in line with Data Protection Laws and its contractual obligations with Data Controllers. There are certain circumstances where we act as a Data Processor.

European Economic Area (“EEA”): refers to the 27 countries in the European Union, Iceland, Liechtenstein and Norway.

Legitimate Interest: refers to when an organisation’s interests are legitimate (as they need to do something to operate and be successful) and these interests do not override an individual’s interests or fundamental rights and freedoms. We make sure to consider and balance any potential impact on individuals (both positive and negative) and their rights before we Process any Personal Data for our Legitimate Interests.

Personal Data: refers to any information identifying an individual or information relating to an individual that an organisation can identify (directly or indirectly) from that data alone or in combination with other identifiers that it Processes. Personal Data includes Special Category Personal Data, Criminal Convictions Data and pseudonymised Personal Data. Personal Data excludes anonymous data or data that has had the identity of an individual permanently removed.

Processing or Process: refers to any activity that involves the use of Personal Data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transmitting or transferring Personal Data to third parties.

Special Category Personal Data: refers to information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data.