Privacy Notice
Bastard . London understands that your privacy is important to you and that you care about how your personal data is used and shared. We respect and value your privacy and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
When you provide personal data to Bastard . London we compile and process it in accordance with this Privacy Policy. In providing personal data you are consenting to its use and storage in accordance with the provisions of this Privacy Policy. Please read this Privacy Notice carefully and ensure that you understand it.
1. DEFINITIONS AND INTERPRETATION
In this Notice the following terms shall have the following meanings:
“Account”
when we contract with you or to take steps to enter into a contract with you we create an Account in or CRM and capture/ process data that will allow us to perform our obligations;
“Cookie”
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 Sites are set out in section 16, below;
“Personal data”
means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via our website, etc. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”)
“We/Us/Our”
Bastard . London is a trading name of If and Then Limited a limited company registered in England under company number *09745865, whose registered address 04 Whitchurch Parade, Whitchurch Lane, Edgware, Middlesex, England, HA8 6LROur VAT number is GB221887989.
2. INFORMATION ABOUT US
2.1 Bastard . London is a trading name of If and Then Limited company registered in England under company number *09745865, whose registered address 04 Whitchurch Parade, Whitchurch Lane, Edgware, Middlesex, England, HA8 6LROur VAT number is GB221887989.
2.2 Our Data Protection Officer is Kai Bastard, Managing Director and can be contacted by email at kai@bastard.london, by telephone on +44 (0)78 1395 7216, or by post at FAO Kai Bastard, Data Protection Officer, If and Then Limited, 169 Grove Road, London, E17 9BZ. United Kingdom.
3. WHAT IS OUR LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA?
We collect personal information from the following types of individual to allow us to undertake our business:
· Clients
· Prospective and placed candidates for permanent or freelance job roles
· Employees
· Suppliers
We collect information about you to carry out core business activities.
When you visit www.bastard.london and sign up to our email newsletter; our freelance network; apply for a job, request a quote for a project or service, correspond via email, phone or otherwise, you share your personal information with us.
We obtain information about you via other sources such as LinkedIn, corporate websites, your business card.
We use information held about you in the following ways:
To carry out our obligations and deliver services under contracts we enter into or intend to enter into, and to provide you with further information about our service offers, projects and news, or that we believe will be of interest to you because it is relevant to you.
We are processing your Personal Data on the following lawful basis:
· Consent of the data subject; should we want or need to rely on consent to lawfully process your data we will request your consent orally, via email or by an online form. Where consent is the lawful basis for our processing your right to withdraw your consent at any time remains
· Processing necessary for the performance of a contract with the data subject or to take steps to enter into a contract
· Processing necessary for compliance with a legal obligation
· Legitimate Business Interests
Our legitimate interests in collecting and retaining your personal data are described below:
As a creative production company we introduce clients prospective or otherwise to our range of service offers, including shoot, CGI and post production. The exchange of personal data is fundamental in seeking new business opportunities.
To maintain, expand and develop our business, we require a record of contact information.
4. YOUR RIGHTS
4.1 As a data subject, you have the following rights under the GDPR, which this Notice and Our use of personal data have been designed to uphold:
4.1.1 The right to be informed about Our collection and use of personal data;
4.1.2 The right of access to the personal data We hold about you (see section 12);
4.1.3 The right to rectification if any personal data we hold about you is inaccurate or incomplete (please contact Us using the details in section 14);
4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);
4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7 The right to object to Us using your personal data for particular purposes; and
4.1.8 Rights with respect to automated decision making and profiling.
4.2 If you have any cause for complaint about Our use of your personal data, please Contact Us using the details provided in section 2 and We will do our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office on 03031231113, via email or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.
4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
5. WHAT DATA DO WE COLLECT?
We may collect some or all of the following personal data:
5.1 [name]
5.2 [business/company name]
5.3 [job title;]
5.4 [contact information such as email addresses, postal address and telephone numbers;]
5.5 [financial information such as credit / debit card numbers;]
5.6 [IP address;]
5.7 [web browser type and version;]
5.8 [operating system;]
6. HOW DO WE USE YOUR DATA?
6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.
6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
6.2.1 [Providing and managing your Account;]
6.2.2 [Personalising and tailoring your experience on Our Sites;]
6.2.3 [Supplying Our products and services to you
6.2.4 [Sending and replying to emails and telephone calls from you, and providing requested information in order to contract you, take steps to enter into a contract, and deliver our service to you;]
6.2.5 [Supplying you with marketing emails that you have opted into (you may update your preferences, unsubscribe or opt-out at any time
6.2.6 [Market research;]
6.2.7 [Analysing your use of Our Sites to enable Us to continually improve Our Sites and your user experience;]
6.3 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email telephone, or post with information, news and offers on Our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
6.4 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
6.5 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. We will retain Customer Data in accordance with a Customer’s instructions, including any applicable terms in the Customer Agreement and as required by applicable law. This may include keeping your Information after we have completed our obligations under our contract for the period of time needed for Bastard . London to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.
7. HOW AND WHERE DO WE STORE YOUR DATA?
7.1 We only keep your personal data for as long as We need to in order to use it as described above in section 5, and/or for as long as We have your permission to keep it.
7.2 Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). If We do store data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR.
7.3 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Sites.
8. DO WE SHARE YOUR DATA?
8.1 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority.
8.2 We may sometimes contract with third parties to supply [products and] services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
8.3 We may compile statistics about the use of Our Sites including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. Data will only be shared and used within the bounds of the law.
8.4 We may sometimes use third party data processors that are located] outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any personal data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR.
8.5 We use a third party provider, Mailchimp, to deliver our regular e-newsletter. We gather statistics around email opening and clicks using industry standard technologies to help us monitor and improve our e-newsletter. For more information, please see Mailchimp’s privacy notice.
9. PROFILING
In the course of providing Our services, We may analyse your information to build individual profiles. These profiles may be used to predict future interests and display targeted marketing. The aim is to provide you with Bastard . London offers that are relevant and interesting for you. The profiling is based on your (surfing) behaviour on the internet which includes the viewing of articles and opening/engagement with our emails. You have the right to withdraw your consent at any time, by sending an email to: data@bastard.london and we will discontinue the processing of your information upon receipt of your withdrawal.
10. FURTHER PROCESSING
If We wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.
11. WHAT HAPPENS IF OUR BUSINESS CHANGES HANDS?
11.1 We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Any personal data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Notice, be permitted to use that data only for the same purposes for which it was originally collected by Us.
11.2 In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.
12. HOW CAN YOU CONTROL YOUR DATA?
12.1 In addition to your rights under the GDPR, set out in section 3, When you submit personal data via Our Sites, you may be given options to restrict Our use of your 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.
12.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
13. YOUR RIGHT TO WITHHOLD INFORMATION
You may access our website without providing any data at all. However, in order for us to provide our services to you will be required to submit or allow for the collection of certain data.
14. HOW CAN YOU ACCESS YOUR DATA?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us via data@bastard.london for data access requests.
15. OUR USE OF ANALYTICS
15.1 Our Sites use analytics services provided by Google. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Sites are used. This, in turn, enables Us to improve Our Sites and the products offered through it. You do not have to allow Us to use Our Sites Analytics, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Sites, it does enable Us to continually improve Our Sites, making it a better and more useful experience for you.
15.2 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.
16. COOKIES
16.1 Our Site uses cookies to distinguish you from other users of our Site. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.
16.2 A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.
16.3 We use the following cookies:
a) Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
b) Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, and remember your preferences.
d) Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website more relevant to your interests.
16.4 You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies.
16.5 All cookies have a pre-designated lifespan after which they will expire.
17. SOCIAL MEDIA
17.1 We have a public blog on our Website. Any information you include in a comment on our blog may be read, collected, and used by anyone. If your Personal Information appears on our blog and you’d like it to be removed, contact us marketing@bastard.london. If we’re not able to remove your information, we’ll let you know why.
17.2 Social Media Features and Widgets may collect information about your IP address and the pages you visit on our site. They may set a cookie to make sure the feature functions properly. Social media features and widgets are either hosted by a third party or hosted directly on our site. Your interactions with those features are governed by the privacy policies of the companies that provide them.
18. CONTACTING US
If you have any questions about Our Sites or this Privacy Notice, please contact Us by email at data@bastard.london, please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 12, above).
19. CHANGES TO OUR PRIVACY NOTICE
This notice was last updated on 25th May 2018. We may change this Privacy Notice from time to time (for example, if the law changes). Any changes will be immediately posted on Our Sites and where appropriate you will be notified by email. We recommend that you check this page regularly to keep up-to-date