This Privacy Statement was published on 14 June 2018.
At Creative Culture Ltd we are committed to protect and respect your privacy in compliance with EU General Data Protection Regulation (GDPR) 2016/679, dated April 27th 2016. This privacy statement explains when and why we collect personal information, how we use it, the conditions under which we may disclose it to others and how we keep it secure. This Privacy Statement applies to the use of our services and to our sales, marketing and customer contract fulfilment activities. It also applies to individuals seeking a job at Creative Culture Ltd.
Who are we?
Creative Culture is a cross-cultural consultancy. Our main objective is to help brands and agencies to get their cross-market messages right.
Our company’s headquarters are located in the United Kingdom. The headquarters’ registered address is 195-197 Victoria Street, London SW1E 5NE, UK.
Creative Culture Ltd is the data controller and our Data Protection Officer can be contacted by email: email@example.com.
When do we collect personal data about you?
- When you are using our services.
- When you interact with us in person, through correspondence, by phone, by social media, or through our websites.
- When we collect personal information from other legitimate sources, such as third-party data aggregators, Creative Culture Ltd marketing partners, public sources or social networks. We only use this data if you have given your consent to them to share your personal data with others.
- We may collect personal data if it is considered to be of legitimate interest, and if this interest is not overridden by your privacy interests. Before data is collected we make sure an assessment is made, ensuring that there is an established mutual interest between you and Creative Culture.
Why do we collect and use personal data?
We collect and use personal data mainly to perform direct sales, direct marketing and customer service. We also collect data about suppliers, partners and persons seeking a job or working in our company.
We may use your information for the following purposes:
- Send you marketing communications which you have requested. These may include information about our services, events, activities, and promotions of our associated partners’ products and services.
- Send you information about the services we provide you with.
- Perform direct sales activities in cases where legitimate and mutual interest is established.
- Provide you content and venue details on a webinar or event you signed up for.
- Reply to a ‘Contact me’ or other web forms you have completed on our website.
- Follow up on incoming requests (customer support, emails, chats, or phone calls).
- Perform contractual obligations such as order confirmation, license details, invoice, reminders, and similar. The contract may be with Creative Culture Ltd directly or with a Creative Culture Ltd partner.
- Notify you about any disruptions to our services.
- Contact you to conduct surveys about your opinion on our services.
- Process a job application.
Our legal basis for collecting personal data
Collecting personal data based on consent
The collection of personal data based on consent from the data subject will be done by using “Consent Forms” that will store documentation related to the consent given by the individual. Individual consents will always be stored and documented in our systems.
Collecting personal data based on contracts
We use personal information for fulfilling our obligations related to contracts and agreements with customers, partners and suppliers.
Collecting personal data based on legitimate interest
We may use personal data if it is considered to be of legitimate interest, and if the privacy interests of the data subjects do not override this interest. Normally, to establish the legal basis for data collection, an assessment has been made during which a mutual interest between Creative Culture Ltd and the individual person has been identified. This legal basis is primarily related to our sales and marketing purposes. We will always inform individuals about their privacy rights and the purpose for collecting personal data.
What type of personal data is collected?
We collect name, phone number, job title, email address, in addition to your company’s name and contact information. We may also collect feedback, comments and questions received from you in service-related communication and activities, such as meetings, phone calls, documents, and emails. From our websites we may collect IP-address and actions taken on the site.
If you upload photos or videos, add posts or comments, etc. on our website, the information can be read by anyone with access to the Community site and used for purposes over which Creative Culture Ltd or you have no control. Therefore, Creative Culture Ltd is not responsible for any information you submit to the website.
If you apply for a job at Creative Culture Ltd, we collect the data you provide during the application process.
Creative Culture Ltd does not collect or process any special categories of personal data, such as public unique identifiers or sensitive personal data.
How long do we keep your personal data?
We store personal data for as long as we find it necessary to fulfill the purpose for which the personal data was collected, while also considering our need to answer your queries or resolve possible problems, to comply with legal requirements under applicable laws, to attend to any legal claims/complaints, and for safeguarding purposes.
This means that we may retain your personal data for a reasonable period of time after your last interaction with us. When the personal data that we have collected is no longer required, we will delete it in a secure manner. We may process data for statistical purposes, but in such cases, data will be anonymised.
In compliance with the applicable UK law, we are required to store accounting documents for ten (10) years. As such, if you have previously worked with us and choose to opt out, we will still be required to retain minimal information for the aforementioned period of time. This minimal information (referred to as “data minimisation” in the GDPR regulation) will be equivalent to the data provided on invoices and POs. This includes, but is not limited to, name, surname, address, email address and bank details.
Your rights to your personal data
You have the following rights with respect to your personal data:
- The right to request a copy of your personal data that Creative Culture Ltd holds about you.
- The right to request that Creative Culture Ltd corrects your personal data if inaccurate or out of date.
- The right to request that your personal data is deleted when it is no longer necessary for Creative Culture Ltd to retain such data.
- The right to withdraw any consent to personal data processing at any time. For example, your consent to receive e-marketing communications: if you want to withdraw your consent to e marketing, please make use of the link included in our communication. Please note that you may still receive system messages and administrative communications from Creative Culture Ltd, such as order confirmations, system messages and notifications about your business activities with us.
- The right to request that Creative Culture Ltd provides you with your personal data and, if possible, to pass on this information directly (in a portable format) to another data controller when the processing is based on consent or contract.
- The right to request a restriction on further data processing, in case there is a dispute in relation to the accuracy or processing of your personal data.
- The right to object to the processing of personal data, in case data processing has been based on legitimate interest and/or direct marketing.
Any query about your Privacy Rights should be sent to firstname.lastname@example.org.
This information is used to make websites work more efficiently, as well as to provide business and marketing information to the owners of the site, and to gather such personal data as browser type and operating system, referring page, path through site, domain of ISP, etc. for the purposes of understanding how visitors use a website. Cookies and similar technologies help us tailor our website to your personal needs, as well as to detect and prevent security threats and abuse. If used alone, cookies and web beacons do not personally identify you.
Do we share your data with anyone?
We do not share, sell, rent, or trade your information with any third parties without your consent, except from what is described below:
Third-party Service Providers working on our behalf:
We may pass your information on to our distributors, agents, sub-contractors and other associated organizations with the purpose of them providing services to you on our behalf.
Third-party Product Providers we work in association with:
If required by law:
We will disclose your personal information if required by law or if we, as a company, reasonably believe that disclosure is necessary to protect our company’s rights and/or to comply with a judicial proceeding, court order or legal process. However, we will do what we can to ensure that your privacy rights continue to be protected.
Use of sub-contractors (processors and sub-processors)
If the sub-contractor processes Personal Data outside the EU/EEA area, such processing must be in accordance with the EU Privacy Shield Framework, EU Standard Contractual Clauses for transfer to third countries, or another specifically stated lawful basis for the transfer of personal data to a third country.
If a new sub-contractor is signed or a change of sub-contractor is performed related to our services, the customers will be notified in line with our Terms of Service. A directory of approved sub-processors is part of our Data Processing Agreement available by emailing email@example.com.
Changes to this Privacy Statement
Creative Culture reserves the right to amend this Privacy Statement at any time. The applicable version will always be found on our website. We encourage you to check this Privacy Statement occasionally to ensure that you are happy with any changes.
If we make changes that significantly alter our privacy practices, we will notify you by email or post a notice on our websites prior to the change taking effect.
We hope that you won’t ever need to, but if you do want to complain about our use of personal data, please send an email with the details of your complaint to firstname.lastname@example.org. We will look into and respond to any complaints we receive.
You also have the right to lodge a complaint with the Information Commissioner’s Office (“ICO”) (the UK data protection regulator). For further information on your rights and how to complain to the ICO, please refer to the ICO website.