CULT LDN’S Privacy Notice
At Cult LDN, we respect your privacy and are committed to protecting your personal data. This privacy notice tells you about how we look after your personal data when you visit our website or otherwise work or communicate with us and it tells you about your privacy rights and how the law protects you.
- Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how Cult LDN collects and processes your personal data through your use of our website or otherwise when you communicate or interact with us in the course of business.
Cult LDN Limited is the data controller of your personal data. We are responsible for its security and for ensuring that we use it only for the purposes outlined in this Privacy Notice.
If you have any questions about this privacy notice or your rights, please contact us using the details set out below.
If you need to get hold of us for any reason in connection with your personal data, please email us at firstname.lastname@example.org.
We are: Cult LDN Limited of East London Works, 75 Whitechapel Road, London E1 1DU.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns about data protection before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 24 May 2018.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
- The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Contact Data includes name, role at business, email address, phone number
- Influencer Data includes social media account details: Facebook, Twitter, Instagram
- Correspondence Data includes email correspondence notes of conversations
- Visual/audio visual Data includes photographs and content relating to individuals where we have express consent from those individuals
- Usage Data includes information about how you use our website.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Marketing Data includes your preferences in receiving marketing from us.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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.
- How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. We collect the majority of your data when you choose to give this to us by email, over the phone, in person at meetings or otherwise.
- Cookies and similar automated technologies. As you interact with our website, we may automatically collect Technical and Usage Data about your equipment, browsing actions and patterns in order that we can monitor and improve the way our website works. We collect this personal data by using cookies, server logs and other similar technologies such as Google Analytics, Shareaholic and/or Yoast SEO. We may also receive Technical and Usage Data about you if you visit other websites employing our cookies.
- How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- in anticipation of or accordance with the service agreement that we have with you; or
- where it is necessary for our legitimate interests (or those of a third party) in the operation of our business and we have made an objective assessment that your interests and fundamental rights do not override those interests (for example to manage our relationship with you and to improve the service that we offer and to send you articles of interest from time to time).
- Where we need to comply with a legal or regulatory obligation.
Please contact us if you need details about the specific legal ground we are relying on to process your personal data.
- Disclosures of your personal data
We will need to share your personal data with the parties set out below for the purposes set out in paragraph 4 above.
- Our service providers acting as processors who may have servers based in the US who provide IT support, IT backup, data storage, email management and system administration services.
- Analytics providers which may have servers based in the US – for the purpose of analysing user behaviour
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law.
We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
- International transfers
We may share your personal data with our US sister company. This will involve transferring your data outside the European Economic Area (EEA).
If you are connected to a client outside the EEA, then we will also be sending your personal data outside the EEA.
In addition, a number of our IT service providers processing your personal data on our behalf have servers based in the US or elsewhere outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring that either:
- we have a specific contract with that processor in a form approved by the European Commission which ensures that service provider gives your personal data the same protection it has in Europe; or
- if the provider is based in the US, it is a member of the US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US; or
- the processing is necessary in anticipation of or in order to perform a contract to which you are a party or in your interest.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
- Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
- Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements.
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.
- Your legal rights
You have the right in certain circumstances to:
- Request access to your personal data (a “data subject access request”).
- Request correction of the personal data that we hold about you.
- Request erasure of your personal data.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
- Request restriction of processing of your personal data.
- Request the transfer of your personal data to you or to a third party.
For more information on these rights and when they apply is available here:
- You will not have to pay a fee to access your personal data (or to exercise any of the other rights).
- 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.
- We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month 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.