We are Flint

Privacy Notice

Privacy Notice

Version 1.1, 25th May 2018

 

Welcome

25-28 Limited (trading as "We are Flint", a company registered under number 10385315 in England with its registered office at Nightingale House, 46-48 East Street, Epsom, Surrey KT17 1HQ) is strongly committed to protecting personal data. This privacy statement describes why or how we collect and use personal data and provides information about individuals’ rights. It applies to personal data provided by us, both by individuals themselves or by others.

Personal data is any information relating to an identified or identifiable living person. 25-28 Limited processes personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure and retention periods for each purpose may differ.

This Privacy Notice tells you how we look after your personal data when you visit our website and at other points at which we collect your personal data. It tells you about your privacy rights and how the law protects you. This Privacy Notice may be presented separately in order to describe how we will use personal data in specific scenarios.

We may use personal data provided to us for any of the purposes described in this privacy notice or as otherwise stated at the point of collection. This document may also be described as a Fair Processing Notice.

Finding your way around this privacy statement

This document 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 notice of every website you visit.

 

Important information about us

25-28 Limited is a communications consultancy. 25-28 Limited acts as a controller of personal data and is responsible for your personal data in connection with its activities (collectively referred to as "25-28 Limited", "we", "us" or "our" in this privacy notice). 25-28 Limited is the data controller which is responsible for this particular website.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

DPO Contact details

Tom Hashemi, Director
tom@weareflint.co.uk 
+44 (0) 208 133 3532
St Matthew’s Church, Brixton Hill, London SW2 1JF, United Kingdom

Changes to this privacy statement

We recognise that transparency is an ongoing responsibility so we will keep this privacy notice under regular review. This privacy notice was last updated on 25th May 2018.

Making a complaint

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 before you approach the ICO so please contact us in the first instance.

 

A request we would like to make of you

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.

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 that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. We will notify you if this is the case at the time.

 

Letting you know about our events

25-28 Limited may invite potential clients and existing clients to events. You may receive such invitations if you have requested information from us where you have not opted out of receiving such invitations. If we seek to share your personal data with any company other than our own, for the purpose of assisting us with offering invitations and organising events, we will request your express ‘opt-in’ consent. We may use your Identity, Contact, Technical, Usage 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 events may be relevant for you.

Opting out

You can ask us or third parties to stop sending you such invitations at any time by following the opt-out links on any invitations sent to you or by contacting us at any time (hello@weareflint.co.uk).

 

The type of personal data that we collect and use

When we refer to collecting or using personal data, or personal information, we are referring to 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 in this table.

Types of personal data that we collect, store, use and transfer

  • Identity Data: This includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender, title or office held within any other organisation, residency status.
  • Contact Data: This includes billing address, delivery address, email address, telephone numbers and social media accounts.
  • Financial Data: This includes bank account details.
  • Transaction Data: This includes details about payments to and from you, and details of services you have purchased from us.
  • Technical Data: This includes internet protocol (IP) address, 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 our website.
  • Profile Data: This includes purchase of our services, your interests, preferences, feedback and survey responses. 
  • Usage Data: This includes information about how you use our website.
  • Events Data: This includes your preferences in receiving information about (or invites to) events and your communication preferences.
  • Special Category Data: This includes data relating to race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.

We may also collect, use and share Aggregated Data (i.e. Anonymous 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.

If you are a potential client or existing client, we may collect Special Categories of Personal Data about you (this may include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data as well as Relevant Tax Data) simply by interacting with you regarding your life and tax affairs. We may also collect information about criminal convictions and offences. Details of the data we collect, why we collect it and what we use it for are listed below.

 

Where do we get your personal data from?

We use different methods to collect data from and about you. We have set this out below.

How we collect personal data

Direct Interactions

You may give us your Identity, Contact, Relevant Tax Data and Financial Data by filling in forms or by corresponding with us by post, phone, email, social media or otherwise. This includes personal data you provide when you:

  • apply for our services or use our services;
  • request that details of events be sent to you;
  • give us some feedback.

Automated technologies or interactions.  

As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

Third parties or publicly available sources.

We may receive personal data about you from various third parties and public sources as set out below

Technical Data from the following parties:

  • analytics providers such as Google, Squarespace and Hubspot based outside the EU;
  • search information providers such Google based outside the EU.
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as NatWest and TransferWise. Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

Further information about cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

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.

We use the following cookies:

  • 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.
  • Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region)
  • 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 and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

All cookies will expire no more than 2 years after being set or updated.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

 

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:

  • Where we have your consent to do so.
  • Where we need to perform a contract which we are about to enter into, or have entered into, with you.
  • Where we need to comply with a legal or regulatory obligation.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

 

The standards we employ when using personal data

We adhere to the principles relating to Processing of Personal Data set out in the GDPR which require Personal Data to be:

  • Processed lawfully, fairly and in a transparent manner (Lawfulness, Fairness and Transparency).
  • Collected only for specified, explicit and legitimate purposes (Purpose Limitation).
  • Adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed (Data Minimisation).
  • Accurate and where necessary kept up to date (Accuracy).
  • Not kept in a form which permits identification of Data Subjects for longer than is necessary for the purposes for which the data is Processed (Storage Limitation).
  • Processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised or unlawful Processing and against accidental loss, destruction or damage (Security, Integrity and Confidentiality).
  • Not transferred to another country without appropriate safeguards being in place (Transfer Limitation).
  • Made available to Data Subjects; and Data Subjects allowed to exercise certain rights in relation to their Personal Data (Data Subject's Rights and Requests).

 

Purposes for which we use your personal data

We have provided examples of when we use your personal data below.

Type of activities which we engage in, and corresponding purposes

Type of Activity

Purpose Description

Primary and secondary research

Processed to develop an understanding of our own and our clients’ stakeholders needs and requirements

Managing website enquiries

Processed as part of answering those enquiries and, where appropriate, offering services.

Marketing

Processed as part of our sales and marketing efforts – see further information below

Recruitment

Processed as part of a recruitment process that you have initiated

 

 

 

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage 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 products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside 25-28 Limited for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time (hello@weareflint.co.uk).

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service.

 

Disclosing your personal data to others

25-28 Limited may need to share your personal data with the parties set out below. Our purposes for doing so are set out in the table above marked “Types of personal data that we collect, store, use and transfer” .

External third parties

 

Type of professional advisers acting as processors or joint controllers

Country in which company is based

Service provided / need for disclosure

 

Lawyers (Bishop & Sewell)

United Kingdom

Legal services

Bankers (NatWest, TransferWise)

United Kingdom

Banking services

Accountants (Tudor John)

United Kingdom

Accounting services

Insurers (Hiscox)

United Kingdom

Insurance services

Companies House

United Kingdom

Statutory registration services

HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers

United Kingdom

Require reporting of processing activities in certain circumstances

Third party companies acting as processors or joint controllers

 

 

IT, Email software provider  (Gmail)

USA

Email

IT. File systems (Google Drive)

USA

To store files and documents

Cloud backup services (Google Drive, Google Vault)

USA

Backup services

Web analytics (Google Analytics, Squarespace)

USA

Analytic data from website

Accounting software (Xero, Sage)

United Kingdom

Assists with accounting

Social media (Linkedin, Twitter, Facebook, Instagram)

USA

Marketing

Email newsletter (Mailchimp)

USA

Newsletters

Customer relationship management software (Hubspot)

USA

To manage client relationships

Instant messaging services (WhatsApp)

USA

Internal team communications

Telecommunications services (Skype, Join.me)

USA

Internal and external, voice and/or video communications

Password management (Dashlane)

USA

To securely store internal and external passwords

Survey platforms (Peanutlabs)

USA

Survey management

Website hosting (WPEngine, Squarespace)

USA

To host websites

 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law and out own specific and stringent security requirements. We do not allow the above 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. In the event that 25-28 Limited sells, transfers, or merges parts of our operation or assets with a third-party organisation, then the new owners or operators may use your personal data in the same way as set out in this privacy notice.

International data transfers

Many of our external third parties are based outside the European Economic Area (EEA). Therefore, their processing of your personal data will involve a transfer of data outside of the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded by ensuring at least one of the following safeguards is implemented.

·       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. For further details, see European Commission: ‘Adequacy of the protection of personal data in non-EU countries’.

·       Where we use service providers in countries that have not been deemed to provide an adequate level of protection, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: ‘Model contracts for the transfer of personal data to third countries’.

·       Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us (hello@weareflint.co.uk) if you wish to receive further information on the specific mechanism which we use 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, altered, disclosed and/or processed in an unauthorised manner. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have an operational ‘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

We will only retain your personal data for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the following criterion: 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; whether we can achieve those purposes through other means; and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available below.

Retention periods

We will only retain your personal data for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the following criterion: 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; whether we can achieve those purposes through other means; and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are described in this policy.

In some circumstances, you can ask us to delete your data: see Request Erasure below for further information.

In some circumstances, we may anonymise your personal data (so that you can no longer be identified through the data) for research or statistical purposes. According to the law, anonymous data is not classed as personal data, as the data cannot be used identify any given individual. As such, we are permitted by law to use anonymous data indefinitely without further notice to any data subject.

Exercising your legal rights

Under certain circumstances, you have rights under data protection law in relation to your personal data.

·       Request access to your personal data.

·       Request correction of your personal data.

·       Request erasure of your personal data.

·       Object to processing of your personal data.

·       Request restriction of processing your personal data.

·       Request transfer of your personal data.

·       Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us (hello@weareflint.co.uk).

No fee usually required

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 may refuse to comply with your request in these circumstances.

What we may need from you

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.

Time limit to respond

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.

Description of your legal rights

You have the right to:

·       Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that your data is being lawfully processed.

·       Request correction of the personal data that we hold about you. This enables you to request that any incomplete or inaccurate data which we hold about you is corrected, though we may need to verify the accuracy of the new data which you provide to us.

·       Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data in the following circumstances: where you have successfully exercised your right to object to processing (see below); where we may have processed your information unlawfully; or where we are legally required to erase your personal data. Please note, however, that we may not always be able to comply with your request of erasure due to specific legal reasons. If such circumstances arise, you will be notified at the time of your request.

·       Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) if our legitimate interest is overridden by your own interests and/or fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.

·       Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where you consider our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

·       Request the transfer of your personal data to yourself or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Please note, this right only applies to automated information which you initially provided consent for us to use, or where we used the information to perform a contract with you.

·       Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you at the time if this is the case.

Contact us

As mentioned above, we have appointed a Data Protection Officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact our DPO using the contact details provided above or by emailing hello@weareflint.co.uk.