WHAT IS THIS?
Verve Creative Solutions Limited (referred to as “we”, “us”, “our”) is committed to protecting and respecting any personal information you share with us.
This statement describes what types of information we collect from you when you work with us, use our website, interact with our digital platforms, when we meet you and when you contact us, how it is used by us, how we share it with others, how you can manage the information we hold and how you can contact us.
We will always give you the option not to receive marketing communications from us. We will never send you unsolicited ‘junk’ email or communications, or share your data with anyone else who might. We do not sell your information to third parties, but we do sometimes work closely with selected partners who help us to provide you with the information, products and services that you request from us. For example, Google Analytics and IP Tracking providers.
The contents of this statement may change from time to time. Where possible, we will contact you directly to notify you of these changes.
This policy was last updated on 25 May 2018.
WHO WE ARE
We, Verve Creative Solutions Limited, 7 Forge Close, Merton, Oxon, OX25 2NW, with company registration number: 7450884 is the data controller in relation to the processing activities described below. This means that we decide why and how your personal information is processed.
Where this policy refers to “we”, “our” or “us” below, unless it mentions otherwise, it’s referring to the particular company that is the controller of your personal information.
HOW WE COLLECT YOUR PERSONAL INFORMATION
We collect information about you whenever you engage and interact with us, whether through our websites www.verve-creative.com (“our websites”), over the telephone, face to face, email, social media interaction or other touch points. We only collect information which is necessary, relevant and adequate for the purpose you are providing it for.
We collect information about you when you contact us and/or use our services (whether through corresponding with us by phone, email or otherwise, via social media platforms, our mobile applications, or our website). We also obtain information about you from events, Cookies, IP tracking, website analytics and other sources mentioned below. Some of this information does not identify you personally, but provides us with information about how you use our services and engage with us (we use this information to improve our services and make them more useful to you). The information we collect includes some or all of the following:
- Name (title, first and last name);
- Email address;
- Social media handles;
- Telephone number and mobile number;
- Aggregated data;
- The pages you visited on our website and how long you visited us for;
- Your Internet protocol (IP) address used to connect your computer or device to the Internet;
- The internet browser and devices you are using;
- We may also collect any personal information which you allow to be shared that is part of your public profile or third party social network, type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- Cookie, pixels or beacon information; and
- Any personal information within correspondence you send to us.
This includes information provided when you enquire about using our services, engaging our services, posting material or requesting further services, managing your account (including accessing documentation and engaging in correspondence with us by phone, email or otherwise). If you complete any surveys that we request you complete for research purposes, we will collect information in such circumstances as well. The information you give us includes your name, address, email address and phone number, enquiry details and may include records of any correspondence and responses to any surveys.
HOW WE USE YOUR PERSONAL INFORMATION
We will only process information that is necessary for the purpose for which it has been collected. You will always have the option not to receive marketing communications from us (and you can withdraw your consent or object at any time). We will never send you unsolicited ‘junk’ email or communications, or share your personal information with anyone else who might.
Where you have provided CONSENT
We may use and process your personal information where you have consented for us to do so for the following purposes:
- contact you via email, post or phone with marketing information about our services if you engage with us, whether online or otherwise and indicate that you would like to receive such marketing from us; (ii) sign up to our newsletter, updates or Blog via our website or other medium where available; or (iii) when you refresh your marketing preferences when responding to a request from us to do so;
You can withdraw your consent at any time by contacting us at [email protected] or, in relation to any marketing messages you receive, by using the unsubscribe option included in those messages.
Where it is necessary for CONTRACTUAL PERFORMANCE
We may use and process your personal information where we have supplied you (or continue to supply you) with any services, where we have arranged for the supply of another company’s products or services to you, or where you are in discussions with us about any new product or service. We will use this information in connection with the contract for the supply of services when it is needed to carry out that contract with you or for you to enter into it. Please see above for the type of personal information we may process about you to fulfil these purposes.
Where there is a LEGAL OBLIGATION
We will use your personal information to comply with our legal requirements. For example: (i) to assist an industry authority investigation or public authority or criminal investigation body; (ii) to identify you when you contact us; and/or (iii) to verify the accuracy of data we hold about you.
Where there is a LEGITIMATE INTEREST
We may use and process your personal information where it is necessary for us to pursue our legitimate interests as a business, or that of a third party, for the following purposes:
- to undertake market analysis and research (including contacting you with surveys) so that we can better understand your needs and provide tailored and bespoke offers and services that we think you will be interested in;
- for service and product development purposes (for example to improve our services, offering and performance);
- in some cases we may use automated methods to analyse, combine and evaluate information that you have provided to us. We collect and analyse this information in this way so that we can deliver the most appropriate customer experience to you by tailoring and making relevant all our service and communications;
- for marketing activities (other than where we rely on your consent to contact you by email, phone or post) with information about our products and services or share your details with third parties to do the same, as explained above;
- to administer competitions and promotions that you enter with us from time to time and to distribute prizes;
- to contact you from time to time with marketing information (unless you object) if you have expressly indicated to us that you are acting on behalf of a business or where we have obtained your business contact details from a third party. In relation to any such information we send by email, we will include an option allowing you to object to receiving future messages by unsubscribing;
- to contact you with targeted advertising delivered online through social media and other platforms operated by other companies, unless you object. You may receive advertising based on information about you that we have provided to us or because, at our request, we have identified you as having similar attributes to the individuals whose details it has received from us. To find out more, please refer to the information provided in the help pages of the platforms on which you receive advertising from us;
- to analyse, evaluate and improve our services so that your engagement with us is more useful and enjoyable;
- for analysis to inform our marketing strategy, and to enhance and personalise your customer experience (including to improve the recommendations we make to you on our website);
- to correspond or communicate with you;
- to verify the accuracy of data that we hold about you and create a better understanding of you as a customer;
- for network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access;
- for prevention of fraud and other criminal activities;
- to comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request);
- for the management of queries, complaints, or claims;
- for the establishment and defence of our legal rights; and
- to inform you of updates to our terms and conditions and policies.
DATA ANONYMISATION AND USE OF AGGREGATED INFORMATION
Your information may be converted into statistical or aggregated data in such a way as to ensure that you are not identified or identifiable from it. Aggregated data cannot be linked back to you as a natural person. We may use this data for analytical and research purposes.
OTHERS WHO MAY RECEIVE OR HAVE ACCESS TO YOUR PERSONAL INFORMATION
Our suppliers and service providers
We may disclose your information to our third party service providers, agents, subcontractors and other organisations for the purposes of providing services to us or directly to you on our behalf. Such third parties may include cloud service providers (such as hosting and email providers), advertising media companies, photographers, printers, solicitors, accountants, advisors and administrative services.
When we use third party service providers, we only disclose to them any personal information that is necessary for them to provide their service and we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions.
Other ways we may share your personal information
We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation. We may also transfer your personal information if we’re under a duty to disclose or share it in order to comply with any legal obligation, to detect or report a crime, to enforce or apply the terms of our contracts or to protect the rights, property or safety of our visitors and customers. We will always take steps with the aim of ensuring that your privacy rights continue to be protected.
WHERE WE STORE YOUR PERSONAL INFORMATION
All information you provide to us is stored on our secure servers which are located within the European Economic Area (EEA).
If at any time we transfer your personal information to, or store it in, countries located outside of the EEA (for example, if our hosting services provider changes) we will ensure that appropriate safeguards are in place for that transfer and storage as required by applicable law. This is because some countries outside of the EEA do not have adequate data protection laws equivalent to those in the EEA.
If you use our services whilst you are outside the EEA, your information may be transferred outside the EEA in order to provide you with those services.
HOW LONG WE KEEP YOUR PERSONAL INFORMATION FOR
Option 1 – High level description of retention
If we collect your personal information, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws. We do not retain personal information in an identifiable format for longer than is necessary.
We may need your personal information to establish, bring or defend legal claims. For this purpose, we will always retain your personal information for 7 years after the date it is no longer needed by us for any of the purposes listed under How we use your personal information above. The only exceptions to this are where:
- the law requires us to hold your personal information for a longer period, or delete it sooner;
- you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law (see furtherErasing your personal information or restricting its processing below); or
- in limited cases, the law permits us to keep your personal information indefinitely provided we put certain protections in place.
OUR WEBSITE – SECURITY AND LINKS TO OTHER SITES
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information when and if transmitted to our website and, accordingly, any transmission is at your own risk. Once we have received your personal information, we put in place reasonable and appropriate controls to ensure that it remains secure against accidental or unlawful destruction, loss, alteration, or unauthorised access.
Our website may contain links to other websites run by other organisations. This statement does not apply to those other websites‚ so we encourage you to read their privacy statements. We cannot be responsible for the privacy policies and practices of other websites even if you access them using links that we provide. In addition, if you linked to our website from a third party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party website and recommend that you check the policy of that third party website.
We may collect your preferences to receive marketing information directly from us by email, post and phone in the following ways:
- if you make a sales enquiry, either by phone, via our website or via email or any other method, or place / enter into a contract with us, we may contact you with marketing information in the ways mentioned in the notices presented to you, except where you indicate you would prefer otherwise.
- if we meet you at an event and you give us your contact information or invite us to make contact with you, we may contact you by one of the methods you have given to us to share marketing information.
From time to time, we may ask you to refresh your marketing preferences by asking you to confirm that you consent to continue receiving marketing information from us.
We may contact you with marketing information by post or by telephone or with targeted advertising delivered online through social media and platforms operated by other companies by using your personal information, or use your personal information to tailor marketing to improve its relevance to you, unless you object.
You have a number of rights in relation to your personal information under data protection law. In relation to certain rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal information. Except in rare cases, we will respond to you within one month from either (i) the date that we have confirmed your identity or (ii) where we do not need to do this because we already have this information, from the date we received your request.
Accessing your personal information
You have the right to ask for a copy of the information that we hold about you by emailing or writing to us at the address at the end of this policy. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.
Correcting and updating your personal information
The accuracy of your information is important to us and we are working on ways to make it easier for you to review and correct the information that we hold about you. In the meantime, if you change your name or address/email address, or you discover that any of the other information we hold is inaccurate or out of date, please let us know by contacting us in any of the details described at the end of this policy.
Withdrawing your consent
Where we rely on your consent as the legal basis for processing your personal information, as set out under How we use your personal information, you may withdraw your consent at any time by contacting us using the details at the end of this policy. If you would like to withdraw your consent to receiving any direct marketing to which you previously opted-in, you can do so using our unsubscribe tool. If you withdraw your consent, our use of your personal information before you withdraw is still lawful.
Objecting to our use of your personal information and automated decisions made about you
Where we rely on your legitimate business interests as the legal basis for processing your personal information for any purpose(s), as under How we use your personal information, you may object to us using your personal information for these purposes by emailing or writing to us at the address at the end of this policy. Except for the purposes for which we are sure we can continue to process your personal information, we will temporarily stop processing your personal information in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your data for those purposes. Otherwise we will provide you with our justification as to why we need to continue using your data. You may object to us using your personal information for direct marketing purposes and we will automatically comply with your request. If you would like to do so, please use our unsubscribe tool.
Erasing your personal information or restricting its processing
In certain circumstances, you may ask for your personal information to be removed from our systems by emailing or writing to us at the address at the end of this policy. Unless there is a reason that the law allows us to use your personal information for longer, we will make reasonable efforts to comply with your request.
You may also ask us to restrict processing your personal information where you believe it is unlawful for us to do so, you have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings. In these situations we may only process your personal information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings.
Transferring your personal information in a structured data file (“data portability”)
Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with your contract, as set out under How we use your personal information, you may ask us to provide you with a copy of that information in a structured data file. We will provide this to you electronically in a structured, commonly used and machine readable form, such as a CSV file.
You can ask us to send your personal information directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.
Complaining to the UK data protection regulator
You have the right to complain to the Information Commissioner’s Office (ICO) if you are concerned about the way we have processed your personal information. Please visit the ICO’s website for further details.
CHANGES TO THIS POLICY
We may review this policy from time to time and any changes will be notified to you by posting an updated version on our website. Any changes will take effect 7 days after the date on which we post the modified terms on our website, whichever is the earlier. We recommend you regularly check for changes and review this policy whenever you visit our website. If you do not agree with any aspect of the updated policy you must immediately notify us and cease using our services.
Please direct any queries about this policy or about the way we process your personal information to our Data Protection Champion using our contact details below.
If you wish to write to us, please write to the address given at the start of this policy.
Our email address for data protection queries is [email protected].
If you would prefer to speak to us by phone, please call +44 (0)7949188923.