(February 2022)
Our website address is: https://thecraft.consulting.
Who is The Craft?
The Craft Consulting Limited (The Craft, us, our, we) is a strategic consultancy agency, registered in England and Wales under company number 09439145. The Craft’s registered office is The Craft Consulting, 60 Great Portland Street, London, United Kingdom, W1W 7RT. Our VAT number is GB 208 5926 93. The controller of your personal data is Agent3 Limited (company number 08331678).
Privacy at The Craft
Our actions and policies are at all times founded on our common sense approach to working with people and managing processes. In handling personal data, our focus will remain on ensuring we comply with applicable privacy requirements.
When we collect, use and otherwise process personal data about you, we are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to services we offer and our wider operations in the European Economic Area (EEA). We may also be subject to other data protection laws where we provide services outside of both the UK and the EEA.
The Craft holds and process information and data through our day-to-day activities, through the services we offer you and your use of our website, and where we collect and process personal information about you in order to provide services to you and our clients]. This policy sets out the basis on which any personal data we collect from you or a third party, or that you provide to us, will be processed by us.
We have appointed an outsourced Data Protection Officer (DPO) and if you have any questions or concerns about the information on this page, or about what we do with personal data, or otherwise wish to contact the DPO, please email us for the attention of the DPO at dpo-hub@next15.com, or write to us at the above address, for the attention of the DPO.
What personal data do we collect?
We may collect, use, store and transfer the types of personal data about you listed in Part 1 of Schedule 1.
We may also collect, use and share aggregated data. However, if we combine aggregated data with your personal data so that it can directly or indirectly identify you, we treat this as your personal data.
We do not collect any special categories of personal data or any information about criminal convictions and offences.
Given the nature of our website and our services, we do not expect to collect the personal data of anyone under 18 years old. If you are aware that any personal data of anyone under 18 years old has been shared with us please let us know so that we can delete that data.
How we collect personal data?
We may collect and process personal data in the ways:
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Direct interactions |
You may provide personal data when you complete online forms, request products/services, subscribe to our services, download content, join our mailing list, or otherwise or correspond with us (by post, phone or email) |
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Automated technology |
We automatically collect personal data (technical and usage) when you browse or interact with our website, by using cookies, server logs and other similar technologies. Please see our cookie policy for further details |
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Publicly available sources |
We may collect personal data from publicly availably sources such as Companies House and the Electoral Register, free-to-access business aggregation based sites (for example, Crunchbase.com and theorg.com), news sites that discuss B2B topics and include mentions of individuals, events sites that list speakers and attendees] and credit reference agencies. We may also collect personal data which is publicly available from social media, for example LinkedIn, Twitter and Facebook. |
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Third parties |
We may receive personal data from: (a) analytics providers based outside the EU (such as Google); (b) advertising networks based inside the EU; and (c) our suppliers such as payment providers, delivery services, website support and maintenance providers; and (d) our clients who may pass us personal data of individuals about whom they wish us to contact. We may also purchase personal data from third party providers to facilitate contact with you in connection with the services we offer as a legitimate business interest of ourselves and our customers. |
How we use personal data?
We will only use your personal data when the law allows us to. Most commonly we will use your personal data:
- where you have given your Consent;
- to perform the contract we are to enter into or have entered into with you;
- to comply with a legal obligation; or
- where it is necessary to carry out our legitimate interests (or those of a third party) and your interests are fundamental rights do not override those interests.
Part 2 of Schedule 1 sets out further details on the lawful basis we will rely on to process your personal data.
Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your information, but at all times we will abide by the rules set out by the GDPR to which we subscribe. If at any time we are required to use your personal data for purposes other than the original intention we shall inform you before doing so.
We may process your personal data (without your knowledge or consent) where this is required or permitted by law.
SHARING AND COLLECTING DATA WITHIN OUR GROUP
We may share your personal data with our parent company, Next Fifteen Communications Group PLC, because it operates a number of our “back office” functions for us, and with our and their technology suppliers (to the extent necessary for them to perform their functions).
We will also share/collect this information across our Agent3 group (including to Berne UK LTD and its UK affiliates and their brands (i.e. OneNineFive and TechOctopus) and Agent3. for the purposes of management between the group and to provide services to our client within the group.
We also operate a group-wide Customer Relationship Manager (CRM) which allows us to organise and optimise our client relationships. Each of our company group members has access to this CRM. Any personal data which is inserted or otherwise uploaded into the CRM will, therefore, be accessible by our company group, but only for legitimate business purposes such as administrative functions, or to leverage existing relationships to offer complimentary services or additional services offered by our wider group.
MARKETING
Generally, you will only receive marketing communications from us:
- if you have purchased services or products from us and have not opted out of receiving marketing at the time we collected your data or unsubscribed;
- you have provided your consent to receiving marketing and you have not subsequently withdrawn your consent; or
- if we have another lawful basis to send you the marketing communications (for example to carry out our legitimate interests as a business).
We will not share your personal data with third parties for their marketing purposes.
HOW TO OPT OUT
You have the right to You have the right to object and/or withdraw your consent for us to retain and/or use your personal data for marketing purposes at any time. If you wish to object and/or withdraw your consent you should email us at dpo-hub@next15.com with a clear instruction for us to remove you from our mailing list.
Even if you opt out of receiving marketing, we may still use your personal data for other purposes provided we have a lawful basis to do so.
Data Retention
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 business, legal, 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. However, we may be legally required to keep certain information (including contact, identity, financial and transaction data) for specific time periods in line with legal requirements.
We may also anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes. We can use anonymised information indefinitely without further notice to you.
Job applicants
From the point that an individual or a third party (such as a recruitment agency) submits an application to be an employee of The Craft we may use their personal data to:
- Enable the job application process and potential future employment
- We may use employment applicant data to monitor our recruitment practices and processes or for related HR statistics at any time, this data will be anonymised if retained for future reference purposes.
- We will store your data in our People system and other relevant systems that are provided by third parties. We ensure all of our providers have privacy policies and processes to comply with current regulations in regards to Data Privacy and Protection.
- Enable any investigation or process connected to or requested by law or law enforcement.
If you don’t provide the personal data when we ask for it we may not be able to process your application or contact you in relation to your application. If you have any concerns about whether you need to provide the personal data please contact us (see ‘How to contact us’ below).
Visitors to our website
We will collect personal data, including technical data so we can maintain security of our site.
To improve usage of our site we collect data through google analytics; this is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
Every time someone visits our website we use ‘cookies’ to collect information. You can view our Cookie policy here.
Where we store & process your data
We may have to share your personal data with third parties further details of which are set out in Part 4 of Schedule 1. 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. They can only process your personal data for specified purposes and in accordance with our instructions.
The EEA, UK and other countries outside the EEA and the UK have differing data protection laws, some of which may provide lower levels of protection of privacy. Due to the global nature of our business It is sometimes necessary for us to share your personal data to countries outside the UK and EEA. In those cases we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data.
For example, we may transfer your personal data to:
- clients who are based in other markets;
- systems and platforms, which store data in other jurisdictions; and
- our global group companies to facilitate our business activities.
Under UK and EU data protection laws, we can only transfer your personal data to a country outside the UK/EEA where there is a transfer mechanism approved by the UK government or the European Commission, or where there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you, or where a specific exception applies under relevant data protection law.
If you would like further details about these data transfers please contact us using the details set out above.
Security
Data security is important to us. Once we have received information, we will use clear internal policies and procedures and, where appropriate, security features.
In order to prevent unauthorised access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect.
Access to your personal data
To find out if The Craft holds information about you, or to make a request to access the information you know we hold about you; please put the request in writing via email to:
dpo-hub@next15.com with the subject heading ‘The Craft, Data Access Request’ so we can deal with your request as quickly as possible and within the applicable timeframe as required by law. If your request is particularly complex or you have made a number of requests it may take longer than normal to comply with. In this case, we will notify you and keep you updated.
You will not have to pay a fee to exercise any of your rights. However, if your request is clearly unfounded, repetitive or excessive, we may charge a reasonable fee for this information or refuse to comply with your request.
We may request specific information from you to help us confirm your identity when you contact us. This is a security measure to ensure that personal data is not disclosed to any person who does not have the right to receive it.
Further details about your rights are set out in Part 3 of Schedule 1 for where you are (i) in the United Kingdom, Switzerland, the European Economic Area and Canada; and where you are (ii) in California.
At The Craft we take every step we can to ensure that the information we hold about you is correct, but if you feel that The Craft holds incorrect information about you, please write or email us as soon as possible and we will correct any information found to be inaccurate.
Right to complain
Please contact us if you have any queries or concerns about our use of your information (see above contact information). We hope we will be able to resolve any issues you may have.
If your personal data is subject to UK or EU data protection laws, then you have the right to lodge a complaint about our handling of your personal data with your local supervisory authority, although we do ask that you raise any concerns with us first as we can probably address them much more efficiently.
In the United Kingdom, the Information Commissioner’s Office is your local supervisory authority. The UK’s Information Commissioner may be contacted at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113. You can find a list of the supervisory authorities for EU member states here [Link to https://edpb.europa.eu/about-edpb/board/members_en].
About this Privacy Notice
Our website may contain links to third party websites, plug-ins and applications. This Privacy Notice does not cover such websites, plug-ins or applications and by clicking on these links or enabling connections you may be allowing third parties to collect or share your personal data. We recommend that you also read the privacy notices on other websites you visit.
This Privacy Notice was last updated in July 2018. We reserve the right to make changes to this policy at any time in order to ensure it remains relevant, accurate and compliant with law.
This notice is an overview of The Craft’s responsibilities in holding and processing personal data. For further information about your rights under the GDPR, please visit the Information Commissioner’s Website
Schedule 1
Part 1: Types of personal data
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contact data |
billing address, delivery address, email address and telephone number |
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financial data |
bank account and payment card details |
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identity data |
first name, maiden name, last name, username or similar identifier |
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Educational and background data |
education, professional certifications, job titles where this is included on a job application you may submit to us |
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marketing and communication data |
your preferences in receiving marketing from us |
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profile data |
your username and password, customer interactions made by you, your interests, preferences, feedback and survey responses |
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usage data |
how you use our website, products and services |
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technical data |
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 our website |
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transaction data |
details about payments to and from you and other details of products and services you have purchased from us |
Part 2: Lawful basis for processing and processing activities
The lawful basis upon which we may rely on to process your personal data are:
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consent |
you have given your express consent for us to process your personal data for a specific purpose. |
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contract |
the processing is necessary for us to perform our contractual obligations with you under our contract, or because you have asked us to take specific steps before entering into a contract with you. |
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legal obligation |
the processing is necessary for us to comply with legal or regulatory obligation. |
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legitimate interests |
the processing is necessary for our or a third party’s legitimate interest e.g. in order for us to provide the best service to you via our website. Before we process your personal data on this basis we make sure we consider and balance any potential impact on you, and we will not use your personal data on this basis where such impact outweighs our interest. |
Set out below are specific details of the processing activities we undertake with your personal data and the lawful basis for doing this.
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Purpose/Activity |
Type of data |
Lawful basis for processing |
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to register you as a new customer |
identity & contact |
to perform our contract with you |
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to process and deliver your order, manage payments, fees and charges and debt recovery |
identity, contact, financial, transaction and marketing & communications |
(i) to perform our contract with you; (ii) as necessary for our legitimate interest in recovering debts due to us. |
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to manage our relationship with you, notifying you about changes to our terms or Privacy Notice |
identity, contact, profile & marketing & communications |
(i) to perform our contract with you (ii) as necessary to comply with a legal obligation (iii) as necessary for our legitimate interests in keeping our records updated and analysing how customers use our products/services. |
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to administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
identity, contact & technical |
(i) as necessary for our legitimate interests in running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise (ii) as necessary to comply with any legal obligations |
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to deliver relevant website content/advertisements to you and measure or understand the effectiveness of our advertising |
identity, contact, profile, usage, marketing & communications & technical |
as necessary for our legitimate interests in studying how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy |
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to use data analytics to manage and improve our website, products/services, marketing, customer relationships and experiences |
technical & usage |
as necessary for our legitimate interests to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy |
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to make suggestions and recommendations to you about goods or services that may be of interest to you, including promotional offers. To connect you with brands with that you have expressed interest in receiving marketing content related to their product |
identity, contact, technical, usage & profile |
consent as necessary for our legitimate interests to develop our products/services and grow our business |
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to manage the recruitment process with you if you apply for a job with us, including to verify your identity, undertake checks. |
Identity & contact |
as necessary for our legitimate interests for the purposes of recruitment or where you have provided your consent |
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to operate and maintain our group wide CRM, allowing us to optimise our client relationships. |
identity, contact, profile & marketing & communications |
only for legitimate business purposes such as administrative functions, or to leverage existing relationships to offer complimentary services or additional services offered by our wider group |
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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) |
identity, contact , technical & transaction |
as necessary for our legitimate interests to respond and comply with to a request from you |
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to contact you if there are any urgent safety notices to communicate to you or where we otherwise reasonably believe that the processing of your personal information will prevent or reduce any potential harm to you. |
identity, contact & technical |
in your vital interests |
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to assist any public authority or criminal investigation body. To identify you when you contact us, |
identity, contact & technical |
for compliance with a legal requirement |
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for the establishment and defence of our legal rights |
identity, contact, profile, usage, marketing & communications & technical |
for our legitimate interests in defending a claim made against us, or members of our group by you |
Part 3: Your legal rights
You have the following legal rights in relation to your personal data:
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Your rights and how to exercise them – individuals in the United Kingdom, Switzerland, the European Economic Area and Canada: |
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access your data |
you can ask for access to and a copy of your personal data and can check we are lawfully processing it |
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correction |
you can ask us to correct any incomplete or inaccurate personal data we hold about you |
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erasure |
you can ask us to delete or remove your personal data where:
We may not always be able to comply with your request for specific legal reasons, which will be notified to you at the time of your request. |
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object |
you can object to the processing of your personal data where:
In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms and in such circumstances, we can continue to process your persona data for such purposes. |
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restrict processing |
you can ask us to us to suspend or restrict the processing of your personal data, if:
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request a transfer |
you can request a transfer of your personal data which is held in an automated manner and which you provided your consent for us to process such personal data or which we need to process to perform our contact with you, to you or a third party. We will provide your personal data in a structured, commonly used, machine-readable format. |
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withdraw your consent |
you can withdraw your consent at any time (where we are relying on consent to process your personal data). This does not affect the lawfulness of any processing carried out before you withdraw your consent. |
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How to exercise your rights: The easiest method of exercising your rights is to:
write to us at The Craft, 75 Bermondsey Street, London, SE1 3XF, United Kingdom, marked for the attention of the Data Protection Officer. In order to protect your privacy, we may ask you to prove your identity before we take any steps in response to a request you have made. |
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Your rights and how to exercise them – individuals in California If your personal data (called “personally identifiable information” for the purposes of California law) is subject to California law, then you have certain rights under the California Consumer Privacy Act (CCPA). |
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Opt-out of sale |
With some exceptions, California residents have the right to opt out of any sale of their personal information. You may enforce this right by clicking this link: https://www2.agent3.com/ccpa/“Do Not Sell My Personal Information”. You may also contact us at +1 510-394-2713. California residents may designate authorized agents to make such requests on their behalf. We must wait at least 12 months before asking you to opt back in to the sale of your personal information, where you have previously opted-out. |
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Disclosure (“right to know”) |
With some exceptions, California residents may request that we disclose to you what personal information we have collected, used, shared or sold about you, and why we collected, used, shared or sold that information. You may obtain this information from us free of charge. The information provided will be for the 12-month period preceding your request. |
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Deletion |
In some limited circumstances, you have the right to have personal data that we hold about you erased. This right is not generally available where we still have a valid legal reason to keep the data (for example, for fraud prevention or because we are obliged to do so by law). |
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Non-discrimination |
We cannot deny services, charge you a different price, or provide a different level or quality of services just because you exercised your rights under the CCPA. However, if you refuse to provide your personal information to us or ask us to delete or stop selling your personal information, and that personal information or sale is necessary for us to provide you with services, we may not be able to complete that transaction. |
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How to exercise your rights: The easiest method of exercising your rights is to:
In order to protect your privacy, we may ask you to prove your identity before we take any steps in response to a request you have made. |
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Part 4: Third Parties
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service providers |
acting as processors based the EAA and US who provide IT and system administration services |
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professional advisors |
acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services |
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HM Revenue & Customs, regulators and other authorities |
acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances |
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third parties |
third parties 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 |
Part 5 Glossary
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aggregated data |
information such as statistical or demographic data which may be derived from personal data but which cannot by itself identify a data subject |
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controller |
a body that determines the purposes and means of processing personal data |
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data subject |
an individual living person identified by personal data (which will generally be you) |
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personal data |
information identifying a data subject from that data alone or with other data we may hold but it does not include anonymised or aggregated data |
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processor |
a body that is responsible for processing personal data on behalf of a controller. |
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special categories of personal data |
information about race, ethnicity political opinions, religious or philosophical beliefs, trade union membership, health, genetic, biometric data, sex life, sexual orientation. |
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ICO |
Information Commissioner’s Office, the UK supervisory authority for data protection issues. |
