Privacy Policy

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, Unit 1, Fairview Court, Fairview Road, Cheltenham GL52 2EX. Our VAT number is GB 208 5926 93.

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.

All UK companies are required to comply with the General Data Protection Regulations 2018 (GDPR) and we take our obligations in this regard seriously. We take appropriate measure to ensure we protect any data that we process.

The Craft holds and process information and data through our day-to-day activities. This policy (together with our terms and any other documents referred to within) 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.

Please read this policy carefully to understand our views and practices regarding your personal data and how we will treat it.

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.

How we collect personal data?

We may collect and process personal data in the ways:

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)

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

Publicly available sources

We may collect personal data from publicly availably sources such as Companies House and the Electoral Register and credit reference agencies, based inside the EU

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

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:

  • 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.

Marketing

Generally, you will only receive marketing communications from us:

  1. 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;
  2. you have provided your consent to receiving marketing and you have not subsequently withdrawn your consent; or
  3. if we have another basis to send you the marketing communications.

We will not share your personal data with third parties for their marketing purposes.

How to opt out

You have the right to withdraw your consent for us to retain and/or use your personal data for marketing purposes at any time. If you wish to withdraw your consent you should email us at mwisemansmith@thecraft.consulting 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.

Visitors to our website

So we can maintain security of our site we will collect information technical data.

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.

Some of our external third parties are based outside the European Economic Area (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 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;
  • we use specific contracts approved by the European Commission which give personal data the same protection it has in Europe with our services providers;
  • we may transfer data to US based service providers under the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

We will not pass on any personal data to third parties for their own use unless we are required to do so by law.

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.

We complete a full annual audit of this and are Cyber Essentials Plus Accredited.

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:

mwisemansmith@thecraft.consulting

with the subject heading ‘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.

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.

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

contact data

billing address, delivery address, email address and telephone number

financial data

bank account and payment card details

identity data

first name, maiden name, last name, username or similar identifier

marketing and communication data

your preferences in receiving marketing from us

profile data

your username and password, customer interactions made by you, your interests, preferences, feedback and survey responses

usage data

how you use our website, products and services

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

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:

consent

you have given your express consent for us to process your personal data for a specific purpose.

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.

legal obligation

the processing is necessary for us to comply with legal or regulatory obligation.

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.

Purpose/Activity

Type of data

Lawful basis for processing

to register you as a new customer

identity & contact

to perform our contract with you

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.

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.

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

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

to use data analytics to 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

to make suggestions and recommendations to you about goods or services that may be of interest to you, including promotional offers

identity, contact, technical, usage & profile

as necessary for our legitimate interests to develop our products/services and grow our business

Part 3: Your legal rights

You have the following legal rights in relation to your personal data:

access your data

you can ask for access to and a copy of your personal data and can check we are lawfully processing it

correction

you can ask us to correct any incomplete or inaccurate personal data we hold about you

erasure

you can ask us to delete or remove your personal data where:

  1. there is no good reason for us continuing to process it;
  2. you have successfully exercised your right to object (see below);
  3. we may have processed your information unlawfully; or
  4. we are required to erase your personal data to comply with local law.

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.

object

you can object to the processing of your personal data where:

  1. where we are relying on our legitimate interest (or those of a third party) as the basis for processing your personal data, if you feel it impacts on your fundamental rights and freedoms;
  2. where we are processing your personal data for direct marketing purposes.

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.

restrict processing

you can ask us to us to suspend or restrict the processing of your personal data, if:

  1. you want us to establish the accuracy of your personal data;
  2. our use of your personal data is unlawful, but you do not want us to erase it;
  3. you need us to hold your personal data (where we no longer require it) as you need it to establish, exercise or defend legal claims; or
  4. you have objected to our use of your personal data, but we need to verify whether we have overriding legitimate grounds to use it.

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.

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.

Part 4: Third Parties

service providers

acting as processors based the EAA and US who provide IT and system administration services

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

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

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

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

controller

a body that determines the purposes and means of processing personal data

data subject

an individual living person identified by personal data (which will generally be you)

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

processor

a body that is responsible for processing personal data on behalf of a controller.

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.

ICO

Information Commissioner’s Office, the UK supervisory authority for data protection issues.