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PRIVACY NOTICE

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This version is effective from: 10th June 2021

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This Privacy Notice (“Privacy Notice”) sets out how Kreate Many Limited processes your personal data in connection with our business, including in relation to our websites at https://www.kreate.co.uk/ and https://kreate.staffed.it (together our “Site”) and the marketing campaign and staffing services that we provide to the brands that we work for (“Services”).

 

This Privacy Notice applies to Site visitors and others that we interact with in connection with our Services, including personnel of our clients and suppliers, and Field Workers that we engage to perform our Services (which doesn’t include our employees). To find out more please see the “Who we collect personal data about” section.

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We will update this Privacy Notice from time to time to reflect any changes or proposed changes to our use of your personal data, or to comply with changes in applicable law or regulatory requirements. We may notify you by email of any significant changes to this Privacy Notice, but we encourage you to review this Privacy Notice periodically to keep up to date on how we use your personal data.

Your access to and use of our Site, including your account page and any secure area, is subject at all times to our Website Terms of Use.

Purpose of this privacy notice

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This Privacy Notice explains our approach to any personal data that we might collect from you or which we have obtained about you from a third party, and the purposes for which we process your personal data. This Privacy Notice also sets out your rights in respect of our processing of your personal data.

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When we talk about “personal data”, we mean any information which relates to an identified or identifiable living individual. Individuals might be identified by reference to a name, an identification number, location data, an online identifier (such as an IP address) or to other factors that are specific to them, such as their physical appearance.

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This Privacy Notice is intended to inform and assist you in respect of your interactions with us. Please take a moment to read and understand it. It should be read in conjunction with our Website Terms of Use and our Cookie Notice.

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This Privacy Notice only applies to the use of your personal data obtained by us, whether from you directly or from a third party. It does not apply to personal data collected by third parties during your communications with those third parties or your use of their products or services (for example, where you follow links, we provide to third party websites over which we have no control, or you purchase goods or services from third parties that we refer you to).

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In addition, this Privacy Notice does not apply when we process personal data on behalf and under the instruction of our clients in connection with our Service, for example where one of our Field Workers collects your contact details at an event so that our clients can send their own marketing to you.

 

About Us 

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The Site and our Services are made available by Kreate Many Limited (“Kreate”, “we”, “us, “our”). Kreate is the data controller responsible for your personal data. Kreate is an English company (no.10357400) with its registered office at 3 The Mount, Trumpsgreen Road, Virginia Water, England, GU25 4EJ. 

How to contact us

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If you have any questions about this Privacy Notice or want to exercise your rights as a data subject set out in this Privacy Notice, you can contact us using the following methods:

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  • On Site.  Contact us using the Contact Form on our Site. 

  • Email. Send us an email at: hello@kreate.co.uk. 

  • Post. Write to us at: Rivington Studios, 1 Bath Place, London EC2A 3DR.

 

What personal data we collect

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In providing our Site and our Services, we may collect and process different types of personal data about you for different processing purposes. The types of personal data we collect depends on who you are and how you use our Site and our Services and includes the following (as applicable):

 

  • Identity Data

    • First name; last name; job title; and organisation that you represent

  • Registration Data

    • First name; last name; email address; and password.

  • Contact Data 

    • Home, work and/or billing addresses; email address; telephone number(s); and social media handles.

  • Profile Data

    • Date of birth; gender; country of residence; nationality; details of your eligibility to work (including documents and information that we may collect to verify this); your work preferences (including areas and dates where you are available for work); your attributes (including physical attributes, such as your height and t-shirt size), skills, qualifications, training and work history; photographs of you; any personal data which appears in your curriculum vitae or application; and any personal data that you volunteer during an interview or your interactions with us.

  • Performance Data

    • Any information that we collect in connection with your work as a Field Worker, including any recording (including video recordings, photographs and any other recording on any other medium) of your work that we create in connection with our Services and any feedback that we receive from our clients or the public in respect of your work.

  • Communications Data

    • The content of any emails or other communications that you send to us.

  • Financial Data

    • Bank account details.

  • Transaction Data

    • Details about payments made between you and us (or paymentsthat we make to the organisation that we engage you through); details of Services provided by us to our clients. 

  • Targeting Data

    • Data relating to your behaviours, interests and preferences, including data collected as a result of your browsing activity and/or interaction with our Site and/or our emails which is obtained through the use of cookies, pixel tags and other similar technologies; information about when your current or previous sessions started.

  • Technical Data

    • IP address; browser type and operating system; geolocation, to ensure we’re showing you the correct notices and information; any other unique numbers assigned to a device.

  • Marketing Data 

    • Details of any marketing preferences that you have communicated to us.

 

How we collect and receive personal data

 

We collect and receive personal data using different methods:

  • Personal data you provide to us 

    • You may give us your personal data directly, for example, when you contact us with enquiries, complete forms on our Site, subscribe to receive our marketing communications or provide feedback to us.

  • Personal data we collect using cookies and other similar technologies

    • When you access and use our Site, we will collect certain Targeting Data and Technical Data. We collect this personal data by using cookies and other similar technologies (see the “Insight, analysis and retargeting through Cookies” section).

  • Personal data received from third parties

    • We may receive personal data about you from third parties. Such third parties may include analytics providers, data brokers, third party directories and third parties that provide technical services to us so that we can provide our Site and our Services.

  • Publicly available personal data

    • From time to time, we may collect personal data about you (Identity Data, Contact Data or Profile Data) that is contained in publicly available sources (including open source data sets or media reports) or that you or a third party may otherwise make publicly available (for example through speeches at events or publishing articles or other news stories or posts on social media platforms).

 

Who we collect personal data about

 

We collect and process personal data from the following people:

  • Site visitors

    • If you browse our Site we will collect and process your personal data in connection with your interaction with us and our Site.

  • People who contact us

    • If you contact us with an enquiry, to provide us with feedback, or to market services to us, including through the contact page on our Site, we will collect and process your personal data in connection with your communication.

  • People who work for our clients and suppliers

    • If you work for one of our clients or suppliers and have responsibility for placing orders with us, administering your organisation’s account with us, or handling our orders or our account with your organisation, we will process your personal data in connection with your organisation’s relationship with us.

  • Visitors to our office and other locations that we use

    • If you attend our offices or other locations (including in relation to any event that we host), we may process personal data that you volunteer in connection with your visit and any enquiries you make. For example, you may volunteer personal data when asking us to assist you in finding accommodation or transportation suitable for your needs, or when signing in as a guest. CCTV footage may also be collected for security purposes. We may also ask you to complete a registration or feedback form, or other document relating to the event or purpose for which you are visiting us.

  • Field Workers

    • If you register to be one of our Field Workers in connection with the services that we provide to our clients, we will process your personal data in order to process your registration and, if you are engaged, to notify you of work opportunities.

  • Job applicants

    • If you apply for formal employment or other type of permanent or semi-permanent position with us, whether through the Site or otherwise, we will collect and process your personal data in connection with your application.

 

How we use your personal data 

 

We use your personal data for the purposes set out in this section. If we wish to make any changes to these purposes, or if we wish to use your personal data for any purpose that is not listed in this section, we will notify you using the contact details we hold for you.

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To register and manage our Field Workers in connection with our Services

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  • To assess your application to be registered as a Field Worker and to update and manage your profile and registration

    • We use Field Workers to help provide our Services by performing a variety of roles, such as demonstrating newly launched products, being part of PR stunts or working at high profile events. These roles are not permanent roles.

    • If you use our registration form to make an application to be registered as a Field Worker, we will ask you to provide your Registration Data to create an account on our staff portal.

    • Once you have created your account, you will be asked to complete your application by providing us with Profile Data. 

    • After you have completed your application, you can use your Registration Data to login to the staff portal to provide additional Profile Data that we did not request as part of the registration process. If you do not provide this, we may ask you for it later when inviting you to work on campaigns or events (see below). If you do not provide this data, you may not be able to work on the relevant campaign or event.  

    • As soon as possible after completing your application, we will contact you using your Contact Details to arrange an interview, and we will use the information that you have provided to assess your application to be registered as a Field Worker. 

    • We will also use your Profile Data and Performance Data on an ongoing basis to assess your continued suitability to be registered as a Field Worker.

    • If we do not consider you to be suitable to be registered as a Field Worker, we will notify you and terminate your registration as a Field Worker.

    • Our legal basis for processing;  It is in our legitimate interest to use your personal data in such a way to assess your application to be a Field Worker. Where you provide any special category data (such as data concerning your health) to us as part of your application, it is necessary for us to process this to ensure that we are meeting our duty of care to you (i.e. to ensure that any work opportunities that we present you with are suitable and do not put you at unnecessary risk) and to defend against any potential legal claim that may be issued against us. 

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  • To assess the suitability of our Field Workers for the campaigns and events that we work on in connection with our Services and to invite Field Workers to work on suitable campaigns and events

    • The nature of the Services that we provide to our clients varies, and some Field Workers are better suited to certain campaigns and events than others. For example, we may run an event that requires Field Workers that have experience working with children or who have experience with bar tendering.

    • Where you are registered as a Field Worker, we will assess your Profile Data and any Performance Data to see whether we think you would be a good fit for the campaign or event that we are working on.

    • If we think you are suitable to work on a campaign or event, we will use your Contact Details to invite you work on the campaign or event via email and/or SMS.      

    • Our legal basis for processing;  It is in our legitimate interest to use your personal data in such a way to determine your suitability for campaigns and events. Where this involves the use of any special category data (such as data concerning your health), it is necessary for us to process this to ensure that we are meeting our duty of care to you (for example, if we are aware that you have a nut allergy, we will exclude you from campaigns and events that involve the serving of nuts) and to defend against any potential legal claim that may be issued against us.

  • To provide our clients with the benefit of your work as a Field Worker in connection with our Services 

    • We may collect (and in some cases our clients may collect and provide to us) Performance Data in connection with your work as a Field Worker, which we will use to deliver our Services to our client. For example, we may take video recordings or photographs of you performing your work which we deliver to our clients for their own use.

    • Our legal basis for processing;  It is necessary for us to use your Profile Data to perform our obligations in accordance with any contract that we may have with you, or it is otherwise in our and/or our client’s legitimate interest to use your personal data in such a way to provide our Services to the best of our ability and in accordance with the obligations that we owe to our clients.

  • To pay you and to maintain records of work that you have provided

    • We will use your Financial Data, which we will need you to provide via the staff portal, and share it with the organisation that you are engaged through in order to pay you for the campaigns and events that you work on.

    • In addition, we will maintain details of the campaigns and events that you have worked on, and Transaction Data in relation to those campaigns and events, for record-keeping purposes. 

    • Our legal basis for processing;  It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you, or it is otherwise in our legitimate interest to process your personal information for this purpose.

  • To manage your access to the staff portal and to contact you in connection with your account and your work

    • Once you have registered as a Field Worker, we will process your Registration Data to authenticate your access to our staff portal. We will also process certain Technical Data to maintain the security of the secure areas of our Site.

    • If there are any technical issues that we need to resolve or we otherwise need to get in touch with you in connection with your work for us (for example, if we need to contact you to arrange delivery of clothing that you need to wear for a campaign) we will use your Contact Details to get in touch with you to try to resolve these. 

    • Our legal basis for processing: It is in our legitimate interest to use personal data in such a way to ensure that we provide access to the staff portal in a secure

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  • If you browse our Site

    • When you browse our Site, we collect and process Targeting Data and Technical Data to help us understand how you are using and navigating our Site. We do this so that we can better understand which parts of our Site are more or less popular and to improve the contents, structure and navigation of our Site. 

    • Our legal basis for processing: It is in our legitimate interest to use personal data in such a way to ensure that we provide access to our Site in a secure and effective way and so that we can make improvements to our Site.

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  • If you contact us through our Site

    • We will collect and use personal data about you when you use the Contact Form on our Site. We may process your Identity Data, Contact Data, Technical Data and any other data that you volunteer in connection with your enquiry. 

    • Our legal basis for processing: It is in our legitimate interest to use personal data in such a way to ensure that we can respond to your enquiries, provide access to our Site in a secure and effective way and make improvements to our Site.

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  • If you link to social media sites and interact with our social media pages

    • If you interact with our social media pages such as on Facebook or Instagram (including interacting with any ‘like’ or similar embedded features on our Site or social media accounts), we and the relevant social media platform may receive information relating to such interaction and may share your personal data in connection with this purpose, such as certain Targeting Data and Technical Data. For more information about how we use this personal data, please see the “Insight, analysis and retargeting through Cookies” section.

    • The relevant social media platform may also be a controller in respect of the personal data that is collected via your use of our social media pages and may use that personal data for additional purposes. For details of how the relevant social media platform uses your personal data, please see the privacy policy of the relevant social media platform.

    • Our legal basis for processing:  It is in our legitimate interest to use personal data in the ways described above to ensure that we provide the Site in an effective way and to promote our Site via social media.

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  • To resolve technical issues concerning our Site

    • If you have a technical issue concerning our Site, we may collect and process Technical Data and any other information that you provide to us to help us diagnose and resolve the technical issues you are experiencing in an efficient way.

    • Our legal basis for processing: It is in our legitimate interest to ensure that our Site is operating effectively.

 

 

Fulfilment of our Services

 

  • Fulfilment of our Services

    • Where you are personnel of or otherwise represent one of our brand clients, we collect and maintain personal data that you provide to us or that we otherwise receive in connection with the Services that we provide. We will use this for the purpose of supplying our Services. 

    • The personal data we process may include your Contact Data Financial Data and Transaction Data (where applicable and to the extent that this constitutes your personal data). We process this information so that we can fulfil the supply of Services and for record-keeping purposes. 

    • If you attend one of our offices, we will process personal data about you that we receive in connection with your visit or any enquiries that you have. This will usually include your Contact Data, and any other personal data you volunteer. 

    • Note, our Services are also subject to separate terms and conditions between us and our clients.

    • Our legal basis for processing:  It is in our legitimate interest to use personal data in such a way to ensure that we provide the Services and manage your visit to our office in an effective, safe and efficient way.

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  • Managing our relationships and communicating with our clients and potential clients

    • When you make an enquiry (whether via email, telephone or otherwise) or we communicate with you in relation to our Services and/or our client relationship, we will collect and process your Identity Data, Contact Data and, if applicable, Transaction Data, as well as any other relevant personal data you volunteer or that we otherwise receive. We use this information to respond to your enquiry and to manage the relationships that we have with our clients. 

    • We may also record (including voice recordings of telephone conversations) and use the information referred to above to train our personnel so that they can effectively deal with enquiries.

    • Our legal basis for processing: It is in our legitimate interest to use your personal data in the ways described above to ensure that we are able to help you with your enquiry, provide a good standard of service and improve our client relationships.

 

Surveys and feedback

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  • If you complete our surveys or provide feedback on your experience of our Services

    • From time to time, we will invite you to provide feedback about us and/or our Services in the form of surveys. We will collect and process your Identity Data, Contact Data and, if applicable, certain Transaction Data, as well as any other personal data you choose to volunteer in your survey response or other feedback. 

    • We use this information to help us to monitor and improve our Services and to train our personnel.

    • You can also get in touch with us to voluntarily provide feedback. Please see the “How to Contact Us” section for details of how to contact us.

    • Our legal basis for processing: It is in our legitimate interest to use the personal data provided by you so that we can improve our Services and provide them in an effective way.

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Hosting and managing events 

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  • If you sign up for and/or attend one of our events

    • From time to time, we may organise and host events for the purpose of promoting our business or for charitable causes or other reasons. We may process your Identity Data and Contact Data to communicate with you about such events where you have specifically requested information about such events or where we have another lawful basis for sending that information to you. 

    • If you attend one of our events, we may use your Identity Data and Contact Data to record your attendance at the event and for related record-keeping purposes and, if relevant, we may collect and process any dietary requirements you may have. You may also feature in photographs taken at our events and such photographs may appear in publications that we make available.

    • Our legal basis for processing: It is necessary for us to use your personal data in this way to perform our obligations in accordance with any contract that we may have with you where you have signed up to attend an event, or it is in our legitimate interest or a third party’s legitimate interest to use personal data in such a way to ensure that the event is operated in an effective way.

    • We may specifically ask your permission to use your photographs, quotes, testimonials, or other content that you make available or publish at the event. Where this is the case, our processing of your such personal data will be based on consent.

 

Prize draws, prize competitions and other promotions

 

  • If you participate in one of our promotions

    • From time to time, we may run prize draws, prize competitions and other promotions on our Site and/or on our social media accounts. For the purposes of administering such promotions, we may process your Identity Data, Contact Data, Transaction Data, Technical Data and any other personal data volunteered by you or that we ask for in relation to your promotion entry. 

    • Our legal basis for processing: It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you (e.g. the promotion terms and conditions) or it is in our legitimate interest to use your personal data to enable us to administer our promotion fairly and effectively and to ensure that we comply with self-regulatory codes governing the operation of promotions.

 

Insight, analysis and retargeting through Cookies

 

  • We use cookies to help us understand more about you and your use of our Site and our Services and to market our Services 

    • We and our third-party partners use cookies, web beacons, pixel tags and other similar technologies (which we generically refer to as “Cookies”) to collect data from the devices that you use to access our Site and any emails that you receive from us. The data that is collected includes Targeting Data and Technical Data. Please see our Cookie Notice for further information, including details of our third-party partners.

    • We and our third-party partners use this data to analyse how you use our Site and the effectiveness of our Site and our emails, including:

      • for the purposes described in the “If we carry out any online personalised advertising”, “If we advertise to you on social media and other platforms”, and the “If we advertise to other people who share similar interests and characteristics to you” sections;

      • to analyse how you use, and the effectiveness of, our Site and our emails;

      • to count users who have visited our Site or opened an email and collect other types of information, including insights about visitor browsing habits, which helps us to improve our Site and Services and the effectiveness of our emails;

      • to measure the effectiveness of our content;

      • to learn what parts of our Site are most popular and what kind of features and functionalities our visitors like to see; 

      • to help us understand the type of content that is most likely to appeal to our visitors and clients; and

      • to help us improve our Services and design our website;

      • to remember your preferences.

    • In some of our email messages, we use a “click-through URL” linked to certain websites administered by us or on our behalf. We may track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications.

    • Our legal basis for processing:  Where your data is collected through the use of non-essential cookies, we rely on consent to collect your personal data and for the onward processing purpose. Please see our Cookie Notice for further details.

 

Advertising and marketing to our clients and prospective clients

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  • If we send our clients or prospective clients marketing communications by post and/or email/SMS

    • We use your Identity Data, Contact Data and Marketing Data (if any) to send you (or the organisation you represent) marketing communications by post and/or email/SMS. Our marketing will include press releases and information about us, our Site, our Services, any events we may hold and the offers and promotions we offer from time to time.

    • Our marketing communications will include personalised and non-personalised marketing. Personalised marketing has been specifically tailored to you and will include content that we think is most relevant to you, based on what we know about you. Non-personalised marketing is marketing that is not tailored to you. 

    • Where we are sending you personalised marketing, we may also use Transaction Data and Targeting Data to help us decide what sort of personalised marketing to send you (please see the “Insight, analysis and retargeting through Cookies” section for more details).

    • Our legal basis for processing; 

      • It is in our legitimate interest to use your personal data for marketing purposes, for example to decide what marketing content we think may appeal to you. 

      • It is in our legitimate interest to use your personal data to send our marketing to you by post.  I

      • t is in our legitimate interest to use your personal data to send our marketing to you by email and/or SMS, except where we are required by applicable law to obtain your consent in which case, we will only send marketing communications to you by email and/or SMS where you have consented to receive such communications.

  • If we carry out any online personalised advertising

    • We and our third party partners may use your Targeting Data and Technical Data and other data that is collected through your interactions with third party websites and services to provide you with, and analyse the effectiveness of, personalised ads when you visit other websites and/or use other services (including the social media and other platforms described in the ““If we advertise to you on social media and other platforms” section).

    • By “personalised ads”, we mean advertisements for services that you have shown an interest in when you have used our Site or which we or our partners otherwise think you might be interested in based on your browsing habits. Note, our third-party partners may also use the data that is collected to show personalised ads for products and services offered by third parties.

    • Our legal basis for processing:  

      • Please see the “Insight, analysis and retargeting through Cookies” section to learn about the legal basis that we rely on to collect data via the use of Cookies.

      • Where we use your personal data to display online personal advertising to you, we rely on the consent that you have provided in respect of the collection of such data, or it is otherwise in our legitimate interests to promote our Site and our Services to you.

      • Our third-party partners may rely on a different lawful basis in respect of their use of your personal data. Please read the privacy notice of the relevant third-party provider, as set out in our Cookie Notice.

  • If we advertise to you on social media and other platforms

    • We share your email address (usually in an encrypted or ‘hashed’ form) with third-party providers of social media platforms and other services, such as Facebook and other similar platforms (“Social Platforms”), so that the third-party providers can try to “match” your data with the data of their registered users of their Social Platforms. 

    • Where there is a successful match, we will display our advertising to you when you use the relevant Social Platform (e.g. on your Facebook newsfeed). This is known as “custom audience” advertising, because we “customise” the audience that we want to reach on the relevant service.

    • Some of the advertising that you see may be personalised to you. The data that we use to personalise our advertising, such as your Targeting Data, will not be provided to the third-party providers of the Social Platforms. Please see the “Insight, analysis and retargeting through Cookies” section to learn more about how we personalise advertising to you. 

    • This activity is also subject to the privacy choices you have elected to make on such Social Platforms.

    • Our legal basis for processing

      • We will only share your personal data with the third-party providers of the Social Platforms, so that we can advertise our Services to you when you use those Social Platforms, where you have provided your consent or where it is otherwise in our legitimate interests to do so in order to promote our Site and our Services.

      • Where this activity is undertaken through the use of Cookies (please see the “Insight, analysis and retargeting through Cookies” section) to learn about the legal basis that we rely on. 

      • You can opt-out of our sharing of your personal information with the third-party providers by exercising your rights as a data subject as set out below.

  • If we advertise to other people who share similar interests and characteristics to you

    • We will provide your personal data to third-party providers of Social Platforms as described in the “If we advertise to you on social media and other platforms” and the “Insight, analysis and retargeting through Cookies” sections. If you are a user of those third-party Social Platforms, we may ask the third-party providers of those Social Platforms to find other registered users of their services who share similar interests and characteristics to you, which will be based on information that the third party holds about you and its other registered users.

    • This is known as “lookalike” audience advertising because we are trying to show our advertising to people who “look like” you. 

    • Please note that such activity is also subject to the privacy choices you have elected to make on such third-party services.

    • Our legal basis for processing

      • Please see the “If we advertise to you on social media and other platforms” section for details of the lawful basis that we rely on to share your personal data with the Social Platforms. 

      • It is in our legitimate interests to further use your personal data to advertise our Services to other individuals that use those Social Platforms and who share similar interests and characteristics with you. 

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Recruitment

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  • If we use your personal data in connection with our recruitment activities (other than recruitment of Field Workers

    • ​We use your personal data for recruitment purposes, in particular, to assess your suitability for any of our positions that you apply for, whether such application has been received by us online, by email or by hard copy and whether submitted directly by you or by a third-party recruitment agency on your behalf. We also use your Identity Data and Contact Data to communicate with you about the recruitment process, to keep records about our recruitment process and to comply with our legal and regulatory obligations in relation to recruitment. 

    • We will process any personal data about you that you volunteer, including during any interview, when you apply for a position with us. We may also process your personal data obtained from any third parties we work with in relation to our recruitment activities, including without limitation, recruitment agencies, background check providers, credit reference agencies and your referees.

    • The personal data we process may include your Identity Data, Contact Data, and Profile Data, or any personal data which is contained in any reference about you that we receive. Such information may also include special categories of personal data (such as information about your health, any medical conditions and your health and sickness records) and information relating to criminal convictions and offences if that information is relevant to the role you are applying for.

    • We also use your personal data for the purposes of reviewing our equal opportunity profile in accordance with applicable legislation. We do not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability or any other basis covered by local legislation. All employment-related decisions are made entirely on merit.

    • Our legal basis for processing

      • Where we use your personal data in connection with recruitment, it will be in connection with us taking steps at your request to enter into a contract we may have with you or it is in our legitimate interest to use personal data in such a way to ensure that we can make the best recruitment decisions. 

      • We will not process any special (or sensitive) categories of personal data or personal data relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.

 

Receipt of products and services from our suppliers.

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  • If we have engaged you or the organisation you represent to provide us with products or services

    • If we have engaged you or the organisation you represent to provide us with products or services (for example, if you or the organisation you represent provide us with services such as IT support or financial advice), we will collect and process your personal data in order to manage our relationship with you or the organisation you represent, to receive products and services from you or the organisation you represent and, where relevant, to provide our Services to others. The personal data we collect from you may include your Identity Data and Contact Data and any other personal data you volunteer which is relevant to our relationship with you or the organisation you represent.

    • Our legal basis for processin; It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you or the organisation you represent, or it is in our legitimate interest to use personal data in such a way to ensure that we have an effective working relationship with you or the organisation you represent and are able to receive the products and services that you or your organisation provides, and provide our Services to others, in an effective way.

 

Security

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  • If we need to use your personal data in connection with the administration of our security measures

    • We have security measures in place at our premises, including CCTV and building access controls. There are signs in place showing that CCTV is in operation. The images captured are securely stored and only accessed on a need to know basis (e.g. to look into an incident). CCTV recordings are typically automatically overwritten after a short period of time unless an issue is identified that requires investigation (such as a theft).

    • We may require visitors to our premises to sign in on arrival and, where that is the case, we will keep a record of visitors for a short period of time. Our visitor records are securely stored and only accessible on a need-to-know basis (e.g. to look into an incident).

    • Our legal basis for processing:  It is in our legitimate interests to process your personal data so that we can keep our premises secure and provide a safe environment for our personnel and visitors to our premises.

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Business administration and legal compliance

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  • If we need to use your personal data to comply with our legal obligations or in connection with the administration of our business

    • We may use your personal data: (i) to comply with our legal obligations; (ii) to enforce our legal rights or defend potential legal claims; (iii) to protect the rights of third parties; and (iv) in connection with a business transition such as a merger, reorganisation, acquisition by another company, or sale of any of our assets.

    • Our legal basis for processing

      • Where we use your personal data in connection with a business transition, to enforce our legal rights or to protect the rights of third parties, it is in our legitimate interest to do so. For all other purposes described in this section, we have a legal obligation to use your personal data to comply with any legal obligations imposed upon us, such as a court order.

      • We will not process any special (or sensitive) categories of personal data or personal data relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.

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If you fail to provide your personal data

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Where we need to collect your personal data, or we need to collect your personal data in connection with any contract we have with you or your organisation, and you fail to provide that personal data when we request it, we may not be able to perform any contract that we have or are trying to enter into or you or your organisation may be prevented from working with us. This may apply where you do not provide the personal data, we need in order to process an application to register as a Field Worker, to assess your suitability for a campaign or event. In these circumstances, we may have to cancel your application or cease working with you, in which case we will notify you.

 

How we obtain your consent

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Where our use of your personal data requires consent, you can provide such consent at the time we collect your personal data following the instructions provided, or by informing us using the contact details set out in the “How to Contact Us” section. 

 

Third-party links

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This Privacy Notice only applies to personal data processed by us through your use of our Site and/or in connection with our business operations. However, from time to time, our Site may contain links to third-party websites and services. We have no control over these websites and services and this Privacy Notice does not apply to your interaction with the relevant third parties.

When you use a link to go from our Site to another website (even if you don’t leave our Site) or you request a service from a third party, your browsing and interactions on any other websites, or your dealings with any other third-party service provider, is subject to that website’s or third-party service provider’s own rules and policies. For example, our Site invites you to connect with us on social media platforms such as Facebook and Instagram. When you click on the links we provide to such third-party platforms, you will be transferred from our Site to the relevant third-party platform and the privacy notice (and other terms and conditions) of that platform will apply to you.

We do not monitor, control or endorse the privacy practices of any third parties. We encourage you to become familiar with the privacy practices of every website you visit or third-party service provider that you use in connection with your interaction with us and to contact them if you have any questions about their respective privacy notices and practices.

 

Sharing personal data

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We only share personal data with others when we are legally permitted to do so. When we share personal data with others, we put contractual arrangements and security mechanisms in place to protect the personal data shared and to comply with our data protection, confidentiality and security standards and obligations.

 

When processing your personal data, we may need to share it with third parties (including other entities within our group of companies), as set out in the table below. This list is non-exhaustive and there may be circumstances where we need to share personal data with other third parties.

 

  • Third-party suppliers who provide applications/ functionality, data processing or IT services

    • We share personal data with third parties who support us in providing our Site and help provide, run and manage our internal IT systems. Such third parties may also include, for example, providers of information technology, cloud-based software-as-a-service providers, identity management, website design, hosting and management, data analysis, data back-up, security and storage services. The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal data may be stored in any one of them. We also share your personal data with third-party service providers to assist us with insight analytics. These providers are described in our Cookie Notice.

  • Payment providers and banks

    • We share personal data with third parties who assist us with the processing of payments and refunds.

  • Delivery and courier companies

    • We share personal data with suppliers who assist us in the delivery of our Services to our customers.

  • Advertising partners

    • We share personal data with third party advertising partners, including those set out in our Cookie Notice when you use our Site. This data is used to provide you with, and measure the effectiveness of, online personalised advertising and for other advertising related activities.

  • Third-party post/email marketing and CRM specialists

    • We share personal data with specialist suppliers who assist us in managing our marketing database and sending out our post and email marketing communications and account-related communications.

  • Third-party suppliers who assist us in administering our promotions

    • We share personal data with specialist suppliers who assist us in administering our prize draws, prize competitions and other promotions.

  • Event partners and suppliers

    • When we run events, we will share your personal data with third-party service providers that are assisting us with the operation and administration of that event. If we are running an event in partnership with other organisations, we will share your personal data with such organisations for use in relation to the event.

  • Hotel and transport operators and other travel-related businesses 

    • When you submit an enquiry to us about a hotel or transport provider, we will share your enquiry (including any personal data you volunteer) with that third party so that they can provide the information and assistance that you have requested.

  • Recruitment agencies and related organisations

    • We share personal data with external recruiters, third-party providers that undertake background checks on our behalf and other entities within our group of companies.

  • Auditors, lawyers, accountants and other professional advisers

    • We share personal data with professional services firms who advise and assist us in relation to the lawful and effective management of our organisation and in relation to any disputes we may become involved in.

  • Law enforcement or other government and regulatory agencies and bodies

    • We share personal data with law enforcement or other government and regulatory agencies or other third parties as required by, and in accordance with, applicable law or regulation.

  • Other third parties

    • Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, or to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.

 

Transfers outside the UK and the European Economic Area (“EEA”)

 

Where necessary in order to provide our Site and our Services, we will transfer personal data to countries outside the UK and the EEA. 

 

Non-EEA countries do not have the same data protection laws as the UK and the EEA. In particular, non-EEA countries may not provide the same degree of protection for your personal data, may not give you the same rights in relation to your personal data and may not have a data protection supervisory authority to help you if you have any concerns about the processing of your personal data. However, when transferring your personal data outside the UK or the EEA, we will comply with our legal and regulatory obligations in relation to your personal data, including having a lawful basis for transferring personal data and putting appropriate safeguards in place to ensure an adequate level of protection for the personal data. We will take reasonable steps to ensure the security of your personal data in accordance with applicable data protection laws.

 

When transferring your personal data outside the UK or the EEA, we will, where required by applicable law, implement at least one of the safeguards set out below. Please contact us if you would like further information on the specific mechanisms used by us when transferring your personal data outside the UK or the EEA. 

 

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How long we keep your personal data

 

We generally keep personal data for as long as we need it for the purposes described in this Privacy Notice.

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In respect of personal data that we process in connection with the supply of our Services, we may retain your personal data for up to seven years from the date of supply of the relevant Services and in compliance with our data protection obligations. We may then destroy such files without further notice or liability.

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Where we process personal data in connection with your registration as a Field Worker, we may retain your personal data for as long as you are registered as a Field Worker and for up to seven years from the date that you ceased to be Field Worker (and in compliance with our data protection obligations). We may then destroy such files without further notice or liability.

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Where we process any other personal data, we will generally retain relevant personal data for up to three years from the date of our last interaction with you (and in compliance with our data protect obligations). We may then destroy such files without further notice or liability. 

If any personal data is only useful for a short period (e.g. for a specific activity, promotion or event), we will not retain it for longer than the period for which it is used by us.

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If you have opted out of receiving marketing communications from us, we will need to retain certain personal data on a suppression list indefinitely so that we know not to send you further marketing communications in the future. However, we will not use this personal data to send you further marketing unless you subsequently opt back in to receive such marketing.

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Confidentiality and security of your personal data 

 

We are committed to keeping the personal data you provide to us secure and we have implemented information security policies, rules and technical measures to protect the personal data under our control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. In addition, all our employees and data processors (i.e. those who process your personal data on our behalf) are obliged to respect the confidentiality of the personal data of all users of our Site and those who purchase our Services.

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Personal data of minors

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Our Site is not intended for use by, or targeted at, minors (individuals under the age of 18) and we do not knowingly collect personal data of minors. However, this does not prevent minors from providing personal data to us. If we do collect personal data of minors, we will comply with all applicable laws and regulations relating to the processing of personal data of minors.

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Your rights as a data subject

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You have certain rights in relation to the personal data we hold about you. These rights include the right: (i) to obtain copies of your personal data; (ii) to have your personal data corrected or deleted; (iii) to limit the way in which your personal data is used; (iv) to object to our use of your personal data; (v) to transfer your personal data; (vi) not to be subject to decisions based on automated processing (including profiling); and (vii) to complain to a supervisory authority. If you would like to exercise any of these rights, please contact us using the details set out in the “How to Contact Us” section. 

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  • Your right of access 

    • If you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a copy of that personal data (along with certain other details). If you require additional copies, we may charge a reasonable fee for producing those additional copies.

  • Your right to rectification 

    • If the personal data we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have shared your personal data with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you who we’ve shared your personal data with so that you can contact them.

  • Your right to erasure 

    • You can ask us to delete or remove your personal data in some circumstances, such as where we no longer need it or where you withdraw your consent (where applicable). If we have shared your personal data with others, we will let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal data with so that you can contact them directly.

  • Your right to restrict processing 

    • You can ask us to “block” or suppress the processing of your personal data in certain circumstances such as where you contest the accuracy of that personal data or you object to us processing it for a particular purpose. This may not mean that we will stop storing your personal data but, where we do keep it, we will tell you if we remove any restriction that we have placed on your personal data to stop us processing it further. If we’ve shared your personal data with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal data with so that you can contact them directly.

  • Your right to data portability 

    • You have the right, in certain circumstances, to obtain personal data you have provided to us (in a structured, commonly used and machine-readable format) and to reuse it elsewhere or to ask us to transfer it to your chosen third party.

  • Your right to object

    • You can ask us to stop processing your personal data, and we will do so, if we are: (i) relying on our own or someone else’s legitimate interest to process your personal data, except if we can demonstrate compelling legal grounds for the processing; or (ii) processing your personal data for direct marketing purposes.

  • Your rights in relation to automated decision-making and profiling

    • You have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for the entering into, or the performance of, a contract between you and us.

  • Your right to withdraw consent

    • If we rely on your consent (or explicit consent) as our legal basis for processing your personal data, you have the right to withdraw that consent at any time. You can exercise your right of withdrawal by contacting us using our contact details in the “How to Contact Us” section or by using any other opt-out mechanism we may provide, such as an unsubscribe link in an email.

  • Your right to lodge a complaint with the supervisory authority 

    • If you have a concern about any aspect of our privacy practices, including the way we have handled your personal data, please contact us using the contact details provided in the “How to Contact Us” section. You can also report any issues or concerns to the Information Commissioner’s Office (“ICO”). Contact details for the ICO can be found on its website at https://ico.org.uk.

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