At Connected Creatives we are committed to protecting and respecting your privacy. This policy outlines details of the information that we collect, store and process, and the measures we take to protect and safeguard this information. Connected Creatives Ltd is a limited company registered in the UK (Company number 11079149) with registered address 83 Ducie Street, Manchester, England, M1 2JQ (“Connected Creatives”). We have created and own the platform called ‘Connected Creatives’. Connected Creatives is the ‘Data Controller’ under English Law and is responsible for the personal data we collect from you (or your child if you are consenting to the collation of personal data as your child’s parent or guardian). Connected Creatives is the controller and responsible for this website and we have appointed a data privacy manager who is responsible for answering any questions about this privacy policy. Please contact the data privacy manager in the following ways: Email address: support@connectedcreatives.co.uk Postal address: Ducie Street, Manchester, England, M1 2JQ You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows: Identity Data includes first name, last name, username or similar identifier, age and gender. Contact Data includes email address and telephone numbers. Financial Data includes bank account and payment card details. Transaction Data includes details about payments to and from you and other details of services you have purchased from us. Technical Data includes 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 this website. Profile Data includes your username and password, preferences and feedback and competition responses. Usage Data includes information about how you use our website. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. We collect personally identifying information from you in a number of ways though your use of our website. Broadly this breaks down into two categories:
Information you provide to us within the website Information obtained relating to the use of the website . If you fail to provide required personal data Where we need to collect personal data by law, or under the terms of the contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with access to the website). In this case, we may have to cancel your access to the website but we will notify you if this is the case at the time. When creating an account to use the website you will have to provide details of your name, email address and create a password for our website. This information is used to provide you with a username when you log in to your Connected Creatives account in order to keep the data you have provided to us secure. We will use your email address to send password reset and other account management communications. Connected Creatives gathers information about the way the website is used by users (including you) including which webpages are used and details inserted into input fields etc). We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: Where we need to perform the contract we are about to enter into or have entered into with you. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Where we need to comply with a legal obligation. Connected Creatives also gathers information relating to the network (IP) address of your computer / tablet / phone. This information is considered to be personally identifiable data and is processed to allow us to provide a reliable experience and to allow us to better secure and protect your personal information. Connected Creatives does not perform any automated decision making based upon any personal data. Our website may also use the Hotjar recording service. Hotjar may record mouse clicks, mouse movements, page scrolling and any text keyed into the website. Data collected by Hotjar is for Connected Creatives’ internal use only. The information collected is used to improve our website usability and is stored and used for reviewing website sessions. We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. 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 data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below. We only hold your data for as long as you have an active account, after which we will remove it Connected Creatives only retain data for as long as it is reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. This means data that you provide through the website is held for at least as long as you have an active account. We consider an account to be inactive if it has either not been logged into in the prior 12 months or if you or the school you attend has requested your account to be deleted. Prior to removal we will attempt to contact you to inform you of the account closure. In order to operate a reliable system and to avoid data loss we perform regular encrypted backups of the system. These backups are retained for up to 90 days, and after this time are removed. This means that a removed account will be completely removed from all our systems and backups 90 days after the removal date. We won’t share or sell your information or allow the use of your information for marketing, however we will share relevant information with our suppliers to help us deliver our services to you Connected Creatives will not sell or rent your information to third parties, and we do not share information for marketing purposes with any third parties Connected Creatives may share data with third party suppliers working on our behalf - this includes contractors, agents and other subcontractor who work for Connected Creatives to provide services and complete tasks for the delivery of our service. Where such a relationship is in place there are contractual safeguards in place to protect your information. Connected Creatives will only share data that is relevant to the tasks being completed and to the delivery of service to you, and where possible the data will be anonymised. None of these organisations and individuals are permitted to use the data for any other purpose. Connected Creatives has been designed with a privacy first development methodology meaning that we follow a rigorous development process which places the security of personal information at its core. To that end, we host our website using a GDPR compliant cloud data provider hosting the website in the UK. All of our services run over HTTPS using TLS ensuring data transmitted between the website and our servers is secure. Data you provide to us which is stored is encrypted when it is stored, and in any backups taken. We take lengths to ensure that the network environment in which the website is hosted is kept secure by following best practices and ensuring that security updates are applied in a timely fashion. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. We will not contact you for marketing purposes by email unless you have given your prior consent. You can change your marketing preferences at any time by contacting us (details set out above). The accuracy of your information is important to us. If you change email address, or any of the other information we hold is inaccurate or out of date and you cannot already change it in the website, please contact us (details set out above).. You have the right to ask for a copy of the information Connected Creatives holds about you. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object 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. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: If you want us to establish the data’s accuracy. Where our use of the data is unlawful but you do not want us to erase it. Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service we are providing to you. Like many other websites and apps, Connected Creatives uses cookies. Cookies are small pieces of information sent by an organisation to your computer or device and stored on your hard drive to allow that website to recognise you when you visit. They collect statistical data about your browsing actions and patterns and do not identify you as an individual. This helps us to improve our website and deliver a better, more personalised service. It is possible to switch off cookies by setting your browser preferences. For more information on how to switch off cookies on your computer, visit our full cookies policy. Turning cookies off may result in a loss of functionality when using our website. This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.] We regularly review our policies. This is the first version of the policy and was created in December 2018. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.Platform Privacy Policy
Who are we?
What information do we collect and how do we use it?
Information you provide through the website
Information about website usage
Why are we collecting your personal data?
Purpose/Activity
Type of data
Lawful basis for processing including basis of legitimate interest
To register you on our website
(a) Identity
(b) Contact
Performance of a contract with you
To process and deliver the website service including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review, provide feedback or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how our accountholders use our services)
To enable you to partake in a prize draw, competition or complete a survey
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how accountholders use our services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests (for 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)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for our legitimate interests (to study how accountholders use our 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, accountholders relationships and experiences
(a) Technical
(b) Usage
Necessary for our legitimate interests (to define types of accountholders 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
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications
Necessary for our legitimate interests (to develop our services and grow our business)
How long do we hold data for?
Who has access to your data?
How will we keep your data secure?
What are your rights to your data?
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Opting Out
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Review of Policy