Last updated: 1 August 2020
https://www.puurcreative.com (‘Website’) is provided by Puur Creative Limited (‘we’/’us’/’our’). In doing so, we may be in a position to receive and process personal information relating to you. As the controller of this information, we’re providing this Privacy Notice (‘Notice’) to explain our approach to personal information. This Notice forms part of our terms and conditions, which governs the use of this Website.
We intend only to process personal information fairly and transparently as required by data protection law including the General Data Protection Regulation (GDPR). In particular, before obtaining information from you we intend to alert you to this Notice, let you know how we intend to process the information and (unless processing is necessary for at least one of the 5 reasons outlined in clause 2. below) we’ll only process the information if you consent to that processing. The GDPR also defines certain ‘special categories’ of personal information that’s considered more sensitive. These categories require a higher level of protection, as explained below.
Of course, you may browse parts of this Website without providing any information about yourself and without accepting cookies. In that case, it’s unlikely we’ll possess and process any information relating to you.
We’ll start this Notice by setting out the conditions we must satisfy before processing your data. However, you may wish to skip to clause 4., which summarises what we intend to collect. The Notice also explains some of the security measures we take to protect your personal information, and tells you certain things we will or won’t do. You should read this Notice in conjunction with the terms and conditions.
Sometimes, when you take a new service or product from us, or discuss taking a new service or product but decide against it, we might wish to provide you with further information about similar services or products by email or other written electronic communication. In that situation, we’ll always give you the opportunity to refuse to receive that further information and you can change your mind at any point (opt-out) by contacting our Data Protection Officer (DPO) as set in clause 1.4. We’ll endeavour to remind you of your right to opt-out on each occasion that we provide such information.
1.Identity and contact details
1.1 Registered number: 8165098
1.2 Registered office: 29 Southway, Colchester, Essex, CO2 7BA
1.4 Our Data Protection Officer (DPO) would welcome communication from you regarding any matter relating to data protection, and can be contacted by email at firstname.lastname@example.org.
2. When we’re allowed to collect information from you
We will only collect personal information relating to you if one of the following conditions have been satisfied:
2.1 You have clearly told us that you are content for us to collect that information for the certain purpose or purposes that we will have specified.
2.2 The processing is necessary for the performance a contract that we have with you.
2.3 The processing is necessary so that we can comply with the law.
2.4 The processing is necessary to protect someone’s life.
2.5 The processing is necessary for performance of a task that’s in the public interest.
2.6 The processing is necessary for our or another’s legitimate interest – but in this case, we’ll balance those interests against your interests.
3. How to consent
3.1 At the point of collecting the information, we’ll endeavour to explain how we intend to use the information and which of these purposes apply. If we rely on consent, we’ll provide you with the opportunity to tell us that you’re happy to provide the information.
3.2 If at any point in time you change your mind and decide that you don’t consent, please let us know and we’ll endeavour to stop processing your information in the specified manner, or we’ll delete your data if there is no continuing reason for possessing it.
3.3 If you don’t consent to a particular bit of processing, we’ll endeavour to ensure that the Website and our service continue to operate without the need for that information.
4. Information we expect to collect from you
4.1 We envisage asking for the following types of information from you:
4.1.1 Comment on articles or work
Lawful basis for processing: Consent given by data subject
Why are we doing this?: You have given your consent by checking the box on the ‘Leave a comment’ form
4.1.2 You fill out a form
When you submit a request through one of our ‘contact’ form on our site we collect your e-mail address, and comment. With the default configuration, the form plugin (Contact form 7), in itself, does not:
• track users by stealth;
• write any user personal data to the database;
• send any data to external servers;
Lawful basis for processing: Consent given by data subject
Why are we doing this?: You have given your consent by checking the box on the ‘email’ form
4.1.3 Google Analytics
Lawful basis for processing: Pursuance of our legitimate interests
Why are we doing this?: To allow us to analyse how visitors interaction with our site in order to improve our site and our services
4.2 We may collect personal information about you from a number of sources, including the following:
a. From you when you agree to take a service or product from us, in which case this may include your contact details, date of birth, how you will pay for the product or service and your bank details.
b. From you when you contact us with an enquiry or in response to a communication from us, in which case, this may tell us something about how you use our services.
c. From documents that are available to the public, such as the electoral register.
d. From third parties to whom you have provided information with your consent to pass it on to other organisations or persons – when we receive such information we will let you know as soon as is reasonably practicable.
4.3 If you refuse to provide information requested, then if that information is necessary for a service we provide to you we may need to stop providing that service.
4.4 At the time of collecting information, by whichever method is used, we’ll endeavour to alert you and inform you about our purposes and legal basis for processing that information, as well as whether we intend to share the information with anyone else or send it outside of the European Economic Area. If at any point you think we’ve invited you to provide information without explaining why, feel free to object and ask for our reasons.
5. Using your personal information
5.1 Data protection, privacy and security are important to us, and we shall only use your personal information for specified purposes and shall not keep such personal information longer than is necessary to fulfil these purposes. The following are examples of such purposes. We have also indicated below which GDPR justification applies, however it will depend on the circumstances of each case. At the time of collecting we will provide further information, and you may always ask for further information from us.
a. To help us to identify you when you contact us. This will normally be necessary for the performance our contract.
b. To help us to identify accounts, services and/or products which you could have from us or selected partners from time to time. We may do this by automatic means using a scoring system, which uses the personal information you’ve provided and/or any information we hold about you and personal information from third party agencies (including credit reference agencies). We will only use your information for this purpose if you agree to it.
c. To help us to administer and to contact you about improved administration of any accounts, services and products we have provided before, do provide now or will or may provide in the future. This will often be necessary, but sometimes the improvements will not be necessary in which case we will ask whether you agree.
d. To allow us to carry out marketing analysis and customer profiling (including with transactional information), conduct research, including creating statistical and testing information. This will sometimes require that you consent, but will sometimes be exempt as market research.