• We will only ever ask for what we really need to know.
• We will collect and use the personal data that you share with us transparently, honestly and fairly.
• We will always respect your choices around the data that you share with us and the communication channels that you ask us to use.
• We will put appropriate security measures in place to protect the personal data that you share.
• We will never sell your data.
1. WHO ARE WE?
Cloudscape Media Limited, is a registered company, registered on August 20, 2009 with Companies House in the UK, as Company Number 06996888.
We are also registered with the Information Commissioner’s Office (the ICO) with registration number, ZA751906.
We may change this Policy from time to time so please check this page occasionally to ensure that you’re happy with any changes. By using our website, you’re agreeing to be bound by this Policy.
The provision of your personal data to us is voluntary. However, without providing us with your personal data, you may be unable to (as appropriate) take an action, like receive information from us.
We may use your information to:
• tell you about Frank Renton on Brass or to answer a query that you have sent to us
• to carry out our obligations arising from any contracts entered into by you and us;
• to process your subscription and to inform you about new content on Frank Renton on Brass;
• seek your views or comments on our work;
• notify you of changes to our organisation;
• send you communications which you have requested and that may be of interest to you.
• process a job application.
2. WHAT INFORMATION DO WE COLLECT?
The type and amount of information we collect depends on why you are providing it.
We will usually ask you for your name and contact details, including physical address, telephone number and e-mail address.
However, we may request other information where it is appropriate and relevant. This additional information might include:
(1) Details of why you have decided to contact us or details of topics/areas of interest to you,
(2) information about your computer and about your visits to and use of this website including your IP address, geographical location, browser type, referral source, length of visit and number of page views;
(3) information about the services you use, services and products of interest to you or any marketing and/or communication preferences you give; and/or
(4) if you are a job applicant the information you are asked to provide is as set out in the application and necessary for the purposes of considering the application.
(5) any other information shared with us in relation to the different purposes set out at clause 1.
Do we process sensitive personal information? Applicable law recognises certain categories of personal information as sensitive and therefore requiring more protection, including health information, ethnicity and political opinions. In limited cases, we may collect sensitive personal data about you. We would only collect sensitive personal data if there is a clear reason for doing so; and will only do so with your explicit consent.
3. COMMUNICATIONS AND MARKETING
Where you have provided us with your physical address, we may contact you by post; and where you have provided appropriate consent, also by telephone and e-mail, with targeted communications to let you know about our activities that we consider may be of particular interest; about the work of Frank Renton on Brass.
4. THIRD-PARTY SERVICE PROVIDERS
We may pass your information to our third-party service providers, agents subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (for example to send you mailings).
These third parties have access to your Personal Information only to perform these specific tasks on our behalf and are obligated not to disclose or use it for any other purpose.
5. CHILDREN’S DATA
We do not knowingly process data of any person under the age of 16. If we come to discover, or have reason to believe, that you are 15 and under and we are holding your personal information, we will delete that information within a reasonable period and withhold our services accordingly.
Where possible and appropriate Cloudscape Media/Frank Renton on Brass will seek consent from a parent or guardian before collecting information about children. When children participate in our events or work, it is in accordance with our safeguarding policy.
6. OTHER DISCLOSURES
We will disclose your Personal Information where required to do so by law or in accordance with an order of a court of competent jurisdiction, or if we believe that such action is necessary to comply with the law and the reasonable requests of law enforcement or to protect the security or integrity of our Service.
7. INTERNATIONAL TRANSFER
Your information, including Personal Information, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. This is because we work with trusted suppliers, for example our email marketing platform, which is Mailchimp, or our email provider who are Google and their gmail service.
If you are located outside the United Kingdom and choose to provide information to us, please note that we transfer the information, including Personal Information, to the United Kingdom and process it there.
In the event that a dispute arises with regards to the international transfer of data, you agree that the courts of England and Wales shall have exclusive jurisdiction over the matter.
8. SECURITY OF AND ACCESS TO YOUR PERSONAL DATA
We endeavour to ensure that there are appropriate and proportionate technical and organisational measures to prevent the loss, destruction, misuse, alteration, unauthorised disclosure or of access to your personal information.
Your information is only accessible by appropriately trained staff, volunteers and contractors.
The security of your Personal Information is important to us but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security. As such we make no warranties as to the level of security afforded to your data, except that we will always act in accordance with the relevant UK and EU legislation.
9. YOUR RIGHTS AND HOW CONSENT WORKS
You have a choice about whether or not you wish to receive information from us.
Where we rely on your consent to use your personal information, you have the right to withdraw that consent at any time. This includes the right to ask us to stop using your personal information for direct marketing purposes or to be unsubscribed from our email list at any time. You also have the following rights:
• (1) Right to be informed – you have the right to be told how your personal information will be used. This Policy and other policies and statements used on our website and in our communications are intended to provide you with a clear and transparent description of how your personal information may be used.
• (2) Right of access – you can write to us to ask for confirmation of what information we hold on you and to request a copy of that information. Provided we are satisfied that you are entitled to see the information requested and we have successfully confirmed your identity, we have 40 days to comply. As from 25 May 2018, we will have 30 days to comply.
• (3) Right of erasure – you can ask us for your personal information to be deleted from our records. In many cases we would propose to suppress further communications with you, rather than delete it.
• (4) Right of rectification – if you believe our records of your personal information are inaccurate, you have the right to ask for those records to be updated.
• (5) Right to restrict processing – you have the right to ask for processing of your personal data to be restricted if there is disagreement about its accuracy or legitimate usage.
• (6) Right to data portability – to the extent required by the General Data Protection Regulations (“GDPR”) where we are processing your personal information (i) under your consent, (ii) because such processing is necessary for the performance of a contract to which you are party or to take steps at your request prior to entering into a contact or (iii) by automated means, you may ask us to provide it to you – or another service provider – in a machine-readable format.
To exercise these rights, please send a description of the personal information in question using the contact details in section 15 below.
Where we consider that the information with which you have provided us does not enable us to identify the personal information in question, we may ask you for (i) personal identification and/or (ii) further information.
Please note that some of these rights only apply in limited circumstances. For more information, we suggest that you consult ICO guidance – https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
You are further entitled to make a complaint about us or the way we have processed your data to the Information Commissioner’s Office (“ICO”). For further information on how to exercise this right, please see the guidance at https://ico.org.uk/for-the-public/personal-information. The contact details of the ICO can be found here: https://ico.org.uk/global/contact-us.
10. LAWFUL PROCESSING
We are required to have one or more lawful grounds to process your personal information. Only 4 of these are relevant to us:
• (1) Consent: We will ask for your consent to use your information to send you electronic communications such as newsletters and marketing emails, for targeted advertising, and if you ever share sensitive personal information with us.
• (2) Contractual relationships: Most of our interactions with subscribers and website users are voluntary and not contractual. However, sometimes it will be necessary to process personal information so that we can enter contractual relationships with people. For example, if you apply for employment or to volunteer with us, or if you purchase something via our online shop if we have one.
• (3) Legal obligations: Sometimes we will be obliged to process your personal information due to legal obligations which are binding on us. We will only ever do so when strictly necessary.
• (4) Legitimate interests: Applicable law allows personal information to be collected and used if it is reasonably necessary for our legitimate activities (as long as its use is fair, balanced and does not unduly impact individuals’ rights).
We will rely on this ground to process your personal data when it is not practical or appropriate to ask for consent.
When we use your personal information, we will consider if it is fair and balanced to do so and if it is within your reasonable expectations. We will balance your rights and our legitimate interests to ensure that we use your personal information in ways that are not unduly intrusive or unfair in other ways.
11. DATA RETENTION
In general, unless still required in connection with the purpose(s) for which it was collected and/or is processed, we remove your personal information from our records five years after the date it was collected. However, if before that date (i) your personal information is no longer required in connection with such purpose(s), (ii) we are no longer lawfully entitled to process it or (iii) you ask us to delete it we will remove it from our records at the relevant time.
In the event that you ask us to stop sending you direct marketing/other electronic communications, we will keep your name on our internal suppression list to ensure that you are not contacted again.
We review our retention periods for personal information on a regular basis (see item 12 of this Privacy Statement). You can request to remove your personal information at any time by emailing us using the details in Section 16 below.
12. POLICY AMENDMENTS
13. THIRD PARTY WEBSITES
14. UPDATING INFORMATION
You can check the personal data we hold about you, and ask us to update it where necessary. Please contact us via the details in Section 16 of this Policy.
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Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
We are not required by law to have a “Data Protection Officer”, however we have a Data Protection Manager.
Please let us know if you have any queries or concerns whatsoever about the way in which your data is being processed by emailing the Data Protection Manager at email@example.com
or by writing to Cloudscape Media via our registered address:
c/o Colin Meager & Co Limited, 8 Caroline Point, 62 Caroline Street, Jewellery Quarter, Birmingham, England, B3 1UF