We collect, use and are responsible for certain Personal Information about you. When we do so we are subject to data protection laws applicable in the United Kingdom and we are responsible as ‘controller’ of that Personal Information for the purposes of those laws.
1. KEY TERMS
It would be helpful to start by explaining some key terms used in this policy:
We, us, our:
Foundation acting as part of Trace Studio Limited, a company registered in Scotland with registered address Floor 4a, Skypark, 5, 45 Finnieston St, Finnieston, Glasgow G3 8JU
(registered company number SC649987)
Any information relating to an identified of identifiable individual.
Sensitive personal information:
Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership.
2. PERSONAL INFORMATION WE COLLECT ABOUT YOU
We may collect and use the following Personal Information about you:
– Your name and contact information, including email address and telephone number.
– Information contained in any CV you submit to us.
– Information you submit to us in respect of business enquiries (e.g. contact information, including email address and telephone number).
– Information about how you use our website.
– in respect of our employees and/or contractors only: your date of birth, gender, marital status, immigration status, and next of kin; your qualifications and training records; your recruitment and employment history.
This Personal Information is required to inform you about the products and/or services we can or currently provide to you. Where you fail to provide that Personal Information 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 products and/or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. HOW YOUR PERSONAL INFORMATION IS COLLECTED
We collect most of this Personal Information directly from you, by telephone, text or email, social media and/or via our website and apps. However, we may also collect information:
– from publicly accessible sources, e.g. Companies House;
– directly from a third party, e.g. customer due diligence providers;
– via our IT systems, e.g. automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging system.
4. HOW AND WHY WE USE YOUR PERSONAL INFORMATION
Under data protection law, we can only use your Personal Information if we have a proper reason for doing so. In order to use your personal information, we rely on the following legal bases:
– processing is necessary for the performance of the products and/or services we provide to you;
– processing is necessary for the purposes of the legitimate business interests pursued by us (in particular, keeping our records up to date and carrying out statistical analysis to help us manage our business e.g. in relation to financial performance, client base and how our clients use our products/services); and
– in respect of our employees and/or contractors only: processing is necessary for the performance of our contract with you or to take steps at your request prior to entering into a contract with you, and is necessary to comply with our legal obligations (e.g. in relation to health and safety at work, monitoring equality and diversity, paying you and making NI contributions).
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by Contacting us.
We collect and process your personal information in order to:
– provide products and/or services to you;
– update customer records;
– prevent unauthorised access and modification to our systems; and
– in respect of our employees and/or contractors only, allow our managers, finance team and human resources to perform their everyday functions and administer your employment or engagement.
5. WHO WE SHARE YOUR PERSONAL INFORMATION WITH
From time to time we may share Personal Information with:
– third parties we use to help deliver our products and/or services to you;
– other third parties we use to help us run our business, e.g. marketing agencies or website hosts;
– where you are a contractor engaged to provide talent, our customers to whom we deliver products and/or services which feature you; and
– third parties approved by you.
If we use service providers to handle your Personal Information we will only do so if we are satisfied that they take appropriate measures to protect your Personal Information. We will also impose contractual obligations on service providers to ensure that they only use your Personal Information to provide services to us and to you.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some Personal Information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
We will not share your Personal Information with any other third party.
6. HOW LONG YOUR PERSONAL INFORMATION WILL BE KEPT
We will only retain your Personal Information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.
To determine the appropriate retention period for your Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements.
When it is no longer necessary to retain your Personal Information, we will delete it.
7. TRANSFERRING YOUR PERSONAL INFORMATION OUT OF THE EEA
We may transfer Personal Information that we collect from you to third party data processors, vendors or hosting partners acting on our behalf located in countries outside of the European Economic Area (“EEA”). We will only transfer your personal information outside the EEA where either the transfer is to a country which the EU Commission has decided ensures an adequate level of protection for your personal information, or we have put in place adequate safeguards as required by applicable data protection law.
If you would like further information please contact our Data Protection Officer (see ‘How to contact us’ below).
When creating and developing mobile applications (apps) for public consumption via the Google Play Store, they may require access to your device’s camera and image gallery as stated below:
– Camera Usage: These apps access the devise’s camera to display augmented reality.
-Image Gallery Usage: These apps access the image gallery to save app screenshots.
9. YOUR RIGHTS
You have the following rights, which you can exercise free of charge:
Access: The right to be provided with a copy of your Personal Information (the right of access)
Rectification: The right to require us to correct any mistakes in your Personal Information.
Erasure: The right to require us to delete your Personal Information—in certain situations.
Restriction of processing: The right to require us to restrict processing of your Personal Information—in certain circumstances, e.g. if you contest the accuracy of the data.
Data Portability: The right to receive the Personal Information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations.
The Right to Object:
—at any time to your Personal Information being processed for direct marketing (including profiling); or
—in certain other situations to our continued processing of your Personal Information, e.g. processing carried out for the purpose of our legitimate interests.
Not to be subject to automated decision making: The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.
Withdraw Consent: The right to withdraw your consent to us processing your Personal Information at any time if our processing is based on your consent.
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
– email or write to our Data Protection Officer—see below: ‘How to contact us’; and
– let us have enough information to identify you (e.g. your full name, address and any customer or matter reference number); and
– let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
– let us know what right you want to exercise and the information to which your request relates.
10. KEEPING YOUR PERSONAL INFORMATION SECURE
We have appropriate security measures to prevent Personal Information from being accidentally lost, or used or accessed unlawfully. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
11. HOW TO COMPLAIN
We hope that our Data Protection Officer can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
This privacy notice was published on 29/04/19 and last updated on 20/05/19.
We may change this privacy notice from time to time – when we do we will inform you via email.
13. HOW TO CONTACT US
Our contact details are shown below:
Trace Studio Limited
45 Finnieston St
Tel: 0330 122 2138
Data Protection Officer:
45 Finnieston St
Tel: 0330 122 2138