What is this Policy about?
The following capitalised terms shall have the following meanings:
“Anonymous Data” means Personal Data that has been amended to the extent that it no longer contains any identifying information and thus, no longer constitutes Personal Data.
“Customer” means any of Our customers.
“Data Controller” means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any Personal Data are, or are to be, processed as outlined in the Data Protection Legislation.
“Data Processor” means any natural or legal person who processes the data on behalf of the Data Controller.
“Data Protection Legislation” all applicable data protection and privacy legislation in force from time to time in the UK including the General Data Protection Regulation ((EU) 2016/679); the Data Protection Act 2018; the Privacy and Electronic Communications Directive 2002/58/EC (as updated by Directive 2009/136/EC) and the Privacy and Electronic Communications Regulations 2003 (SI 2003/2426) as amended.
“Personal Data” has the meaning given to it in the Data Protection Legislation.
“Products” means the products We provide to Customers.
“Services” means the provision of the Products by Us to a Customer.
“User” means any user of the Website and/or Services, including without limitation, any Customer.
“Website” means www.emmastevenson.co.uk.
What is the purpose of this policy?
Who is the data controller?
EMCStevenson is a Data Controller in respect of certain Personal Data provided by Customers.
EMCStevenson have appointed various Data Processors who will process Personal Data relating to Customers on behalf of EMCStevenson and in the manner dictated by EMCStevenson.
How do we make changes to this policy?
It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if any aspect of your Personal Data changes during your relationship with us. Any previous data held on you will be deleted to the fullest extent possible.
Interacting with third party links
The Website may include links to third-party websites, plug-ins and applications. Clicking on any of these links or enabling those connections may allow third parties not associated with Us to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.
What personal data do we collect?
We may collect, use, store and transfer different kinds of Personal Data about you, which include but are not limited to, the following categories:
Contact Data: means data that includes your contact information, such as: your email address, phone number, home address (if you are an individual) and office address (if you are a corporate client).
Financial Data: means data that includes your financial details, such as your bank account information and payment card details.
Identity Data: means data that includes your name and information contained in identification data documents required for proof of identity and proof of address.
Marketing and Communications Data: includes your preferences in receiving marketing communications from us and/or our third parties and what are your communication preferences. You are able to opt out or marketing communications by clicking the opt out link in any marketing email.
Transaction Data: means data that includes details about any payments to and from you and the details of the Products and/or Services you have purchased from us.
Technical Data: may include internet protocol (IP) addresses you may have visited, the type and version of browser you are using, the time zone setting and location from which you are accessing the Website, browser plug-in types and versions, which operating system and Website are being used and other technology on the devices you use to access the Website.
Usage Data: includes information about how you use the Website and our Services such as the full uniform resource locations (URL) clickstream to, through and from the Website (including date and time), pages you viewed or searched for, page response times, download errors, length of visits of certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
We may also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data (which has been collected and processed lawfully) but is not considered to constitute Personal Data under the Data Protection Legislation. This is because the data does not directly or indirectly reveal your identity.
Other than Background Check Data and Location Data, we do not collect any “Special Categories of Personal Data” about you. Special categories mean the kinds of data recognised by the Data Protection Legislation as being more sensitive in nature than Personal Data. This includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your genetic and biometric data.
What happens if you don't provide personal data?
Where We need to collect Personal Data by law, or under the terms of a 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 goods or the 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 of contracting.
For the avoidance of doubt, We accept no liability for any losses arising from their inability to fulfil any contractual requirement as a result of your failure to provide the data required.
How do we collect your personal data?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact, Account, Financial and Marketing and Communications Data by engaging us for the provision of Services or by corresponding with us by post, phone, email, via our Website or otherwise. This includes Personal Data you provide when you:
- use of our Services; or
- signing up to our newsletter;
- request for marketing material to be sent to you; or
- request for more information related to our Services to be sent to you; or
- give us some feedback.
- Automated technologies or interactions. As you interact with us via our Website, we may automatically collect Technical Data about your equipment, browsing actions and pattern through mediums such as recording systems, cookies, server logs and other similar technologies. We collect this Personal Data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
- Technical Data from the following parties:
- analytics providers (such as Google Analytics);
- providers of technical, payment and delivery services.
- search information providers (such as Google); and
- advertising networks (such as Google and Facebook);
- Identity and Contact Data from publicly availably sources such as Companies House.
How do we use your personal data?
- Where We post on the Website any information that you wish to post as part of using our Services.
- Where to provide to any other User with whom you have sought to share your personal information.
- Where we need to notify you about changes to our Services.
- Where we need to contact you about your Account and our Services.
- 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 or regulatory obligation.
Why we will use your personal data
- In the table below, We have set out, all the ways we plan to use your Personal Data, and the legal basis which we will be relying on to do so. Our legitimate interests have been identified where appropriate.
- We may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data. We encourage you to contact us, should you require any further details about the grounds We rely on.
- This table is not exhaustive of the ways in which We may use your Personal Data, there may be occasions where we require additional information.
Why we will use your data
|Purpose/Activity||Type of data||Lawful Basis for Processing Including Basis of Legitimate Interest|
|To register you as a Customer||(a) Identity Data (b) Contact Data (c) Account Data (d) Financial Data||Performance of a contract with you|
|To enable you to use the Website and initiate the Services.||(a) Identity Data (b) Contact Data (c) Account Data (d) Financial Data (e) Transaction Data||Performance of a contract with you|
|To enforce legal measures in relation to any fraud or theft||(a) Identity Data (b) Contact Data (c) Account Data (d) Financial Data (e) Transaction Data||Necessary to comply with a legal obligation, where such data will be shared with police authorities and the User|
|To manage our relationship||(a) Identity Data (b) Contact Data (c) Account Data (d) Marketing and Communications Data||(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 Customers use our Products/Services, so that we can develop our Services to suit the demands and preferences of those using our Website and/or Services)|
|To provide you with information on our Products or Services that you have indicated are of interest to you, such as our newsletter, or which we reasonably believe are of interest to you||(a) Identity Data (b) Contact Data (c) Account Data (d) Marketing and Communications Data||(a) Performance of a contract with you (b) Necessary for our legitimate interests (to provide Services to Customers)|
|To administer and protect our business and the Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity Data (b) Contact Data (c) Technical Data||(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)|
|To deliver relevant Website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity Data (b) Contact Data (c) Account Data (d) Usage Data (e) Marketing and Communications Data (f) Technical Data||Necessary for our legitimate interests (to study how Customers use our Products/Services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve the Website, Products/Services, marketing, Customer relationships and experiences||(a) Technical Data (b) Usage Data||Necessary for our legitimate interests (to define types of Customers 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 Products or Services that may be of interest to you||(a) Identity Data (b) Contact Data (c) Account Data (d) Technical Data (e) Usage Data (f) Marketing and Communications Data||Necessary for our legitimate interests (to develop our Products/Services and grow our business in a way that is compatible with the preferences of those using them)|
- We will only use your Personal Data for the purposes for which we collected it. There may times where We consider it necessary to use your data for another reason which is compatible with the original purpose. For further information on how your data may be used for another reason, please contact us.
- We will contact you as soon as reasonably practicable, if We use your Personal Data for any unrelated purpose.
- Please note that we may process your Personal Data without your knowledge or consent, but only where it is compliance with the rules set out above, where this is required or permitted by law.
Marketing and promotional offers from us
- By accessing our Website, and not opting out of our marketing and promotional offers, you are consenting Us to use your Identity Data, Contact Data, Account Data, Technical Data, Usage Data and Marketing and Communications Data and form a view of Products that We think may interest you.
- You may withdraw your consent for Us to contact you, at any time by selecting the opt out link on any of Our marketing emails or contacting us.
- It is possible that you may receive marketing communications from Us, if you have requested information on any of our Products and Services or if you have purchased from us before or in the event that you have provided your details to Us when you have entered into any competition or registering for a promotion. In some cases you may receive marking communications after visiting our website . in each case, you will be consenting for us to use your Personal Data to contact you, prior to you exercising your right to opt out.
Third party marketing
- We will get your express consent before we share your Personal Data with any other company which is not directly linked to Us for marketing purposes.
- At any point, you can ask Us or the third parties to stop sending you marketing communications and to stop processing your Personal Data by following the opt-out links on emails or by contacting Us. Where you have not contacted Us directly with your updated preferences, we will continue to process your Personal Data until such time that we are informed directly of your withdrawal of consent.
- When you opt out of receiving any marketing communications, this will not apply to Personal Data provided to Us.
We use the following cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of the Website. If you block these cookies, the Website will not operate properly.
- Analytical/performance cookies. These cookies allow us to recognise and count the number of visitors and to see how visitors navigate around the Website when they are using it. This helps us to improve the way the Website works, for example, by allowing us to tailor the Services to try and ensure that users are finding what they are looking for easily and their preferences are stored for future reference.
- Functionality cookies. These cookies are used to recognise you when you return to the Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Targeting cookies. These cookies record your visit to the Website, the pages you have visited and the links you have followed. We will use this information to make the Website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
You can disable some or all of the cookies by amending your browser settings. In the event that you amend your browser settings, it can be possible that some parts of the website will become inaccessible or function properly. We will accept no liability for any under-performance of the website as a result of your refusal or disabling of cookies.
When will we disclose your personal data
We may have to share your Personal Data with the third parties, including but not limited to following and for the purposes set out in the table in Paragraph 12 above:
- Payment providers;
- Analytics providers;
- Advertising partners;
- Customer Service providers;
- Our hosting provider;
- Law enforcement authorities; and
We may sell data derived from usage of our website including viewings and downloads of pages, profiles and adverts on the website which will always be in aggregated and anonymised form to Customers, purchasers and retailers.
All third parties are required to respect the security of your Personal Data and to treat it in accordance with the law. We will not allow our third-party service providers to use your Personal Data for their own purposes.
Will we transfer your personal data outside of the UK and EU?
- Some of our external third parties are based outside the European Union (EU) so their processing of your Personal Data will involve a transfer of data outside the EEA.
- Whenever we transfer your Personal Data out of the EU, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give Personal Data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of Personal Data to third countries.
- Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data out of the EU.
How do we protect your personal data?
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. 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 will notify you and any applicable regulator (as required by law to do so) of any suspected breach of your Personal Data.
How long will we use your personal data for?
- In accordance with General Data Protection, We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Once these have been satisfied, the Personal Data will either be deleted or amended to the extent that it would be considered Anonymous Data.
- We will consider the nature and sensitivity of the Personal Data and any potential risk of harm from unauthorised use or disclosure of your Personal Data when determining the appropriate retention period. We will consider other means and applicable legal requirements for when we process your Personal Data.
- You can ask us to delete your Personal Data: see Erasure Request below for further information. In some circumstances we may anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your legal rights
- You have rights under the Data Protection Legislation in relation to your Personal Data.
- You have the right to:
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.
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 (commonly known as “Erasure Request”). 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 the Data Protection Legislation. 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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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. In addition, this does not provide you with routine access to our systems and processes and only the extraction of your Personal Data.
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.
- If you wish to exercise any of the rights set out above, please contact us.
- 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 may refuse to comply with your request in these circumstances.
- We may implement our security measures, such as requesting specific information about you to ensure that your Personal Data is not disclosed to any unauthorised person. We may also contact you to ask you for further information in relation to your request to speed up our response.
- We will use all reasonable endeavours to respond to all legitimate requests within one month of the time we receive all of the information required to complete your request. Occasionally it may 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.
Questions and contact
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.
Our details are:
Full name of legal entity: EMCStevenson Limited (company number: 13172366).
Postal address: Studio 210 134-146 Curtain Road, London, England, EC2A 3AR.
If you wish to contact us regarding your rights, we reserve the right to request copies of your identification or any other information that may be reasonably required to verify your identity.