Creative Development Services Limited (“we”, “us” or “our”) is a company incorporated in England and Wales with company number 9252187. Our registered office is Suite 2022, Letraset Building, Ashford, Kent, TN23 6LN. We are committed to preserving your privacy. This policy sets out the basis on which any personal data we collect from you, that you provide to us or that we obtain from other sources, will be processed by us. This includes personal data we use in connection with:
- use of our website at freedomviaproperty.com;
- sale and provision of our products and services;
- any of our services when you call or otherwise contact us; and
- the provision of our newsletters, surveys and updates.
- For the purpose of data protection laws, the data controller is Creative Development Services Limited of Suite 2022, Letraset Building, Ashford, Kent, TN23 6LN. We are registered as a data controller with the Information Commissioner’s Office under number ZA182883.
Our full details are:
Full name of legal entity: Creative Development Services Limited
Postal Address: Suite 2022, Letraset Building, Ashford, Kent, TN23 6LN
Email address: [email protected]
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would be grateful if you could contact us first if you do have a complaint so that we can try to resolve it for you.
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at [email protected]
1. LAWFUL BASIS FOR PROCESSING PERSONAL DATA
1.1. Paragraphs 1.2 – 1.6 below explain how and why we process your personal data, as well as the legal basis on which we carry out this processing.
1.2. To enter into and perform contracts with you:
Where you ask us to provide products and / or services to you, we will process your personal data to provide these products and / or services to you. Our use of your personal data in this way includes sharing your personal data with our employees and other personnel, partner agencies and suppliers such as hosting service providers, payment service providers, cloud-based email and CRM system providers, and marketing and public relations agencies. We need to process your personal data in this way to enter into and fulfil our contract with you for sale of products or supply of services at your request. If you do not wish to provide us with your personal data in this way, you will be unable to purchase our products and / or use our services. The lawful basis on which we process your personal data for these matters is our contractual obligation as a business to provide you with the products and or services you have paid for.
1.3. To communicate with you:
Where you: submit a complaint or enquiry to us; provide feedback to us; complete a survey; sign up to our updates and / or newsletters; or otherwise provide us with any submissions, we will process your personal data so that we can respond to your complaint / enquiry, provide you with the information you requested and / or otherwise communicate with you. The lawful basis on which we process your personal data in these circumstances is our legitimate interest as a business to respond to customer communications and requests, and to maintain customer satisfaction.
1.4. To make our website better:
We may also process personal data in order to provide you with a more tailored experience, including using personal data to make sure our websites are displayed in the most effective way for the device you are using. This processing means that our services will be more tailored to you.
The legal basis on which we process personal data in these circumstances is our legitimate interest to provide you with a better user experience, and to ensure that our website is kept secure.
The use of any non-essential cookies is subject to your consent. You can also prevent us from using your personal data in this way by using the ‘do not track’ functionality in their internet browser. If you enable such do not track functionality, our website may be less tailored to your needs and preferences.
1.5. For marketing purposes:
1.5.1. We will process your personal data to provide you with marketing communications if you have requested information from us or purchased products or services from us (including from other companies within our group of companies), and, in each case, you have not opted out of receiving that marketing. We may use external marketing agents to help us with such marketing communications. The legal basis on which we process personal data for marketing purposes is our legitimate interest to develop our products and services and grow our business.
1.5.2. You can ask us to stop sending you marketing communications at any time by contacting us at [email protected] or, where relevant, by following the unsubscribe link in any marketing communication you receive from us. Where you opt out of receiving these marketing communications, this will not apply to personal data provided to us as a result of a product or service purchase or other transaction.
1.6. Legal obligation:
In certain circumstances we may also need to share your personal data if we are under a duty to disclose or share personal data in order to comply with any legal obligation.
2. WHAT DATA DO WE COLLECT ABOUT YOU?
Personal data means any information capable of identifying you as an individual. It does not include anonymised data. We may process certain types of personal data about you as follows:
2.1. Identity Data may include your first name, maiden name, last name, username, marital status, title, date of birth and gender.
2.2. Contact Data may include your billing address, delivery address, email address and telephone numbers.
2.3. Financial Data may include your bank account and payment card details.
2.4. Transaction Data may include details about payments between us and other details of purchases made by you.
2.5. Technical Data may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.
2.6. Profile Data may include your username and password, purchases or orders, your interests, preferences, feedback and survey responses.
2.7. Usage Data may include information about how you use our website, products and services.
2.8. Marketing and Communications Data may include your preferences in receiving marketing communications from us and our third parties and your communication preferences.
2.9. We may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your Usage Data to work out the percentage of website users using a specific feature of our site. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.
2.10. We do not process any special categories of personal data, meaning personal data revealing: racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic or biometric data that uniquely identifies individuals; or data concerning an individual’s health, sex life or sexual orientation.
2.11. We do not process data relating to criminal convictions unless legally obliged to do so.
Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.
3. HOW WE COLLECT YOUR PERSONAL DATA
We collect data about you through a variety of different methods including:
3.1. Direct interactions: You may provide data by filling in forms on our sites (or otherwise) or by communicating with us by post, phone, email or otherwise, including when you:
• order our products or services;
• create an account on our site;
• subscribe to our service or publications;
• request resources or marketing be sent to you;
• enter a competition, prize draw, promotion or survey; or
• give us feedback.
3.3. Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below:
• Analytics providers such as Google based outside the EU;
• Advertising networks such as Facebook based outside the EU; and
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as GoCardless, Paypal or Stripe based outside the EU; and
• Identity and Contact Data from publicly available sources such as Companies House, Land Registry and the Electoral Register based inside the EU.
3.4. Change of purpose: We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us at [email protected]pg.com. If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
4. SHARING OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in paragraph 1 above:
• Service providers who provide IT and system administration services.
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
• Business partners and/or sub-contractors that are needed to help us fulfil our legal and contractual obligations to you.
• Third parties to whom we sell, transfer, or merge parts of our business or our assets.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
5. WHERE WE STORE YOUR PERSONAL DATA
5.2. All information you provide to us is stored on secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. You must not share your password with anyone.
Please email us at [email protected] if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
6. KEEPING YOUR DATA SECURE
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 such data. 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.
7. DATA RETENTION
7.1. 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.
7.2. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
7.3. By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
7.4. In some circumstances you can ask us to delete your data: see below for further information.
7.5. 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.
8. YOUR RIGHTS UNDER DATA PROTECTION LAWS
8.1. Right to object
You have the right to object to us processing your personal data where we are processing your personal data:
8.1.1. based on our legitimate interests (as set out at sections 1.3 and 1.4 above). If you ask us to stop processing your personal data on this basis, we will stop processing your personal data unless we can demonstrate compelling grounds as to why the processing should continue in accordance with data protection laws; and
8.1.2. for direct marking purposes. If you ask us to stop processing your personal data on this basis, we will stop.
8.2. Right of access
8.2.1. You have the right to receive confirmation as to whether your personal data is being processed by us, as well as various other information relating to our use of your personal data. You also have the right to access your personal data which we are processing.
8.2.2. Please note where you register your details for certain services and open a user account that you can then use to access and log on to use those services, you may change or update your user name and password or other details at any time via your account.
8.3. Right to rectification
You have the right to require us to rectify any inaccurate personal data we hold about you. You also have the right to have incomplete personal data we hold about you completed, by providing a supplementary statement to us.
8.4. Right to restriction
You have the right to restrict our processing of your personal data where:
8.4.1. the accuracy of the personal data is being contested by you;
8.4.2. the processing by us of your personal data is unlawful, but you do not want the relevant personal data erased;
8.4.3. we no longer need to process your personal data for the agreed purposes, but you want to preserve your personal data for the establishment, exercise or defence of legal claims; or
8.4.4. we are processing your data on the basis of our legitimate interest (as set out at sections 1.3 and 1.4 above) and you:
220.127.116.11. object to our processing on the basis of our legitimate interest under section 8.1.1 above; and
18.104.22.168. want processing of the relevant personal data to be restricted until it can be
22.214.171.124. determined whether our legitimate interest overrides your legitimate interest.
8.4.5. Where any exercise by you of your right to restriction determines that our processing of particular personal data are to be restricted, we will then only process the relevant personal data in accordance with your consent and, in addition, for storage purposes and for the purpose of legal claims.
8.5. Right to data portability
You have the right to receive your personal data in structured, standard machine- readable format and the right to transmit such personal data to another controller.
8.6. Right to erasure
You have the right to require we erase your personal data which we are processing where one of the following grounds applies:
8.6.1. the processing is no longer necessary in relation to the purposes for which your personal data was collected or otherwise processed;
8.6.2. our processing of your personal data is based on your consent, you have subsequently withdrawn your consent and there is no other legal ground we can use to process your personal data;
8.6.3. you object to the processing in as set out in section 8.1.1 of this policy and we have no overriding legitimate interest for our processing;
8.6.4. the personal data have been unlawfully processed;
8.6.5. the erasure is required for compliance with a law to which we are subject.
You have the right to lodge a complaint with the Information Commissioner’s Office, the supervisory authority for data protection issues in England and Wales.
8.7. Exercising rights
If you wish to exercise any of the rights set out above, please email us at [email protected]
You can see more about your rights at:
9. CHANGES OF BUSINESS OWNERSHIP AND CONTROL
10. LINKS ON OUR WEBSITES
Our websites 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 notice of every website you visit.
11. COOKIES ON OUR WEBSITES
Last Updated: 28 April 2020