GDPR Data Privacy Notice for Websites — May 19
This is privacy notice of Circle Circle Films
We respect your privacy and are determined to protect your personal data. The purpose of this privacy notice is to inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from). We’ll also tell you about your privacy rights and how the data protection law protects you.
- Who We Are and Important Information
- The Personal Data We Collect About You
- How We Collect Your Personal Data
- How We Use Your Personal Data
- Who We Share Your Personal Data With
- International Transfers
- Data Security
- Data Retention
- Your Legal Rights
- Changes To This Notice And Your Duty To Inform Us Of Changes
- Queries, Requests or Concerns
1. Who We Are and Important Information
What Is the Purpose of This Privacy Notice?
This privacy notice aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you sign up to our mailing list or purchase a product or service.
This website is not intended for children and we do not knowingly collect data relating to children.
You must read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Circle Circle Films is the controller and responsible for your personal data (collectively referred to as ["COMPANY"], "we", "us", or "our" in this privacy notice).
Our contact details are PLATF9RM, Hove Town Hall, Church Road, Hove BN3 2AF, [email protected]. For all data matters contact our DATA PROTECTION OFFICER on +44 (0)20 7284 6868.
Third-Party Links Outside of Our Control
This website 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.
When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. The Personal Data We Collect About You
Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioners Office.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes [FIRST NAME/LAST NAME/ USERNAME/MARITAL STATUS/ TITLE/DATE OF BIRTH/GENDER].
- Contact Data includes [BILLING ADDRESS/DELIVERY ADDRESS/EMAIL ADDRESS/ TELEPHONE NUMBERS].
WE 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 BUT IS NOT CONSIDERED PERSONAL DATA IN LAW AS THIS DATA DOES NOT DIRECTLY OR INDIRECTLY REVEAL YOUR IDENTITY. FOR EXAMPLE, WE MAY AGGREGATE YOUR USAGE DATA TO CALCULATE THE PERCENTAGE OF USERS ACCESSING A SPECIFIC WEBSITE FEATURE. HOWEVER, IF WE COMBINE OR CONNECT AGGREGATED DATA WITH YOUR PERSONAL DATA SO THAT IT CAN DIRECTLY OR INDIRECTLY IDENTIFY YOU, WE TREAT THE COMBINED DATA AS PERSONAL DATA WHICH WILL BE USED IN ACCORDANCE WITH THIS PRIVACY NOTICE.
Personal data may contain "sensitive personal data" as described under the Data Protection Act 1998 (DPA). Such "sensitive personal data" is information about your racial or ethnic origin, religious beliefs or other beliefs, physical or mental health or, in relation to DPA only, other conditions and information concerning any criminal offences or criminal proceedings. This data would only be used if you have directly provided it yourself (with your consent), for example during one-to-one conversations with our representatives or collected for travel arrangements or event management purposes e.g. for assessing access requirements arising from a disability.
If You Fail to Provide Personal Data
Where we need to collect your 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 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 We Collect Your Personal Data
We use different methods to collect data from and about you including through:
Directly. You may give us your [IDENTITY, CONTACT AND FINANCIAL DATA] by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- Apply for our products or services;
- Subscribe to our service or publications;
- Request marketing to be sent to you.
Indirectly. With regard to each of your visits to our website www.circlecirclefilms.com we may automatically collect the following information We may use special technologies to passively collect information while you are visiting www.circlecirclefilms.com (that is, you do not actively provide this information). These technologies allow us to collect certain kinds of non-personally identifiable information, including your Internet domain name, the type of web browser you use, the operating system you use, the date and time of your visit, the specific pages you visit, and the address of the web site you visited prior to entering circlecirclefilms.com. We do not link this passively collected non-personally identifiable information with personally identifiable information you have actively provided elsewhere on this site. We reserve the right to share with third parties, including our business partners and advertisers, the anonymous aggregated information that we have passively collected via this site.
The primary means of passive information collection at our site are:
- Internet Protocol (IP) Addresses: This site uses Internet protocol (IP) addresses. IP addresses are unique identifiers automatically assigned to each computer when logging onto the Internet. IP addresses allow us to collect much of the same information we collect through cookies, including browser type, what pages you visit, and how long you stay on the site. In general, IP addresses allow us to identify problems with our servers, prepare aggregate demographic information and other information regarding this use of this site, and improve the functions of this site.
Other sources. We may receive information from other sources about you. We work closely with third parties, including for example, business partners, subcontractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies, and may receive information about you from them.
4. How We Use Your Personal Data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Performance of Contract this means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- Legitimate Interest this means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
- Comply with a legal or regulatory obligation this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
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 AT PLATF9RM, HOVE TOWN HALL, CHURCH ROAD, HOVE BN3 2AF.
You can ask us to stop sending you marketing messages at any time BY FOLLOWING THE OPT-OUT LINKS ON ANY MARKETING MESSAGE SENT TO YOU OR BY CONTACTING [email protected]AT ANY TIME.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of A PRODUCT/SERVICE PURCHASE PRODUCT OR SERVICE EXPERIENCE OR OTHER TRANSACTIONS.
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 get an explanation as to how the processing for the new purpose is compatible with the original purpose, please us on [email protected]. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Who We Share Your Personal Data With
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006
- Internal Third Parties - subcontractors and other freelance workers for the performance of any contract we enter into with them or you. External Third Parties Service Software as a Service Providers based with the EU 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 [WHO REQUIRE REPORTING OF PROCESSING ACTIVITIES IN CERTAIN CIRCUMSTANCES].
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International Transfers
If Transfers Out of EEA Occur
[SOME OF OUR PROJECTS ARE CONDUCTED OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA), AND THEREFORE SOME OF OUR INTERNAL AND EXTERNAL THIRD PARTIES ARE BASED OUTSIDE THE (EEA) - 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 EEA, WE ENSURE A SIMILAR DEGREE OF PROTECTION IS AFFORDED TO IT BY IMPLEMENTING SAFEGUARDS.
PLEASE CONTACT US ON [email protected]IF YOU WANT FURTHER INFORMATION ON THE SPECIFIC MECHANISM USED BY US WHEN TRANSFERRING YOUR PERSONAL DATA OUT OF THE EEA.]
7. Data Security
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. 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.
8. Data Retention
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.
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.
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.
In some circumstances you can ask us to delete your data: see Your Legal Rights 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.
9. Your Legal Rights
Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data:
- The right to request a copy of the personal data which we hold about you;
- The right to request that we correct any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary to retain such data;
- The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data;
- The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), where applicable 9i.e. where our processing is based on consent or is necessary for the performance of our contract with you or where we process your data by automated means);
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
- The right to object to our processing of personal data, where applicable i.e. where processing is based on our legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct marketing or processing for the purposes of scientific/historical research and statistics).
If you wish to exercise any of the rights set out above, please contact the Data Protection Officer on [email protected].
No Fee Required - With Some Exceptions
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 admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What We May Need From You
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time Limit To Respond
We try to respond to all legitimate requests within one month. 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.
10. Changes to This Notice and Your Duty to Inform Us of Changes
THIS VERSION WAS LAST UPDATED ON 1st MAY 2019 AND HISTORIC VERSIONS CAN BE OBTAINED BY CONTACTING US.
Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.
11. Queries, Requests or Concerns
To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact our DATA PROTECTION OFFICER on [email protected]. If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England, UK.