1.0 OUR CORE BELIEFS REGARDING USER PRIVACY AND DATA PROTECTION
- User privacy and data protection are human rights
- We have a duty of care to the people within our data
- Data is a liability, it should only be collected and processed when absolutely necessary
- We loathe spam as much as you do!
- We will never sell, rent or otherwise distribute or make public your personal information
2.0 RELEVANT LEGISLATION
Along with our business and internal computer systems, this website is designed to comply with the following national and international legislation with regard to data protection and user privacy:
- UK Data Protection Act 1988 (DPA)
- EU Data Protection Directive 1995 (DPD)
- EU General Data Protection Regulation 2018 (GDPR)
- Australian Privacy Act 1988 (APA)
This site’s compliance with the above legislation, all of which are stringent in nature, means that this site is likely compliant with the data protection and user privacy legislation set out by many other countries and territories as well. If you are unsure about whether this site is compliant with your own country of residence’s specific data protection and user privacy legislation you should contact our data protection officer (details of whom can be found in section 9.0) for clarification.
3.0 PERSONAL INFORMATION THAT THIS WEBSITE COLLECTS AND WHY WE COLLECT IT
This website collects and uses personal information for the following reasons:
3.1 Site visitation tracking
Like most websites, this site uses Google Analytics (GA) to track user interaction. We use this data to determine the number of people using our site, to better understand how they find and use our web pages and to see their journey through the website.
Although GA records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us. GA also records your computer’s IP address which could be used to personally identify you but Google does not grant us access to this. We consider Google to be a third-party data processor (see section 6.0 below).
Disabling cookies on your internet browser will stop GA from tracking any part of your visit to pages on this website.
We use Facebook’s pixel to collect three types of data whenever it is loaded:
- HTTP headers – Anything present in HTTP headers. HTTP headers are a standard web protocol sent by default between any browser request and any server on the Internet. HTTP headers include IP addresses, information about the web browser, page location, document, referrer and user agent.
- Pixel-specific data – This includes the pixel ID and Facebook cookie.
- Optional values – We can optionally choose to send additional information about the visit through custom data events. Example custom data events are conversion value, page type and more. Read more about custom data events here.
All modern browsers allow you to change your cookie settings. The following links may be helpful in helping you understand how you can update your browser cookie settings:
- Cookie settings in Internet Explorer
- Cookie settings in Firefox
- Cookie settings in Chrome
- Cookie settings in Safari
Data Processing Agreement
Note: This document is only available in English.
3.2 Our blog
Should you choose to add a comment to any posts that we have published on our blog, the name and email address you enter with your comment will be saved to this website’s database, along with your computer’s IP address and the time and date that you submitted the comment. This information is only used to identify you as a contributor to the comment section of the respective blog post and is not passed on to any of the third-party data processors below. Only your name will be shown on the public-facing website although if the supplied email address is linked to a Gravatar account, your Gravatar photo will also be displayed.
Your comment and its associated personal data will remain on this site until we see fit to either 1.) remove the comment or 2.) remove the blog post. Should you wish to have the comment and its associated personal data deleted, please email us using the email address that you commented with.
If you are under 16 years of age you MUST obtain parental consent before posting a comment on our blog.
NOTE: You should avoid entering personally identifiable information into the actual comment field of any blog post comments that you submit on this website.
3.3 Contact forms and email links
Should you choose to contact us using the contact form on our contact us page or an email link, none of the data that you supply will be stored by this website or passed to / be processed by any of the third-party data processors defined in section 6.0. Instead, the data will be collated into an email and sent to us over the Simple Mail Transfer Protocol (SMTP). Our SMTP servers are protected by TLS (sometimes known as SSL) meaning that the email content is encrypted using SHA-2, 256-bit cryptography before being sent across the internet. The email content is then decrypted by our local computers and devices. All emails to the nuttifox domain are processed using Google Suite and Google mail servers.
3.4 Email newsletter
If you choose to join our email newsletter, the email address that you submit to us will be forwarded to Active Campaign which provides us with email marketing services. We consider Active Campaign to be a third-party data processor. The email address that you submit will not be stored within this website’s own database or in any of our internal computer systems.
Your email address will remain within Active Campaign’s database for as long as we continue to use Active Campaign’s services for email marketing or until you specifically request removal from the list. You can do this by unsubscribing using the unsubscribe links contained in any email newsletters that we send you or by requesting the removal of the email. When requesting removal via email, please send your email to us using the email account that is subscribed to the mailing list.
If you are under 16 years of age you MUST obtain parental consent before joining our email newsletter.
While your email address remains within the Active Campaign database, you will receive periodic (approximately twelve times a year) newsletter-style emails from us.
4.0 HOW WE STORE YOUR PERSONAL INFORMATION
As detailed in section 3.2 above, if you submit a comment to a blog post published on this website some personal information will be stored in this website’s database. This is currently the only occasion where personal data will be stored on this website. This data is currently stored in an identifiable fashion; a limitation of the content management system that this website is built on (WordPress). In the near future, we aim to change the storage of this data to a pseudonymous fashion meaning that the data would require additional processing using a separately stored ‘key’ before it could be used to identify an individual.
Pseudonymisation is a recent requirement of the GDPR that many web application developers are currently working to fully implement. We are committed to keeping it a high priority and will implement it on this website as soon as we are able to.
Our data processors
Our services operate across a global infrastructure using our data controllers, who process data in both EU and US-based servers. This processing is supported by strict legal compliance for safeguarding any transfers of personal data outside of the EU. You can find more information on how each of our data controllers processes your data below.
5.0 OUR THIRD-PARTY DATA PROCESSORS
We use a number of third parties to process personal data on our behalf. These third parties have been carefully chosen and all of them comply with the legislation set out in section 2.0. All of these third parties are based in the UK and US with servers across the EU and US. They are EU-U.S Privacy Shield compliant.
- Amazon (AWS GDPR centre)
6.0 DATA BREACHES
We will report any unlawful data breach of this website’s database or the database(s) of any of our third-party data processors to any and all relevant persons and authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.
8.0 DATA CONTROLLER
The data controller of this website is: 303 LONDON LIMITED, a UK Private limited Company with company number: 08752972
64 New Cavendish Street, London, England, W1G 8TB
9.0 DATA PROTECTION OFFICER
Mr Oliver Fawcett
Director, 303 London Limited.
10.0 YOUR RIGHTS & REQUESTS
Right to rectification – You’re able to request we edit account information at any time through the form below.
Right to be forgotten – After receiving a request to be forgotten, we will permanently delete your record and all data associated with it within 30 days of receiving the request.
Right of portability – If requested, we will export your data so it can be transferred to a third party.
Right to object – At any time, you may object (via opt-out) to your personal data being used for specific purposes such as direct marketing, research, etc.
Right of access – We’re transparent about the data we have and how we use it. You can contact us at any time if you’d like to access your data or if you have any questions about your data and how we’re using it.
In accordance with GDPR, as our customer, you can exercise your data subject rights at any time.