Improper Agency Ltd trading as Improper Agency
Registered in England & Wales
We collect your data (specifically outlined below, but generally basic information about you in a professional context, such as email, job title, company name, etc) strictly to provide you with access to our news, events and other programmes. We will not share this data with anyone unless you explicitly consent to us doing so. We honor your right to privacy and will comply with your wishes to remove your data from our systems.
How to ask us to delete your data.
If you would like to request a complete data delete please email Kate Ford – email@example.com
OUR COMMITMENT TO THE SECURITY OF YOUR DATA
To prevent unauthorised parties from accessing your data and maintain the accuracy and cleanliness of our own data while ensuring the correct use of it, we have put in place appropriate physical, electronic and managerial procedures to safeguard and secure the information we collect online.
1. Definitions & Interpretation.
In this Policy, the following terms shall have the following meanings:
“Account” means an account required to access and/or use certain areas and features of Our Site;
“personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us. This definition shall, where applicable, incorporate the definitions provided in the Data Protection Act 1998 and EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and
“We/Us/Our” means Improper Agency, a limited company registered in England under company number 12298133 whose registered address is Ciconia, The Hollows, Brentford, England, TW8 0DZ
2. Information about us.
2.1 Our Site is owned and operated by Improper Agency.
3. What does this policy cover?
4. Your rights.
4.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
4.1.1 The right to be informed about Our collection and use of personal data;
4.1.2 The right of access to the personal data We hold about you (see section 12);
4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);
4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);
4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7 The right to object to Us using your personal data for particular purposes; and
4.1.8 Rights with respect to automated decision making and profiling.
4.2 please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
5. What Data do we collect?
Depending upon your use of Our Site and our company, We may collect some or all of the following personal and non-personal data:
5.1 name; 5.2 business/company name 5.3 job title; 5.4 profession; 5.5 contact information such as email addresses and telephone numbers; 5.6 demographic information such as post code, preferences, and interests; 5.7 IP address; 5.8 web browser type and version; 5.9 operating system; 5.10 a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;
6. How do we use your data?
6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under GDPR at all times. For more details on security see section 7, below.
6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
6.2.1 Providing and managing your access to Our Site;
6.2.2 Personalising and tailoring your experience on Our Site;
6.2.3 Supplying Our services to you (please note that We require your personal data in order to enter into a contract with you);
6.2.4 Personalising and tailoring Our services for you;
6.2.5 Replying to emails from you;
6.2.6 Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by clicking the unsubscribe link included in marketing emails or contacting our Data Protection Officer.
6.2.7 Market research;
6.2.8 Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;
6.3 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email, telephone, text message and post with information, news and offers on Our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
6.4 Third parties whose content appears on Our Site may use third party Cookies, as detailed below in section 13. Please refer to section 13 for more information on controlling Cookies. Please note that We do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties.
6.5 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
6.6 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for six months.
7. How and where do we store your data?
7.1 We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
7.2 Your data will only be stored in the UK.
7.3 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
7.4 Steps We take to secure and protect your data include:
7.4.1 Computers and documents that hold your personal data are password protected.
8. Do we share your data?
8.1 We may share your data with other companies in Our Group including, Sauders and Thomson
8.2 We may sometimes contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
9. How can you access your data?
9.1 You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at firstname.lastname@example.org
10. Contacting us.