At Strafe Creative, we are proud that we are fully complaint with the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679).
This is a notice to inform you of our policy about all information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.
We regret that if there are one or more points below with which you are not happy, your only recourse is to leave our website immediately.
We take seriously the protection of your privacy and confidentiality.
We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).
The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. You can see further information about your rights, and our obligations, at www.ico.org.uk. Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.
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 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 regards 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)
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 residences’ 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
The law requires us to determine under which bases we process different categories of your personal information, and to notify you of the basis for each category. If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.
3.1 Information we process because we have a contractual obligation with you
When you sign up to buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us. In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information. We may use it in order to:
- verify your identity for security purposes
- sell products to you
- provide you with our services
- provide you with suggestions and advice on products, services and how to obtain the most from using our website
We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract. Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable. We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
3.2 Information we process with your consent
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including our products and services, you provide your consent to us to process information that may be personal information. Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to tick a box on our contact form indicating your consent. Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply. Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on our website. If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful. We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists. You may withdraw your consent at any time by instructing us at firstname.lastname@example.org. However, if you do so, you may not be able to use our website or our services further.
3.3 Information we process because we have a legal obligation
We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation. For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order. This may include your personal information.
4.0 THIS WEBSITE COLLECTS AND USES PERSONAL DATA FOR THE FOLLOWING REASONS:
4.1 Site visitation tracking
4.2 Contact forms and email links
Should you choose to contact us using the contact form on our Contact us page, our Project Planner none of the data that you supply will be stored by this website. Your personal data will not be passed to / be processed by any of the third party data processors defined in section 7.0. The data submitted on our contact forms 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.
If you contact us via an email link on the website, your data may be passed to / be processed by Hubspot CRM and Google/G Suite as detailed in section 7.0.
4.3 Email newsletter
If you choose to join our email newsletter, the email address that you submit to us will be forwarded to MailChimp who provide us with email marketing services. We consider MailChimp to be a third party data processor (see section 7.0). 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 MailChimp’s database for as long as we continue to use MailChimp’s services for email marketing or until you specifically request removal from the list or until your interactions via Mailchimp are deemed inactive. You can remove your details from the newsletter list by unsubscribing using the unsubscribe links contained in any email newsletters that we send you or by requesting removal via email by contacting email@example.com. 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 MailChimp database, you will receive periodic (approximately once per month) newsletter-style emails from us, as well as important service messages relating to products and services that you have already obtained from us, for example, your website.
4.4 Sending a message to our support team
When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need. We record your request and our reply in order to increase the efficiency of our business. We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a quality service.
When we receive a complaint, we record all the information you have given to us. We use that information to resolve your complaint.
5.0 HOW WE STORE YOUR PERSONAL INFORMATION
Any data that 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, which many web application developers are currently working to fully implement. We are committed to keeping it as a high priority and will implement it on this website as soon as we are able to.
6.0 ABOUT THIS WEBSITE’S SERVER
This website is hosted by Kinsta Inc. within a UK data centre located in London, England.
Kinsta Inc. is a managed WordPress hosting provider. Running their services on cutting-edge technology, they take security very seriously and offer the highest levels of technical resilience and physical security available. Kinsta’s legal documentation can be viewed online.
7.0 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. Some of these third parties are based in the USA and are EU-U.S Privacy Shield compliant.
- Google / G Suite
- Facebook (via Facebook Pixels)
- CV Library
- Go Cardless
- Digital Ocean
- Kinsta Inc.
Please note, your data will not be automatically shared with all of the above third parties and will only be processed where necessary.
8.0 HOW TO REQUEST YOUR PERSONAL INFORMATION
8.1 Access to your personal information
At any time you may review or update personally identifiable information that we hold about you and to obtain a copy of any information that is not provided on our website you may send us a request at firstname.lastname@example.org. Requests for data will be processed within 1 calendar month, in accordance with the GDPR.
8.2 Removal of your information
If you wish us to remove personally identifiable information from our website, you may contact us at email@example.com. This may limit the service we can provide to you.
8.3 How you can complain
1.2. If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office. This can be done at https://ico.org.uk/concerns/.
9.0 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. This will be reported to any and all relevant persons / authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.
10.0 REGISTRATION WITH INFORMATION COMMISSIONER’S OFFICE (ICO)
Strafe Ltd is officially registered with the Information Commissioner’s Office (ICO) under registration reference: ZA320915. Our Certificate of Registration can viewed here.
11.0 DATA CONTROLLER
The data controller of this website is:
Strafe Ltd, a UK Private Limited Company with company number: 08691800.
The registered office is:
68 West Gate
The operating office is:
30 Woolpack Lane
12.1 Change Log
03/01/2020: Operating address updated (section 11.0)
26/02/2019: ICO Certificate of Registration updated.
24/02/2020: ICO Certificate of Registration updated.
03/03/2020: Website server information updated (section 6.0). Third party data processors updated (section 7.0)