Chromacity takes your privacy very seriously.
Our use of your personal data is subject to your instructions, the EU General Data Protection Regulation (GDPR), other relevant UK and EU legislation and our professional duties to clients.
Chromacity Limited, registered no SC442724, Registered Office 13 Melville Street, Edinburgh EH3 7PE
Our Head of Privacy oversees compliance with data protection laws and this policy and provides guidance and advice to the as company required.
Contact information for our Head of Privacy is provided below under the heading How to contact us about this policy.
What personal data we collect about you
We may collect information from you in the course of our business, including when you engage us to provide you with details of our products and/or services, when you contact or request information from us, when you use our website or as a result of your relationship with one or more of our staff and clients.
The personal information we may collect about you includes:
In general, you will be able to choose whether or not to provide us with your personal data. If you do not provide the personal data that we need to collect then this may affect our ability to provide products or services to you, for example because this personal data is required to process your instructions or and if you do not provide personal data we ask for, it may delay or prevent us from providing services to you.
How we collect your personal data
We collect most of this information from you:
We may also collect information via our website or via our information technology (IT) and other systems, for example:
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason for doing so.
This will be for one of the following reasons:
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
We may process special category personal data for the following reasons:
There may be additional reasons which will be notified to you where they apply.
In the next section The basis on which we use your personal data we give more information about the way in which your information is used.
The basis on which we use your personal data
We have explained our reasons for using your personal data. We set out below more detail on the ways in which we use your personal data. We use your data:
We will also process personal data which is provided to us by or on behalf of our clients for the purposes of services we provide to them.
Managing our business
In relation to a number of uses of personal data we refer to above we are using such personal data on the basis that it is in our legitimate interests or those of a third party for us to do so. These interests cover a number of aspects of our business operations, namely:
We have a legitimate interest in processing your personal data for promotional purposes (see above The basis on which we use your personal data). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal data with the utmost respect.
You have the right to opt out of receiving promotional communications at any time by:
If you ask us to delete your information in accordance with your rights set out below, we will retain basic information on a suppression list to record your request and to avoid sending you unwanted materials in the future.
You can also update your marketing preferences and give us more detail of the type of information you would like to receive from us by contacting us on our preference centre.
We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
Use of website
At a number of points on our website you are asked to provide information, for example. our contact page. At the point at which information is requested it is clear what the purpose of providing the information is and we will only use the personal data you provide to us for that purpose.
Our website makes use of Google Analytics to look at how our website is used. This is done by placing small text files, known as session cookies, on your device to collect information about how visitors use our website. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. This information is transmitted to and stored by Google on servers in the US.
Who we share your personal data with
We share personal data on a confidential basis where required for the purpose of providing the best possible support for our products or services and for administrative, billing and other business purposes.
We also routinely share personal data with:
We will only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you and to ensure compliance with data protection laws.
We may also, should the need arise, need to share some personal data with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible.
The recipient of the information will be bound by confidentiality obligations.
We may also use aggregated personal data and statistics for the purpose of monitoring website usage in order to help us develop our website and our services.
Other than as set out above, we will only disclose your personal data when you direct us or give us permission, when we are required by applicable law or regulations or judicial or official request to do so, or as required to investigate actual or suspected fraudulent or criminal activities.
Personal data about other people which you provide to us
How long your personal data will be kept
The retention periods we apply take account of:
When it is no longer necessary to retain your personal data, we will delete or anonymise it.
Updating personal data about you
We also need to know that your information is accurate and up to date so please advise of any changes or firstname.lastname@example.org. You should also use this email address if you want to cancel any request you have made to us or you become aware of any inaccuracy in the data we hold about you.
Transferring your personal data out of the European Union
To deliver services to our clients, it is sometimes necessary for us to share your personal data outside the European Union (EU), e.g.:
These transfers are subject to special rules under European and UK data protection law.
We will, however, implement appropriate safeguards to ensure the transfer complies with European and UK data protection law and all personal data will be secure. If you would like further information on these safeguards please contact our Head of Privacy (see How to contact us about this policy below).
The steps we take to protect your personal data
We will take appropriate technical and organisational measures to keep your personal data confidential and secure. We have appropriate security measures in place which take account, in particular, of the risks arising from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
The rights you have in relation to your personal data
You have the following rights, which you can exercise free of charge:
You can ask us to:
You can object:
If you would like to exercise any of those rights, please email us at email@example.com
Your objection (or withdrawal of consent) may mean we cannot perform the services you have requested of us or you may not be able to use the services we offer. We will advise you where this is the case. In certain circumstances even if you withdraw your consent we may still be able to process your personal information if required or permitted by law or for the purpose of exercising or defending our legal rights or meeting our legal and regulatory obligations.
You also have the right to complain to the supervisory authority in the part of the European Union where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns. We would, however, appreciate the chance to deal with your concerns before you approach the Information Commissioner so please contact us in the first instance.
Our contact details can be found in the section below How to contact us about this policy.
How to contact us about this policy
Our contact details are shown below:
Head of Privacy, Chromacity Limited, 13 Melville Street, Edinburgh, EH3 7PE
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