Privacy Policy

privacy policy

PRIVACY POLICY

Last updated: 22 July 2020

1.ABOUT THIS PRIVACY POLICY

1.1The website https://wearecomplexcreative.com (the Site) is operated by Complex Creative Ltd (“we”, “us”, “our”), a company incorporated in England and Wales under company number 123447472. Our registered office is at 3rd Floor, 86-90 Paul Street, London, EC2A 4NE . 

1.2We are committed to protecting your privacy and complying with our data protection obligations under the Data Protection Act 2018 (the DPA 2018), the General Data Protection Regulation 2016/679 (the GDPR) and any other applicable UK legislation (together, Data Protection Law).

1.3When you interact with us or use the Site, we act as the data controller of your personal data. This means that we are responsible for processing your personal data and deciding how to use it. This privacy policy explains the types of personal data we may collect about you when you interact with us, why we collect it, what we use it for and what rights you have over that data. Personal data is any information about an identifiable person. Processing is anything we do with your personal data, including using, storing, sharing and deleting it.

1.4This policy was last updated on the date shown at the top. We may change this policy at any time by posting an updated version on the Site and will make reasonable efforts to bring any material changes to your attention. You may wish to check it before using the Site as any changes will be effective from the date that they are made. 

2. CONTACT INFORMATION

2.1If you have any concerns or would like further information about our use of data or this policy in general, you can contact our Sabrina Chevannes at sabrina@wearecomplexcreative.com. 

3. WHAT INFORMATION DO WE COLLECT?

3.1We collect, store and use the types of personal data set out in the table at the end of this policy.

4. HOW WILL WE USE YOUR PERSONAL DATA?

4.1We will use your personal data for the purposes set out in the table at the end of this policy.

5. HOW DO WE SHARE YOUR PERSONAL DATA?

5.1When we share personal data, we do so in accordance with Data Protection Law. We may share certain personal data, where necessary, with employees, contractors, consultants or advisers, to facilitate sales and for general commercial purposes.

In addition, where necessary, your personal data may be shared:

5.1.1with parties who provide products or services to us, such as software development, user analytics, email services, payment processing, advertising, user notification and feedback functionality, data insight companies etc.

5.2We may also provide third parties with aggregated but anonymised information and analytics about our customers. Before we do so we will make sure that it does not identify you.

6. THIRD PARTY LINKS

6.1This Site contains links to other websites over which we have no control. We are not responsible for and do not review or endorse the privacy policies or practices of other sites which you choose to access from this Site. We encourage you to review the privacy policies of those other sites, so you can understand how they collect, use and share your personal information.

7. YOUR RIGHTS

7.1We respect your rights to privacy and will respond to requests for access or control over information about you in accordance with Data Protection Law. We may require you to verify your identity before we take any action.

7.2Depending on the reason we have your personal data, you have a right to:

7.2.1access the personal information we hold about you (commonly known as subject access);

7.2.2request that we correct or complete personal information we hold about you that is inaccurate or incomplete; 

7.2.3request that we erase your personal information in some circumstances, or object to our processing it as detailed at paragraph 7.5; 

7.2.4restrict how we use your personal information, in certain circumstances; 

7.2.5request that we provide you with copies of your personal information in a machine-readable format or transfer it across different services; and

7.2.6where we have asked for your consent to process your data, to withdraw this consent.

7.3These rights are limited in some situations under Data Protection Law – for example, where we can demonstrate that we are under a legal obligation to process your data.

7.4If you wish to exercise any of these rights, please contact us using the details in paragraph 2 above. 

7.5 Your right to object 

You have a right to object to our processing of your personal data and ask us to stop doing so. If we are processing your personal data for direct marketing purposes (which includes profiling to the extent that it is related to such direct marketing) and you object to this, we will stop processing your personal data immediately.

If our processing of your personal data is in the public interest or pursuant to our legitimate interests and you object to this, we will stop processing your personal data unless we have compelling reasons which override your interests, or our use of your personal data is for the establishment, exercise or defence of legal claims.

7.6We hope that we can satisfy any queries you may have about the way we process your data. However, if you have unresolved concerns you also have the right to complain to data protection authorities (in the UK, the Information Commissioner’s Office). You can call the ICO on 0303 123 1113 or go to their website: https://ico.org.uk/make-a-complaint/).

8. DATA RETENTION

8.1Your personal data will only be kept for as long as necessary for our purposes. Specific periods are set out in the table at the end of this policy.

9. DATA PROTECTION PRINCIPLES

9.1We process your personal data in accordance with the following principles: 

9.1.1we process your personal data lawfully, fairly and in a transparent way; 

9.1.2we collect your personal data for specified, explicit and legitimate purposes; any further processing we do is compatible with the original purposes for which for which we collected it;

9.1.3we only process personal data which is adequate, relevant and limited to what is necessary to achieve the purpose for which it is processed; 

9.1.4we take reasonable steps to ensure that all personal data is accurate and kept up to date where necessary;

9.1.5we do not store personal data in a form which identifies you for any longer than is necessary for the purposes of processing; and

9.1.6we process personal data securely and in a way that protects against unauthorised or unlawful processing, accidental loss, destruction or damage. 

9.2When we ask for your personal data we will tell you whether you are required by law or contract to provide it, and what will happen if you do not provide the data.  

9.3Any request for consent to the processing of your personal data will be made directly to you and will include information about why we require the personal data and what will be done with it.

10. WHAT IS OUR LAWFUL BASIS FOR PROCESSING?

10.1We will only process personal data when we have a lawful basis for doing that processing. The table at the end of this policy sets out the lawful basis we rely on for each type of data we process.

10.2We will choose one of the lawful bases in the GDPR to justify how we use your personal data. These are:

10.2.1Consent: You have given consent to the processing of your personal data for one or more specific purposes.

10.2.2Contract: The processing is necessary for the performance of a contract with you or in order to take steps at your request before entering into a contract.

10.2.3Legal obligation: We need to process your personal data to comply with a legal obligation.

10.2.4Vital interests: The processing is necessary to protect the vital interests of you or another person.

10.2.5Public interest: Processing is necessary for the performance of a task carried out in the public interest or in the exercise of some official authority.

10.2.6Legitimate interests: Processing is necessary for the purposes of legitimate interests pursued by us or someone else, except where such interests are overridden by your interests or fundamental rights and freedoms requiring the protection of your personal data.

TABLE OF PERSONAL INFORMATION WE USE

 

The table below sets out detailed information about our purposes for processing, the basis for processing and the retention period for the personal data.

 

Category of personal data

 

Purpose of processing

 

Lawful basis for processing

 

Retention period

 

Name and contact details

 

 

 

To deliver your purchases to you

To send you order updates

For fraud prevention and detection

 

To contact you with information, newsletters and marketing materials about our products and services

 

Performance of contract

 

Compliance with legal obligation

 

Consent

 

 

For six years since you gave consent, or until you withdraw consent if earlier

 

Payment information

 

To take payment and give refunds

For fraud prevention and detection

Performance of contract

 

Compliance with legal obligation

 

For six years since you last logged on to the Site
Saved items in online shopping basket To sell products and services to you

 

 

Performance of contract Until you complete your order or for seven days after the item is saved

 

Purchase history

 

To provide customer service and support and handle returns

 

To  find out what products you like

 

Performance of contract

 

Consent

 

For three years since you gave consent, or until you withdraw consent if earlier

 

Browser, device and Site usage information

 

To improve the Site

To protect the Site against fraud

To set default options for you, such as language and currency

 

Performance of contract

 

Legitimate interest in maintaining our Site

For three years since you last logged on to the Site

 

Information from linked accounts

 

To enable you to log into the Site simply without having to create a specific account Legitimate interest in providing high quality customer service For three years since you last logged on to the Site

 

Responses to surveys, competitions and promotions

 

To run the survey, competition or promotion Performance of contract

 

Legitimate interest in administering and/or improving our products and services generally

For six years

 

Customer comments and product reviews

 

 

To improve our products and services

Where relevant, to establish, exercise or defend legal claims

Performance of contract

 

Legitimate interest in dealing with complaints or claims and improving our products and/or services generally

 

For six years

 

Information generated in the course of the use of our products and services

 

For internal research and development purposes

To improve and test the features and functions of our Site

Performance of contract

 

Legitimate interest in maintaining our Site and improving our products and/or services generally

 

For four years
Information collected through cookies and similar technologies To conduct and store site usage analytics, statistical and trend analysis and market research

To generate customer profiles to facilitate marketing initiatives

 

Consent For three years since you gave consent, or until you withdraw consent if earlier