This Privacy Policy is issued by Ripple Studios Limited, company number 11734181; registered office address: 97 Viewpoint, Derwentside, Business Park, Consett, Co Durham, DH8 6BN; principal trading address: c/o Crown House, 27 Old Gloucester Street, London, WC1N 3AX - referred to as “we”, “us” or “our” in this Privacy Policy.
We take your privacy very seriously. This Privacy Policy explains how we obtain, hold, process, retain and use Personal Data in all dealings and transactions with our clients or potential clients (referred to as “you” in this Privacy Policy), whether making an enquiry via our website or by email or telephone, through to providing you any professional services of an advisory, consultancy or media creative nature.
Capitalised terms used in this Privacy Policy such as “Personal Data”, “Controller” and “Processor” have the meaning given to them by the Data Protection Act 2018.
We are registered with the Information Commissioner under reference number ZA555041
Our Data Protection Officer is Lisa MacHale, whose contact details are shown at section 11 below.
Ripple Studios Limited is the Data Controller who is responsible for the operation of our website and any data collected when you communicate or transact with our website.
Unless specifically agreed with you otherwise, when Ripple Studios provides any advisory, consultancy or media creative services to you, and agency services, you shall remain the Data Controller and Ripple shall be a Data Processor. Ripple will only process Personal Data in line with your instructions, to be confirmed as part of our scope of engagement with you.
1. HOW WE COLLECT PERSONAL DATA
1.1 We may collect data from and about you during the course of your dealings dealing with us, including:
a. Direct interactions.
You may give us your Personal Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you, inquire about our services, request marketing information to be sent to you, give us feedback or contact us or when we provide you with services.
b. Automated technologies or interactions.
As you interact with our website, we may automatically collect certain Personal Data, in accordance with our [insert link to Cookie Policy]. You may opt-out from cookies being placed on your computer as set out in our website’s cookie notice.
c. Third parties or publicly available sources.
We may receive Personal Data about you from various third parties and public sources when responding to an enquiry or when providing services to you.
d. Technical Data from the following parties:
Analytics providers such as Google Analytics, who may based outside the EEA.
1.2 Where we need to collect Personal Data by law, or under the terms of a contract or potential contract between us, and you fail to provide that data when requested, we may not be able to perform or enter into that contract with you (for example, to provide you with services). We will notify you if this is the case at the time.
1.3 If you provide us with Personal Data relating to any other person, you must ensure that you have fully complied with your own legal obligations concerning data protection and privacy before to those persons doing so.
2. HOW WE USE YOUR PERSONAL DATA
2.1 This section provides you with information about:
a. the Personal Data we hold and process;
b. in respect of Personal Data that we did not collect from you directly, where we obtained that data from, and
c. what types of data we have collected; the purposes for which we may process your Personal Data; and the legal grounds on which we process your data.
2.2 Enquiry Data.
We may process contact details that you provide to us. This Enquiry Data may include your name, telephone number, email address, nature of your enquiry and your marketing preferences to receive information from us and, may be collected through our website when you contact us through our Enquiry Form. If you contact us by telephone or email, we may collect other Personal Data such as your correspondence address, your business title or role and the nature of your enquiry. We may use this contact data to respond to your enquiry. The legal basis for this processing is our legitimate interest in processing your query.
Your Enquiry Data may be processed for the purposes of performing our contract with you, or in taking steps at your request prior to entering into a contract.
We may also use this Enquiry Data to contact you for feedback on our website or services. The legal basis for this processing is our legitimate interest in ensuring the efficient administration and continued improvement of our website and services for clients. Depending on your chosen marketing preferences, we also may use Enquiry Data to contact you with information about our services you may be interested in. We will not pass Enquiry Data to any other person or business for any other reason.
2.3 Identity Data.
If you engage us to provide services, depending on the nature of those services, it may be necessary for us to collect and process Personal Data to enable us to check and verify your identity. This identity data may include your name, address, telephone number, date of birth, passport details and other information or documents we may be required for legal or regulatory purposes to collect. The legal basis for this processing is the performance of our contract with you and to comply with our legal and regulatory obligations.
2.4 Transaction Data.
We may collect and process Personal Data relevant to our services that you may discuss with and the engage us to perform, such as names and contact details for the people we may be working with or customer information you may provide us. We may also keep written records and notes of our telephone calls, correspondence (written and electronic) and meetings with you.
The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and to comply with our legal and regulatory obligations.
2.5 Website Data.
We may process data about your use of our website and services provided on it. The Website Data may include your IP address, geographical location, browser type and version, time zone setting, browser plug-in types, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use.
We collect this Personal Data by using cookies, server logs and other similar technologies. Please see our Cookie Policy at [hyperlink to policy].
Website Data may be processed for the purposes of analysing and improving the experience of using our website and services.
The legal basis for this processing is our legitimate interests in monitoring and improving our website and services.
2.6 Communication Data.
We may process data about your communications with us, whether sent or received by telephone or in written form, including by post, email or when you input any text into the contact or feedback features of our website or any of the services provided on it. The Communication Data may include a copy of the text of any communication between us or notes of such communication where that communication is by phone. Communication Data may be linked to your Identity Data.
The legal basis of this processing is our legitimate interest in monitoring and improving the delivery of any services to you and as a record in the event of any dispute between us or to comply with good business practices.
2.7 Other Processing Activities.
In addition to the specific purposes for which we may process your Personal Data set out above, we may also process any of your Personal Data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
2.8 Consent.
Generally, we do not rely on consent as a legal basis for processing your Personal Data except as set out in the “Promotional Communications Including Newsletters” section below. You have the right to contact us to withdraw consent to marketing at any time.
2.9 Special Categories of Personal Data.
We do not expect to collect or process any Special Categories of Personal Data from you, whether your own or your customers’ Personal Data (this includes details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about health, and genetic and biometric data). Nor, unless we are required by law for a specific purpose to do so, do we collect any information about criminal convictions and offences. In the event our engagement with you requires us to collect or process any Special Categories of Personal Data, this will be subject to a specific and more detailed data processing agreement with you.
3. PROVIDING YOUR PERSONAL DATA TO OTHERS
3.1 Professional Advisers and Consultants.
We may disclose your data to third party professional advisers engaged in the transaction where necessary for the purposes of providing our services to you, e.g. solicitors, accountants, architects, tax advisers or other property consultants or experts. Our professional advisors and consultants are bound by confidentiality obligations and only process any Personal Data as instructed by us.
3.2 Our Specialist Technical Partners.
We may disclose your data to specialist third-party IT and technical system partners that we work with to provide services through our website for the purposes of our contract with them and to best ensure we are able to perform our contract with you. Some of our specialist technical partners may be located outside the European Economic Area (EEA) and any transfer of your Personal Data will be subject to the provisions of Section 4, below. Our specialist technical partners are bound by confidentiality obligations and only process any Personal Data as instructed by us.
3.3 Other Third Parties.
We may disclose your data to other third parties where it is necessary for us to do so in order to provide services to you or to comply with a legal or regulatory obligation.
3.4 Our Insurers and Brokers.
We may disclose your Personal Data to our insurers and insurance brokers insofar as is reasonably necessary and proportionate for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.
3.5 Provision of your Personal Data to any Third Party.
Where we share your Personal Data with any third party, we will ensure this processing is protected by appropriate safeguards, including a suitable data processing agreement with that third party.
3.6 To Comply with Legal Obligations.
In addition to the specific disclosures of Personal Data detailed above, we may also disclose your Personal Data where such disclosure is necessary for compliance with a legal or regulatory obligation we have to comply with, or in order to protect your vital interests or the vital interests of another individual.
3.7 Other.
We may also need to share some Personal Data with other parties, such as a potential buyer 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.
4. DATA SECURITY
4.1 We have put in place appropriate organisational and technical security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.
4.2 We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator (in the UK, the ICO) of a breach where we are legally required to do so.
5. MARKETING COMMUNICATIONS
5.1 We may use your Personal Data, including Enquiry Data and Communication Data to send you marketing communications (by email, text message, telephone or post), including updates about developments in our business that might be of interest to you, newsletters and/or information regarding our services.
If you are a client / customer of ours and you have not “opted out” from receiving such marketing communications, we have a legitimate interest in processing your Personal Data for promotional purposes. This means we do not usually need your consent to send you promotional communications, including newsletters. If you are not a client / customer of ours (for example if you have only made an enquiry) and your consent to receive marketing communications is needed, we will ask for this consent separately and clearly.
We will always treat your Personal Data with the utmost respect and never sell or share it with other organisations for marketing purposes, except where we have obtained your consent in advance. You have the right to opt out of receiving promotional communications at any time by using the ‘unsubscribe’ link in any emails we may send you, or contacting us by email at:
contactus@theripplestudios.com
6. TRANSFERS OF YOUR PERSONAL DATA OUTSIDE OF THE EUROPEAN ECONOMIC AREA (EEA)
6.1 Your Personal Data may be transferred and stored outside of the EEA. It may also be processed by our staff, or those of our suppliers, operating outside of the EEA.
6.2 Where your Personal Data is transferred outside of the EEA, we will ensure that either (a) The European Commission has made an "adequacy decision" with respect to the data protection laws of the country to which it is transferred, or (b) where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield, which requires them to provide similar protection to Personal Data shared between Europe and the US; or (c) we have entered into a suitable data processing agreement with the third party situated in that country to ensure the adequate protection of your data. In all cases, transfers outside of the EEA will be protected by appropriate safeguards.
7. RETAINING AND DELETING PERSONAL DATA
7.1 Personal Data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
7.2 Unless we contact you and obtain your consent for us to retain your Personal Data for a longer period, we will retain and delete your Personal Data as follows:
a. Enquiry Data will be retained for 3 years following the date of our last contact or dealing with you, at the end of which period it will be deleted from our systems, except as may be required for any applicable legal or regulatory compliance purposes.
b. Website Data will be retained for 3 years following the date of our last contact or dealing with you, at the end of which period it will be deleted from our systems.
c. Identity Data and Transaction Data will be retained after we have finished providing our services to you. This is in order for us to respond to any questions, complaints or claims made by you or on your behalf and/or to keep records required by law. In most cases this data will be retained for no more than 7 years following the end of the completion of our services.
d. Communications Data will generally be retained for the same period as Transaction Data above.
7.3 We may retain your Personal Data for a longer period where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
8. AMENDMENTS
8.1 We may update this policy from time to time by publishing a new version on our website or sending a copy to you.
8.2 We may notify you of changes to this policy by email or by placing a notice to that effect our website or log-in page of any service of ours you may use.
9. YOUR RIGHTS
9.1 You may instruct us to provide you with any Personal Data we hold about you; provision of such information will be subject to:
a. your request not being unfounded or excessive, in which case a charge may apply; and
b. the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).
9.2 We may withhold Personal Data that you request to the extent permitted by law.
9.3 You may instruct us at any time not to process your Personal Data for marketing purposes.
9.4 In practice, you will usually either expressly agree in advance to our use of your Personal Data for marketing purposes, or we will provide you with an opportunity to opt out of the use of your Personal Data for marketing purposes.
9.5 The rights you have under data protection law are:
a. the right to access;
b. the right to rectification;
c. the right to erasure; the right to restrict processing;
d. the right to object to processing;
e. the right to data portability;
f. the right to complain to a supervisory authority; and
g. the right to withdraw consent.
9.6 Your right to access your data.
You have the right to ask us to confirm whether or not we process your Personal Data and, to have the right to access to the Personal Data, and any additional information. That additional information includes the purposes for which we process your data, the categories of Personal Data we hold and the recipients of that Personal Data. You may request a copy of your Personal Data. The first copy will be provided free of charge, but we may charge a reasonable fee for additional copies.
9.7 Your right to rectification.
If we hold any inaccurate Personal Data about you, you have the right to have these inaccuracies rectified. Where necessary for the purposes of the processing, you also have the right to have any incomplete Personal Data about you completed.
9.8 Your right to erasure.
In certain circumstances you have the right to have Personal Data that we hold about you erased. This will be done without undue delay. These circumstances include the following: it is no longer necessary for us to hold Personal Data in relation to the purposes for which they were originally collected or otherwise processed; you withdraw your consent to any processing that requires consent; the processing is for direct marketing purposes; and the Personal Data have been unlawfully processed. However, there are certain general exclusions of the right to erasure, including where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal or regulatory obligation; or for establishing, exercising or defending legal claims.
9.9 Your right to restrict processing.
In certain circumstances you have the right for the processing of your Personal Data to be restricted. This is the case where: you do not think that the Personal Data we hold about you is accurate; your data is being processed unlawfully, but you do not want your data to be erased; it is no longer necessary for us to hold your Personal Data for the purposes of our processing, but you still require that Personal Data in relation to a legal claim; or you have objected to processing, and are waiting for that objection to be verified. Where processing has been restricted for one of these reasons, we may continue to store your Personal Data. However, we will only process it for other reasons: with your consent; in relation to a legal claim; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
9.10 Your right to object to Processing.
You may object to us processing your Personal Data on grounds relating to your particular situation, unless our legal basis for the processing is that it is necessary for: the performance of a task carried out in the public interest, or in the exercise of any official authority vested in us; or the purposes of our legitimate interests or those of a third party. If you make an objection, we will stop processing your Personal Data unless we are able to: demonstrate compelling legitimate grounds for the processing, and that these legitimate grounds override your interests, rights and freedoms; or the processing is in relation to a legal claim.
a. Your right to object to direct marketing.
You may object to us processing your Personal Data for direct marketing purposes. If you make an objection, we will stop processing your Personal Data for this purpose.
b. Your right to object for statistical purposes.
You may object to us processing your Personal Data for statistical purposes on grounds relating to your particular situation, unless the processing is necessary for performing a task carried out for reasons of public interest.
9.11 Automated data processing.
To the extent that the legal basis we are relying on for processing your Personal Data is consent, and where the processing is automated, you are entitled to receive your Personal Data from us in a structured, commonly used and machine-readable format. However, you may not have this right if it would adversely affect the rights and freedoms of others.
9.12 Your right of data portability.
We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
9.13 Complaining to a supervisory authority.
If you think that our processing of your Personal Data infringes data protection laws, you can lodge a complaint with a supervisory authority responsible for data protection. You may do this in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
9.14 Right to withdraw consent.
To the extent that the legal basis we are relying on for processing your Personal Data is consent, you are entitled to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
9.15 Exercising your Rights.
You may exercise any of your rights in relation to your Personal Data by written notice to us in addition to methods specified above.
10. COOKIE POLICY
10.1 For information about how we use Cookies please see our Cookie Policy at:
[link to cookies policy]
11. OUR DETAILS
11.1 You can contact us:
a. by post, using the following postal address: Ripple Studios Limited, c/o Crown House, 27 Old Gloucester Street, London, WC1N 3AX;
b. by telephone, on +44 203 488 0983 or the contact number published on our website from time to time; or
c. by email, by using: contactus@theripplestudios.com or the email address published on our website from time to time.
Copyright © 2023 Ripple Studios Ltd - All Rights Reserved.
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