Formative Content Limited

External Privacy Notice

Last Updated: 29/06/2023

Who we are and what we do

Who we are

We are Formative Content Limited (“Formative Content”, “us”, “we”, “our”). We are a limited company and employee owned trust registered in England and Wales under registration number 08924217 and we have our registered office at 55 Station Road, Beaconsfield, HP9 1QN. We are registered with the UK supervisory authority, Information Commissioner’s Office (“ICO”) in relation to our processing of Personal Data under registration number ZB118103. 

What we do

We are in the business of providing Corporate and business to business Digital Content Services.  We are committed to protecting the privacy and security of the Personal Data we process about you. 

Controller

Unless we notify you otherwise, we are the controller of the Personal Data we process about you. This means that we decide what Personal Data to collect and how to process it.

Processor

If Formative Content processes data about you because we have collected it or it has been provided to us by or on behalf of a Formative Content client, we are acting as a data processor and this privacy notice does not apply.  You should review the privacy notice of the Formative Content client that collected your personal data.

1. Purpose of this privacy notice 

The purpose of this privacy notice is to explain what Personal Data we collect about you and how we process it. This privacy notice also explains your rights, so please read it carefully. If you have any questions, you can contact us using the information provided below under the ‘How to contact us’ section. 

1. Who this privacy notice applies to

This privacy notice applies to you if:

1. You visit our website.

2. You purchase services from us.

3. You enquire about our services.

4. You sign up to receive newsletters and/or other promotional communications from us

5. You are supplier of goods and services to us.

6. You work for our clients or are a supplier to our clients.

1. What Personal Data is

‘Personal Data’ means any information from which someone can be identified either directly or indirectly. For example, you can be identified by your name or an online identifier. 

‘Special Category Personal Data’ is more sensitive Personal Data and includes information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the purposes of uniquely identifying someone, data concerning physical or mental health or data concerning someone’s sex life or sexual orientation.  

1. Personal Data we collect

The type of Personal Data we collect about you will depend on our relationship with you. For the type of Personal Data we collect see the table below in the section entitled ‘Purposes, lawful bases and retention periods’.

1. How we collect your Personal Data

We collect most of the Personal Data directly from you in person, by telephone, email and/or via our website.   We also collect information from your devices (including mobile devices) and applications you or your users use to access and use any of our websites, applications or services (for example, we may collect the device identification number and type, location information and connection information such as statistics on your page views, traffic to and from the sites, referral URL, ad data, your IP address, your browsing history and your web log information). We may do this using cookies or similar technologies (Please see our Cookie Notice for more information).

We may also collect your Personal Data from third parties such as: 

• reputable companies who provide lead generation contact lists 

• others to whom you have provided consent

• publicly available sources such as social media platforms 

1. Purposes, lawful bases and retention periods

We will only use your Personal Data when the law allows. Most commonly, we will use your Personal Data in the following circumstances:

 

 

Categories of individualsCategories of Personal DataPurpose of ProcessingLawful BasisClientsName, Company, job title, address, email address, phone number.To fulfil the contract for our services.ContractClients’ employees/suppliersName, company, job title, address, email address, phone number.To communicate with you regarding events we are working on together.Legitimate InterestClients/Prospective ClientsName, job title, work email address, work phone number, company you work for.To sent you newsletters and other promotional materialConsentClients/Prospective ClientsName, email address, phone number.To respond to your enquiry when you contact us via the contact us form on our website.Legitimate InterestClients/Prospective clientsName, job title, work email address, work phone number, company you work for.To maintain a suppression list when you unsubscribe from our marketing communicationsLegitimate InterestSuppliersName, company, job title, address, email address, phone numberTo interact with you to procure and pay for goods and servicesContract

Where Personal Data is processed because it is necessary for the performance of a contract to which you are a party, we will be unable to provide our services without the required information.

1. How long we keep your data

We will retain your personal data for as long as is necessary to provide you with our services and for a reasonable period thereafter to enable us to meet our contractual and legal obligations .

At the end of the retention period, your personal data will be securely deleted or anonymised, for example by aggregation with other data, so that it can be used in a non-identifiable way for statistical analysis and business planning.

1. Sharing your Personal Data

We use a number of different service providers (acting as ‘data processors’) who provide services or cloud-based software to enable us to operate our business and the services we provide to our customers. Your personal data is transferred to (and stored by) these service providers (as our ‘data processors’), who generally fall under the following categories:

• Website analytics

• Website and data hosting

• IT and system administration

• Document storage

• Email, contacts and calendar

• CRM, accounting and billing

These ‘data processors’ only process data on our behalf and won’t use your personal data for their own purposes and we only permit them to use it in accordance with our instructions and the law.

We may share your Personal Data with third parties where we are obliged to do so under other applicable law, for example:

• Government bodies, regulators and any other third parties necessary for Formative Content to meet its legal and regulatory obligations or is mandatory under applicable law.

• any third party in the context of actual or threatened legal proceedings, provided we can do so lawfully (for example in response to a court order);

• any third party in order to meet our legal and regulatory obligations, including statutory or regulatory reporting or the detection or prevention of unlawful acts;

• another organisation if we sell or buy (or negotiate to sell or buy) any business or assets;

• another organisation to whom we may transfer our agreement with you.

1. Marketing Communications

From time to time, we may use your information to contact you with details about our services which we feel may be of interest to you.  You have the right at any time to stop us from contacting you for marketing purposes. If you wish to exercise these rights you can do so by following the ‘unsubscribe’ link on any emails received or contacting us at data@formativecontent.com

 

1. International Transfers

Your Personal Data may be processed outside of the UK. This is because the organisations we use to provide our service to you are based outside the UK. 

We have taken appropriate steps to ensure that the Personal Data processed outside the UK has an essentially equivalent level of protection to that guaranteed in the UK. We do this by ensuring that:

• Your Personal Data is only processed in a country which the Secretary of State has confirmed has an adequate level of protection (an adequacy regulation), or

• We enter into an International Data Transfer Agreement (“IDTA”) with the receiving organisation and adopt supplementary measures, where necessary. (A copy of the IDTA can be found here international-data-transfer-agreement.pdf (ico.org.uk)).

1. Your rights and how to complain

You have certain rights in relation to the processing of your Personal Data, including to:

• Right to be informed

You have the right to know what personal data we collect about you, how we use it, for what purpose and in accordance with which lawful basis, who we share it with and how long we keep it. We use our privacy notice to explain this.

• Right of access (commonly known as a “Subject Access Request”)

You have the right to receive a copy of the Personal Data we hold about you.

• Right to rectification 

You have the right to have any incomplete or inaccurate information we hold about you corrected.

• Right to erasure (commonly known as the right to be forgotten)

You have the right to ask us to delete your Personal Data.

• Right to object to processing

You have the right to object to us processing your Personal Data. If you object to us using your Personal Data for marketing purposes, we will stop sending you marketing material. 

• Right to restrict processing

You have the right to restrict our use of your Personal Data. 

• Right to portability

You have the right to ask us to transfer your Personal Data to another party.

• Automated decision-making. You have the right not to be subject to a decision based solely on automated processing which will significantly affect you. We do not use automated decision-making.  

• Right to withdraw consent

If you have provided your consent for us to process your Personal Data for a specific purpose, you have the right to withdraw your consent at any time. If you do withdraw your consent, we will no longer process your information for the purpose(s) you originally agreed to, unless we are permitted by law to do so.

• Right to lodge a complaint

You have the right to lodge a complaint with the relevant supervisory authority, if you are concerned about the way in which we are handling your Personal Data. The supervisory authority in the UK is the Information Commissioner’s Office who can be contacted online at:

Contact us | ICO

Or by telephone on 0303 123 1113

How to exercise your rights

You will not usually need to pay a fee to exercise any of the above rights. However, we may charge a reasonable fee if your request is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances. 

If you wish to exercise your rights, you may contact us using the details set out below within the section called ‘How to contact us and our Data Protection Officer’. We may need to request specific information from you to confirm your identity before we can process your request. Once in receipt of this, we will process your request without undue delay and within one month. In some cases, such as with complex requests, it may take us longer than this and, if so, we will keep you updated.  

1.  How to contact us and our Data Protection Officer 

If you wish to contact us in relation to this privacy notice or if you wish to exercise any of your rights outlined above, please contact us as follows:

Formative Content Limited

55 Station Road, 

Beaconsfield, 

HP9 1QN

Email:  data@formativecontent.com

We have also appointed a Data protection Officer (“DPO”). Our DPO is Evalian Limited and can be contacted as follows:

West Lodge

Leylands Farm

Colden Common

Winchester, SO21 1TH

dpo@evalian.co.uk

03330 500111

Please mark your communications FAO the ‘Data Protection Officer’.

1. Changes to this privacy notice

We may update this notice (and any supplemental privacy notice), from time to time as shown below. We will notify of the changes where required by applicable law to do so.

Last modified 29/06/2023