Emotional Logic respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.
You can view this policy on our websites www.emotional-logic.co.uk and our separate privacy notice which applies to our market research candidates so that they understand what it is that we do with their personal data. You can view this by clicking here.
Please also use the Glossary at the end to understand the meaning of some of the terms used in this Privacy Notice.
WHO WE ARE
Emotional Logic Limited is a company registered in England. Our registered address is Studio 18, the Kiln, Hoult’s Yard, Walker Road, Newcastle upon Tyne, NE6 1AB. Our company number is 06057985.
We are the data controller when we collect personal information (sometimes called personal data) from our customers, prospective customers and suppliers.
We will not pass your personal data on to any third party unless required to do so by law or if you have given us separate written permission to do so. This may occur, for example, where you have asked us to provide personal data to a third party as part of a wider commercial project, but we will only do so under your express instructions.
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Privacy Notice. If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Name of data privacy manager: Annett Pecher
Email address: firstname.lastname@example.org
Postal address: Studio 18, the Kiln, Hoult’s Yard, Walker Road, Newcastle upon Tyne, NE6 1AB, United Kingdom
Telephone number: +44 (0) 191 265 3248
Inform Us of Changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third Party Links
Our websites may include links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and process different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, last name, job title and gender.
- Contact Data includes business address (including home address if you conduct business from your home address), email address and telephone numbers.
- Finance Data includes bank account and payment details (where you pay for our services or we pay you for your services from a non-business account).
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website or email communication from us.
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
The personal data we process differs depending upon our interactions with you and can be summarised as follows:
If you contact us by making an Enquiry (either via the Contact Us form on our website, via email or telephone) then we will record the contact details that you supply to us. We will contact you about the enquiry that you have made and send you information relevant to the nature of your enquiry.
If you are a Customer, then we need to keep your name and your contact details. We will contact you about the services you have asked us to provide and we may ask for your feedback shortly afterwards. If you pay by cheque, we do not record your bank details. If you pay electronically, we do not receive your full bank details (only a reference).
If you are a Supplier, then we need to keep your name and your contact details. If you are VAT registered, then we keep a record of your VAT number. We will contact you about the goods and/or services you provide to us. If you give us your bank details to pay you electronically then we will keep these on file.
This website is not intended for children and we do not knowingly collect data relating to children.
Special Category Data
We do not anticipate that any special category data will be processed by us in our business relationship with you.
HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us using the details above.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. We hold data processing records which demonstrate the lawful bases we rely upon to lawfully process your personal data. Please contact us if you need details about this.
We may have to share your personal data with the parties set out below for the purposes for which we process your data. This will only occur in limited circumstances to the following:
- External Third Parties:
- Service providers and agents who process data on our behalf e.g. internet service, software, back-up and platform providers, telecoms providers and those organisations we engage to help us send communications to you.
- Professional advisers including lawyers, bankers, auditors and insurers based who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
- Other third parties where you have given us your consent for us to do so (see below).
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. If your personal data is transferred to, stored at or otherwise processed in a country or territory outside the EEA, and that country or territory has not been recognised as providing an adequate level of data protection, we will put in place additional safeguards to protect your personal data.
These safeguards will ensure a similar degree of protection is afforded to it by confirming that at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield or some future transfer mechanism endorsed by the European Commission which requires that provider to provide similar protection to personal data shared between the Europe and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place appropriate 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.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How Long Will You Use My Personal Data For?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available in our Data Retention Policy which you can request from us by contacting us.
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
You have the right to:
Request Access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request Correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request Erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object To Processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request Restriction of Processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the Transfer of your personal data to you or to a third party. 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.
Withdraw Consent at Any Time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
No Fee Usually Required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What We May Need From You
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request, to speed up our response.
Time Limit Within Which To Respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or if you have made a number of requests. In this case, we will notify you and keep you updated.
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be made available on this page.
This Privacy Notice was last updated on 17 February 2020.