This Privacy Notice is effective from 20/04/2018
Your privacy is critically important to us. At TEVIOT Creative Ltd, we have a few fundamental principles:
- We limit the collection of data for specific purposes and ensure that we have legitimate and lawful grounds for processing that data.
- We store personal information for only as long as we have a reason to keep it.
- We aim to ensure that the data we hold is accurate and up to date.
- We aim for full transparency on how we gather, use, and share your personal information.
- We implement security controls specifically to protect personal and sensitive data.
Who We Are and What This Privacy Notice Covers
We are TEVIOT Creative Ltd, a Brand and Marketing Agency based in Edinburgh, Scotland. We are registered at 7-13 Dublin Street Lane South, Edinburgh EH1 3PX.
- Using our website (teviotcreative.com and all subdomains);
- Having personal interactions via various forms of electronic messaging, voice and video communication or face to face.
- Communication of relevant marketing information that you have either consented to or otherwise expect from us as part of an established relationship.
- Out of contractual necessity such as in the delivery or products or services or the employment of our staff
- From 3rd parties with whom you have agreed for them to share your data with us.
Below we explain how we collect, use, and share information about you, along with the choices that you have with respect to that information.
Definitions you should be aware of
Personal data: “personal data” means any information relating to an identified or identifiable natural person (known as the ‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
Data Subject: The “Data Subject” is the individual that the personal data relates to and identifies
Data Controller: “Controller” This is the decision maker who decides how, when and where data under their control will be processed.
Data processor: “Processor” refers to the individual or organisation that carries out data processing activities under instruction from the Data Controller. The Data Controller may also be the Data Processor.
Processing: “Processing” processing relates to any activity carried out on personal data and includes manipulating, sharing, copying, viewing and storage of data or simply the activity of making a decision based on that data. Decision making may also include automated decision making.
Filing System: “Filing System” basically means any form of data that can be interrogated or searched, and can be digital (like a database or email system) or hard copy (like files in a filing cabinet or contact details in a rolodex).
Consent: “Consent” of the Data Subject relates to the permission to use their personal information following a clear explanation of how that data will be processed and why.
Legitimate Interest: “Legitimate interest” relates to the processing of personal on the basis that the organisation feels that their data processing activities will not infringe upon anyone’s rights or freedoms and that there is a reasonable expectation that these activities will take place.
Special Category: “Special Category” data is personal data which reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health, sex life or sexual orientation.
Data Breach: “Personal Data Breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed
Information We Collect
We only collect information about you if we have a reason to do so; for example, to provide our Services, to communicate with you, or to make our Services better.
We collect information in three ways: if and when you provide information to us, automatically through operating our services, and from outside sources. Let’s go over the information that we collect.
Information You Provide to Us
It’s probably no surprise that we collect information that you provide to us. The amount and type of information depends on the context and how we use the information. Here are some examples:
- Basic Client Information: We ask for basic information from you in order to set you up as a client in our project management software account. We require your name an email address, and a work address and that’s it. You may provide us with more information, like your business phone number or other ways to contact you, but we don’t require that information to create your profile
- Business Account Information: If you have a business account with us we will require certain information in order to fulfil our obligations to you. This information will include contact details such as email, phone number and mailing address for individuals associated with your account as well as project history in order to provide you with the best service possible.
- Billing Information: If you buy something from us, you will provide additional payment information that is required to process the transaction such as your Business Bank Account details, and contact information of other employees at your firm
Information We Collect Automatically
Log Information: Like most businesses with a web presence, we collect information that web browsers, mobile devices, and servers typically make available, such as the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information.
Location Information: We may determine the approximate location of your device from your IP address. We collect and use this information to, for example, calculate how many people visit our website from certain geographic regions. We may also collect information about your precise location via our mobile apps if you allow us to do so through your mobile device operating system’s permissions.
Information We Collect from Other Sources
We may also get information about you from other sources. For example, if you create or log into your account through another service (like Google) or if you connect your website or account to a social media service (like Twitter), we will receive information from that service (such as your username, basic profile information, and friends list) via the authorization procedures used by that service. The information we receive depends on which services you authorize and any options that are available.
From time to time we may also obtain information from third party services (for example as part of development of new business) about individuals who are not yet our clients (…but we hope will be!), which we may use, for example, for marketing and advertising purposes.
How We Use Information
We use information about you as mentioned above and as follows:
- To provide our Services, for example:
- Brand Strategy
- Creative Design Services
- Website Design and Build Services
- Client Relationship Management
- Social Media Management
- To further develop our Services – for example by adding new services that we think our clients will find beneficial
- To monitor and analyse and better understand how our clients interact with our services and team, which helps us improve, evolve and develop our Services;
- To monitor and protect the security of our work on behalf of our clients, detect and prevent fraudulent transactions and other illegal activities, fight spam, and protect the rights and property of TEVIOT Creative Ltd and others;
- To communicate information we think will be of interest to you, solicit your feedback, or keep you up to date on TEVIOT Creative Ltd and our services;
- To personalize your experience using our online services, provide content recommendations and serve relevant advertisements based on your preferences.
Sharing of Personal Data
How We Share Personal Data
We do not sell our users’ private personal information under any circumstances.
We share your personal data in the limited circumstances spelled out below and with appropriate safeguards on your privacy:
With Your Consent: We may share and disclose information with your consent or at your direction. For example, we may share your information with third parties with which you authorize us to do so. Where we require your consent to share your data with 3rd parties you will find these listed under Sharing with Third Parties.
We may also request your consent to process limited elements of your data in specific ways. Where we require this consent, it will be presented to you in a way that allows you to have a clear understanding of what you are consenting to and enable you to agree to this in a clear and positive way.
Sharing with Third Parties: We may share information about you with third party vendors who need to know information about you in order to provide their services to us. This group includes vendors that help us provide our Services to you (like payment providers that process your credit and debit card information) and those that help us understand and enhance our Services (like analytics providers). We require vendors to agree to privacy commitments in order to share information with them.
With your consent or when considered a legitimate interest that does not negatively affect your rights and freedoms as an individual, we may also share your data with other third parties. These third parties and the reason for sharing your data with them is listed below:Xero – Financial information to allow us to invoice and pay clients and suppliers.Deltek – “Traffic” is our cloud-based project management software that allow us to communicate with our clients more effectively.Catalyst2 – Hosting services related to client websites.
As Required by Law: We may disclose information about you in response to a subpoena, court order, or other governmental request.
To Protect Rights and Property: We may disclose information about you when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of TEVIOT Creative Ltd, third parties, or the public at large. For example, if we have a good faith belief that there is an imminent danger of death or serious physical injury, we may disclose information related to the emergency without delay.
Sale or Transfer: If we’re discussing selling or transferring part or all of a business, we may share information about you to prospective purchasers – but only so they can evaluate that business. If we are reorganised or sold to another organisation, we may transfer information we hold about you to them so they can continue to provide the services to you.
Publicly Shared Information
Information that you choose to make public is, you guessed it, disclosed publicly. That means, of course, that information like your public profile, posts, other content that you make public on our system. Public information may also be indexed by search engines or used by third parties. Please keep all of this in mind when deciding what you would like to share.
While no online service is 100% secure, we work very hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so. To enhance the security of your account, we encourage you to observe good security best practices with your account information, such as choosing strong passwords when registering with our systems and keeping this information secret.
We employ a range of security controls throughout our organisation to ensure that we look after your personal data and protect it from loss, corruption or unauthorised access. Our Information Protection Security Policy which outlines our commitment to protecting your data is available on request.
We only retain data for as long as is necessary to satisfy the following requirements: Legal Requirements: We are required to meet legal obligations in terms of retention periods for some data, such as financial records and information.
Contractual: Your data will be retained for the duration of your contract, as required by us to fulfil our contractual obligations. Following the end of the contract term we retain your information for a period of 1 year for marketing and business analysis purposes.
Marketing: Where data is held for marketing purposes then we hold this for 1 year of inactivity prior to destruction.
Business Analysis: Where data is held for business analysis purposes, data is limited to only that necessary to perform the analysis. We retain business analysis data for 1 year.
We always aim to keep the amount of personal data we hold to a minimum and so, unless we have received a specific request from you to erase any of your data before the retention periods expire, we will destroy/erase with an expired retention period as soon as the retention period has expired.
You have several choices available when it comes to information that we hold about you: Limit the Information that You Provide: If you have an account with us, you can choose not to provide the optional account information, profile information, and transaction and billing information. Please keep in mind that if you do not provide this information, certain features of our Services may not be accessible (contact us for more information).
Limit Access to Information On Your Mobile Device: Your mobile device operating system should provide you with the ability to discontinue our ability to collect stored information or location information via our mobile apps. If you do so, you may not be able to use certain features (like adding a location to a photograph, for example).
Opt-Out of Electronic Communications: You may opt out of receiving promotional messages from us. Just follow the instructions in those messages. If you opt out of promotional messages, we may still send you other messages, like those about your account and legal notices.
Set Your Browser to Reject Cookies: At this time TEVIOT Creative Ltd does not respond to “do not track” signals on our website. However, you can usually choose to set your browser to remove or reject browser cookies before using the teviotcreative.com website, with the drawback that certain features of the teviotcreative.com website may not function properly without the aid of cookies.
When it comes to personal data you have defined rights regarding how your data is collected, processed and shared. These rights are explained below:
The Right of Access: You have the right to request that we show you what personal data of yours we hold and process.
The Right to Withdraw Consent: Where you have specifically given us consent to process your data then you have the ability to withdraw that consent at any time. Please be aware that where that data is used to provide you with services, then withdrawal of consent to use this data may negatively impact on our ability to provide those services for you.
The Right to Erasure: In specific circumstances, you have the right to request that any data we hold on you be erased. This includes where:
- Your personal data is no longer necessary in relation to the purpose for which it was originally collected/processed.
- You withdraw consent.
- You object to the processing and there is no overriding legitimate interest for continuing the processing.
The Right to Object: There are cases where we may process some of your data in order to help us assess and improve our business. This type of processing may not be supported by a contractual requirement or your consent, but would have been carefully assessed to ensure that we have a clear legitimate interest in doing so that does not adversely affect you as an individual.
In these instances, we make you aware of these activities along with your right to object to this kind of processing should you wish.
The Right to rectification: If you become aware that any data we hold is incorrect you have the right to request that this data be corrected
The Right to Data Portability: You have the right to request that we provide you with an electronic copy of any data you have given to us as part of a contractual relationship or following your consent. This also includes any data about you that has been generated automatically as part of these agreements.
The Right to Restrict Processing: In some situation you may require us to restrict processing, such as following an objection or if data accuracy is in question. Where you exercise your right to restrict processing we shall not recommence processing without first notifying you.
Automated Decision Making: As part of our ongoing efforts to improve the speed and quality of our service we use some automated decision-making processes. These processes are designed to provide fast, consistent results based on information contained within your personal data. If you are unhappy with having automated decisions made based on your personal data then you have the right to request that these decisions are conducted by one of our staff instead.
Exercising your rights
If you wish to exercise any of your rights, we would be happy to help you. Please use the contact details below to communicate your requirements.
Other Things You Should Know
Transfer of Information outside of the EEA
Ads and Analytics Services Provided by Others
Registering a Complaint
If you have any complaints about the way in which your personal data is being handled, then please contact us using the contact details below. Alternatively, you may also contact the national supervisory authority to register a complaint, their details can be found at https://ico.org.uk
To contact us about your personal data or with any data requests, you may contact us via our Data Protection Officer who is Ed Vickers, Managing Partner, Operations, Teviot, 7-13 Dublin Street Lane South, Edinburgh, EH1 3PX. Telephone: 0131 538 8325 or via email: email@example.com.