Privacy Policy

All references to ‘Formulate Digital’, ‘our’, ‘us’, ‘our site’ or ‘we’ within this policy are deemed to refer to Formulate Digital, and all other subsidiaries, affiliates, and/or associates of Creative Technologist Ltd.

At Formulate Digital, we respect your concerns about privacy and value the relationship that we have with you. This policy provides information on how we process personal information collected from users of our website.

Please read this privacy policy carefully to understand how we handle your personal data. Continued use of our site indicates you have read, understood and accepted the latest version of our privacy policy. If you do not agree to our privacy policy, please stop using our site immediately.

On a small-scale basis, we have the right to collect, process and use the following categories of personal data about you:

Personal data you provide in correspondence with us by phone, e-mail or post, including when you contact us via the ‘contact us’ form on our site. This information typically includes your name, contact details, nature of the product or service requested and related information so that we may fulfil your request.
Any other personal or private information about you that you choose to submit to our site or any of the social media platforms that we operate.
Information about your use of our site, including your cookie data, clickstream data, browsing history, location data, and preferences in relation to direct marketing.

We, or our Third Parties acting on our behalf, have the right to collect, use and store the personal data listed above for the following reasons:

To operate our business and provide you with services you have requested.
To display the content of our site, and any customisations you may select.
To verify your identity.
To acknowledge, confirm and deal with any enquiries or complaints you may send us.
To administer our site and ensure that our site is presented in the most effective manner for you and for your computer/device.
For internal business/technical operations, including troubleshooting, data analysis, reporting and business administration, testing, research, statistical and survey purposes and as part of our efforts to keep our site secure.
On an aggregate basis, to understand how individuals collectively use the features of our site.
To give effect to your legal rights and your rights under this privacy policy.
To establish or exercise and legal rights or claims such as to protect against fraud, identity theft, and other unlawful activity.
To satisfy our obligations under applicable law, this privacy policy, and any other policies or terms that are applicable to our relationship with you.
For other purposes to which you have consented such as to publish any testimonials submitted by you to promote our products on our site or in other relevant promotional materials.
We may use your personal data for undertaking marketing by email. We may send you certain marketing communications (including communications to existing customers) if it is in our legitimate interests to do so for marketing and business development purposes. However, we will always obtain your consent to direct marketing communications where we are required to do so by law and if we intend to disclose your personal data to any third party for such marketing. If you wish to stop receiving marketing communications, you unsubscribe from any marketing email or you can contact using the information in section 13.

We may also combine personal data that you provide to us with other information we collect about you for the purpose set out in the privacy policy.

We consider that the legal basis for processing your personal data are as follows:

The use of your personal data is necessary to perform our obligations under any contract with you. For example, to comply with the terms of use of our site which you accept by browsing our site.
We may use your personal data for our legitimate interests; to operate and improve our site, to provide goods and services, and to develop our business in by any means appropriate.
We will rely on your continued use of our site as consent to use your personal data for all of terms laid out in section 2. You may withdraw your consent at any time by contacting us using the information in section 13.

Our site uses cookies for a number of purposes, including to distinguish you from other users, to provide you with a good user experience when you browse our site and to allow us to improve the features of our site. For more information on cookies, view our cookie policy.

Where it is in our legitimate interest to do so, the personal data collected may be shared with our parent company, its subsidiaries, and/or any third parties who may provide services for us.

In the following situations:

To third party service providers and suppliers who support our business operations (for example, external consultants and/or agencies) subject to appropriate contractual protections in accordance with applicable law.
To third party purchasers if we sell or transfer all, or any portion, of our business or company assets to any third party. Should such a sale or transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your personal information uses it in a manner that is consistent with this privacy policy.
To law enforcement agencies, courts, regulators, government authority or any other third party where this is necessary to comply with a legal or regulatory obligation, or otherwise where it is necessary to establish, exercise or defend legal rights or claims, or for the purposes of investigating actual or suspected unlawful activity.
For monitoring, marketing and promotion purposes we may disclose and use anonymised, aggregated reporting, and statistics about the users of our website for the interest of our parent company, its subsidiaries and/or any third parties.

If you have given your consent for us to use your personal data in a particular way, but later change your mind, you should contact us, and we will stop doing so.

If we provide any personal data about you to any such non-EEA members of our group or Third-Party Sources, we will take appropriate measures to ensure that the recipient protects your personal data adequately in accordance with this privacy policy.

These measures include, but are not limited to: in the case of US based entities, entering into European Commission approved standard contractual arrangements with them, or ensuring they have signed up to the EU-US Privacy Shield (see further: https://www.privacyshield.gov/welcome); or in the case of entities based in other countries outside the EEA (including Japan), entering into European Commission approved standard contractual arrangements with them.

Further details on the steps we take to protect your personal data, in these cases is available from us on request by contacting us.

We will keep your personal data for as long as we have a relationship with you. Once our relationship with you has come to an end, we will retain your personal data for a period of time that enables us to:

Maintain business records for analysis and/or audit purposes.
Comply with record retention requirements under the law.
Defend or bring any existing or potential legal claims.
Deal with any complaints regarding our products or services.

We will delete your personal data when it is no longer required for these purposes. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.

Subject to applicable law, you may have the following rights in relation to your personal data:

The right to request access to, or copies of, your personal data that we process.
The right to request correction of any inaccuracies in your personal data.
The right to restrict our use of your personal data.
The right to object, in certain circumstances, to our processing of your personal data.
The right to request, in certain circumstances, that your personal data is deleted
The right to object to your personal data shared to a third-party provider of services;
The right to receive your personal data in a usable electronic format and transmit it to a third party (right to data portability).

If you would like further information in relation to these or would like to exercise any of your rights, please contact us using the contact details in section 13.

We will consider all such requests and provide our response within a reasonable period (and in any event any time period required by applicable law).

Please note, however, that certain personal data may be exempt from such requests in certain circumstances. If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make.

With guidance from the ICO we have made the decision that we do not need to appoint a dedicated Data Protection Officer, however, this is subject to change should the need arise.

We take the security of our customers’ data very seriously and we use appropriate measures to protect all personal information collected in a secure, controlled environment consistent with applicable data protection legislation. The personal data that we collect from you will be stored on UK based servers.

We commit to providing full training to our employees; ensuring a full knowledge of data protection laws, and how the laws may affect their job role and duties.

Our site and social media pages may, from time to time, contain links to websites operated by third parties including partner networks and our group companies. Please note that this privacy policy only applies to the personal data that we collect through our site and social media pages or which we receive from Third Party Sources, and we cannot be responsible for personal data about you that is collected and stored by third parties. Third party websites have their own terms and conditions and privacy policies, and you should read these carefully before you submit any personal data to these websites. We do not endorse or otherwise accept any responsibility or liability for the content of such third-party websites or third-party terms and conditions or policies.

Occasionally we may feel it necessary to update our privacy policy, therefore please check back frequently to check any updates or changes.

By continuing to use our site and the services it offers, (or to offer and/or provide services to us) you are confirming that you have read and understood the latest version of our privacy policy.

Our privacy policy was last updated on 17th March 2020.

Questions, comments or requests regarding this privacy policy should be sent to our registered address:

REF: Data Protection
Creative Technologist Ltd
The Parlour,
Shoelands Farm,
Seale Lane,
Puttenham,
Surrey,
GU10 1HL

or by email at info@formulatedigital.co.uk

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy.

If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to the data protection authority of the UK using their website: ico.org.uk, [LINK] or your local data protection authority (where applicable).

Before using our site, please read our cookie policy and terms of use.

Data collection

Use of data

Legal basis for use of your personal data

Cookies

Disclosure of personal data

Transfers of personal data

Retention of personal data

Your rights

Security

Third party websites

Changes to our privacy policy

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