aRCHIVED POLICIES and other information

You can view all our website policies(both past and present) and our terms and conditions here.

Privacy Policy

Bright Arts is committed to privacy.

We believe in providing you with the services and customer services you need.  Collecting data from our website visitors and customers allows us to do that.

But, your privacy is also import to us, so we are striving to handle your information in the best way possible and we are also endeavouring to collect and store only what we need.

Date of effect

This privacy notice was posted on 16th of May 2018. It is effective for new users and for all users from 20th May 2018.

Purpose of this policy

This policy aims to explain how we collect, process, store and secure your personal data through our website and other channels.

It is important that you read this notice along with any other notices that we provide that relate to the processing and collecting of your personal data. 

Important information

Scope

This privacy notice applies to any Bright Arts website, service, products, tool or application.

Children

Our websites and marketing channels are not intended for children. We do not knowingly collect any information or data on children.

data Controller

Bright Arts is the controller and responsible for your personal data. (collectively referred to as Bright Arts Ltd “we”, “us” or “our” in this privacy notice). Bright Arts also uses the trading name Bright Arts Agency.

If you have any questions about this privacy notice, you can contact us using the details below.

Your duty to inform us about changes to your personal information

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.

Your information and links to third-party websites

This website and our other media channels may include links to third-party websites. This policy does not cover those sites as we do not control them and can not be responsible for their privacy policies. Please check the Privacy Policy on each website that you visit.

Personal information we collect

Personal information, or personal data, means any information about a person from which that individual can be identified.

It does not include data where the identity has been removed.

We may collect, use, store and transfer different kinds of personal data. We have grouped that data as follows:

Identity Data includes first name, last name, username, title, date of birth and gender.

Contact Data includes billing address, email address, skype ID (or similar) and telephone numbers.

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.

Profile Data includes your purchases or orders made by you, your interests, preferences, feedback and survey responses.

Usage Data includes information about how you use our website, products and services.

Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

Financial Data includes bank account and payment card details.

We do not collect any Special Categories of Personal Data about you (this includes details about ethnicity, religious beliefs, sexual orientation, political views, union membership, information about health and genetic and biometric data). Nor do we collect any information about your convictions and offences.

Aggregated Data

We also collect, use and share Aggregated Data.

Aggregated Data may be derived from your personal data but is not considered personal data in law as it does not reveal your identity.

For example, we may aggregate your Usage Data to calculate the percentage of users opening a email newsletter.

However, if we combine or connect Aggregated Data with your personal data so that it can identify you, we will treat the combined data as personal data that will be used in accordance with this privacy notice. 

How we collect your personal information

We use a variety of methods to collect your information, these include:

 When you contact us via forms on our website, email, phone calls, text message, whatsapp, social media or other channel. Examples of this include:

  • Enquire about our services or an affiliate service
  • Create an account
  • Subscribe to our newsletter
  • Fill in a survey or take part in a competition.
  • Setting up a meeting or Skype call to discuss a project
  • Request pricing information via a form on our website

When you interact with our website or email marketing we may collect information about your browsing experience and the device and browser you are using.

For example, we use services like Google Analytics to see how people enter and exit our website.

This data is related to payments due from the service we are providing to you.

How we use your personal information

We use your data only as the law allows us to.

We typically use your data in the following ways:

  • When we need to execute the contract we have entered into with you.
  • When we need to comply with laws and regulations
  • When it is necessary for our legitimate interests of those of a trusted third party who are working on our behalf. 

Purposes for which we use your data

Below we have set out all the ways that we plan to use your personal data. Alongside the purpose, you’ll find the type of data required and also the lawful basis for using that data. 

Type of Data – 

(a) Identity, (b) Contact

Lawful basis for processing including basis of legitimate interest

Performance of a contract with you

 

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

Type of Data – 

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications 

Lawful basis for processing including basis of legitimate interest

Performance of a contract with you(a) Identity

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us) 

 

Type of Data – 

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

Lawful basis for processing including basis of legitimate interest

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey

 

Type of Data – 

(a) Identity, (b) Contact,(c) Profile,(d) Marketing and Communications 

Lawful basis for processing including basis of legitimate interest

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Type of Data – 

a) Identity

(b) Contact

(c) Technical

 

Lawful basis for processing including basis of legitimate interest

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

Type of Data – 

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

 

Lawful basis for processing including basis of legitimate interest

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

Type of Data – 

(a) Technical

(b) Usage 

Lawful basis for processing including basis of legitimate interest

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

Type of Data – 

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

Lawful basis for processing including basis of legitimate interest

Necessary for our legitimate interests (to develop our products/services and grow our business)

To deal with a general enquiry, business enquiry or set up a meeting.

Type of Data – 

(a) Identity

(b) Contact 

Lawful basis for processing including basis of legitimate interest

(a) Consent

(b) Necessary for our legitimate interests (to communicate with our customers, prospects, partners and other third parties)

 

Marketing and promotional offers

We use your personal information to provide you with relevant information, training, news, and offers that we think are a good match for you. Having your personal information helps us to do that. We endeavour to let you opt out of any marketing service you do not wish to receive.

third-party marketing

We do not share your personal data with third-party marketing companies.

opting out

You can opt out of our email newsletters by using the unsubscribe button at any time – these are in every newsletter we send.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

You can opt out marketing cookies on our website. Learn more about how we use cookies on our cookie page.

change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosure of your personal data

We may have to share your personal data with the parties set out below:

  • Internal Third Parties
  • External Third Parties
  • 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 have strict Data Processing Agreements (DPA’s) in place with third parties. For example, we have a signed DPA with Active Campaign, the company that runs and processes our email marketing and related data records.

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.

We will never share your details with third parties for marketing and advertising without clear and express permission from you.

 

International Transfers

Most of the information we hold on you will be used and stored in the UK. However, we may transfer your information overseas as some of our operations, and third party providers are not based in the UK.

We will only transfer your information where lawfully permitted and in compliance with applicable laws.

We ensure your personal data is protected by requiring all our 3rd parties to follow the same rules when processing your personal data.

These rules are called “binding corporate rules”. For further details, see European Commission: Binding corporate rules.

Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

transfers outside the EEA

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring 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. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

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. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

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 the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Data Security

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. Everyone who touches your data is subject to a duty of confidentiality and they will only process your data on your strict instructions.

We password protect all our software and hardware. Where possible we use encryption during storage and transmission of all data. All our email inboxes are password protected and encrypted by industry standard TLS. Please be aware if your email provider is not using TLS that your emails may not be encrypted.

We will also notify you and the appropriate regulators of any data breach that occurs.

Data Retention

We don’t keep your information for longer than we need to.

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.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for [six] years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see [Request erasure] below for further information.

How you can access, control, and correct your personal information

We respect your right to access, correct, request deletion, or request restriction of our usage of your personal information. You can contact the Data controller at any time for help with the following. Their contact information is further down this page.

We do our best to ensure that the data we collect is accurate and up to date.

  • You have the right to know what personal information we maintain about you
  • We will provide you with a copy of your personal information in a structured, commonly used and machine readable format on request
  • If your personal information is incorrect or incomplete, you have the right to ask us to update it
  • You have the right to object to our processing of your personal information
  • You can also ask us to delete or restrict how we use your personal information, but this right is determined by applicable law and may impact your access to some of our Services – if we can’t hold your payment details we may not be able to deliver a service for you.

Data Controller

You can contact:

Andrew Bull, Bright Arts Ltd, 187 Hillyfields, Loughton, Essex, United Kingdom, IG102PW

Contact Us

If you have any questions or a complaint about this privacy notice. You can contact us by writing to us here:

Andrew Bull, Bright Arts Ltd, 187 Hillyfields, Loughton, Essex, United Kingdom, IG102PW

Your right to file complaints with a data protection supervisory authority remains unaffected. 

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Your legal rights under GDPR

GDPR stands for General Data Protection Regulation, Europe’s new framework for data protection laws. 

The GDPR provides the following rights for individuals:

  • The right to be informed
  • The right of access
  • The right to rectification
  • The right to erasure
  • The right to restrict processing
  • The right to data portability
  • The right to object
  • Rights in relation to automated decision making and profiling.

You can learn more about your individual rights here.

If you wish to exercise any of your legal rights, please contact us here.

No fee required

Typically, we do not charge a charge a fee to comply with a person’s access request. 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 the wrong person. We may also contact you to ask you for further information so as to speed up our response.

Time limit 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 you have made a number of requests. Please, also understand that Bright Arts Ltd is a small organisation – during some circumstances, such as annual leave and sickness, requests may take longer to process.

Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

External Third Parties

  • Service providers acting as processors who provide IT and system administration services.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
  • External third parties who provide electronic / computing services, as listed below:

Name

Type of service

Data Processed

Google

Cloud based documentation software & storage

Occasional instances of customer name and email address on internally-shared documents

Active Campaign

Email automation and CRM

Name, email address, phone, services bought, services interested in, marketing preferences.