whitefox Publishing Limited (“whitefox”, “we”, “us” and “our”) is committed to protecting and respecting your privacy.
This Policy sets out:
1. what personal data we collect about you and how;
2. our lawful basis for using that information and why we use that information;
3. who we may share that information with;
4. where we store that information;
5. your rights under Data Protection laws, and;
6. how long we will retain your information.
For the purpose of the Data Protection laws, the data controller is whitefox Publishing Limited, 39 Roderick Road, London NW3 2NP.
Third party websites Our sites (as defined below) may include external links to other websites, which may be operated by third parties. Clicking on these links may allow the collection or sharing of personal data about you in ways which may differ from the terms set out here. We are not responsible for the privacy policies, contents or practices of third party websites, and encourage you to read the privacy policies of every external website you visit from our sites.
1. What information do we collect about you? 1.1 We may process information you have given us by filling in forms on our websites which include but are not limited to ‘www.wearewhitefox.com’ (collectively known as “our sites”) or by corresponding with us by phone, email or otherwise. This includes personal data you provide when you:
- a) apply for or enquire about our services;
- b) subscribe to our publications;
- c) enter into competitions, surveys or promotions that we may run from time to time;
- d) give us feedback;
- e) contact us;
- f) request marketing to be sent to you.
1.2 This information may include:
- a) your name;
- b) address;
- c) date of birth;
- d) e-mail address;
- e) mobile phone number;
- f) details of your company;
- g) details of your past, future or current projects, engagements or ideas, including photographs where relevant;
- h) other personal data that may relate to the reason why you are corresponding with us;
- i) feedback and survey responses;
- j) marketing preferences.
1.3 With regard to each of your visits to our site we may automatically collect the following information:
- a) technical information, including the Internet protocol (IP) address used to connect your computer to the internet, browser type and version, time zone setting, browser plug-in types, and;
- b) information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products viewed or searched for; page response times, download errors, lengths of visits to certain pages, page interaction (such as scrolling, clicks and mouse-overs), methods used to browse away from the page and any phone number used to call us.
- 2. How will we use your personal information? a) where it is necessary for our legitimate interests (or those of a third party) namely providing you with information that you request, contacting you to establish how and if we can assist you and enabling the management of all matters relating to our business, but only where your interests and fundamental rights do not override those interests;
- b) where you have given your consent and that consent has not subsequently been withdrawn by you.
2.1 We will only use your information when it is fair and lawful to do so. Most commonly, we will use your personal information in the following circumstances:
2.2 We may also use your personal information in the following circumstances, which are likely to be rare:
- a) where we need to protect your interests (or someone else’s interests);
- b) where we are required to do so by a legal or regulatory obligation;
- c) where it is needed in the public interest.
2.3 The information we collect about you may be used in the following ways:
- a) to provide you with the information and/or services that you request from us, for example to discuss a potential project or collaboration;
- b) to draft, create and/or publish blogs or articles that may reference or quote you or the work that you may be involved with;
- c) if you are applying for a position to work for whitefox, we will use your personal information to assess your suitability for the role, to contact you for further information or, if relevant, to invite you to interview;
- d) to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- e) for internal training purposes;
- f) to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
- g) as part of our efforts to ensure the security of our sites and services.
2.4 Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before 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.
3. Who we may share your information with 3.1 We may share your information to third parties where this is necessary, for the purposes set out in the policy including:
- a) suppliers, consultants and sub-contractors for the performance of any contract we enter into with them or you;
- b) analytics and search engine providers that assist us in the improvement and optimisation of our site.
3.2 We may disclose your personal information to third parties:
- a) in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
- b) if whitefox or substantially all of its assets are acquired by a third party, in which case personal data held by it about its clients, freelancers, marketing contacts, website data and other contacts may be one of the transferred assets;
- c) if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of business and other agreements from time to time; or to protect the rights, property, or safety of whitefox, our employees, our clients or others. This includes exchanging information with other companies and organisation for the purposes of fraud protection and credit risk reduction.
4. Where we store your data
4.1 We have put in place appropriate security measures to prevent your personal data from being accidentally lost, misused 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 with a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality and where necessary, a non-disclosure agreement.
4.2 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.
4.3 We use Google Analytics to collect information about your visit to our site for the purposes outlined above. This information may be transferred and stored outside of the European Economic Area (“EEA”). Where any transfer is made to a country outside of the EEA and the European Commission has not made an adequacy decision in relation to the laws of that country we will ensure that appropriate safeguards are in place prior to any transfer of your data. Those safeguards are likely to consist of either the use of standard data protection clauses adopted or approved by the European Commission or transfer to a US based recipient which is a member of the EU-US Privacy Shield self-certification arrangement or an equivalent regime.
5. Your rights under Data Protection law
5.1 Under certain circumstances, the law permits that you have the right to:
- a) access your information; You are entitled to request access to the information we hold about you (known as a
- ‘data subject access request’). You are entitled to receive a copy of the personal information we hold about you and to check that it is being lawfully processed.
- b) correct your information; If the information we hold for you is incomplete or incorrect, you have the right to request a correction.
- c) request erasure; Where there is no lawful reason for continuing the processing of your personal information, you are able to request the removal or deletion of the personal information.
- d) object to processing; Where the firm relies on legitimate interest for the processing of your personal information, or for the purposes of direct marketing, you have the right to object to the processing.
- e) request the restriction of processing; You are entitled to request for a suspension for the processing of your personal information, for example, if you are awaiting the reasons for the processing of the information or require us to establish its accuracy.
- f) transfer your personal information; You are able to request the transfer of your personal information to another party.
5.2 If you would like to exercise any of the rights outlined above, please contact [email protected]
5.3 These rights are available to you at no cost; however we may charge a reasonable fee where a request is deemed to be excessive or unfounded. In such circumstances, we may otherwise refuse to comply with the request.
5.4 If you consider that our processing of your personal information infringes the Data Protection laws, 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.
6. How long is your personal data retained?
6.1 We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any regulatory, tax or accounting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
6.3 It is not always possible to specify in advance the length of time your personal information will be retained due to the nature of the services we offer. The retention of your personal data will be determined based on statutory authority, the nature of your relationship with the firm, the nature and sensitivity of the personal information, the purposes for which the information is being processed and whether there are other means to achieve those purposes.
6.4 Personal information may be retained for as long as necessary to comply with our legal or regulatory obligation, or in order to protect yours or another person’s vital interest.
If you have any questions about the information contained in this privacy notice or about how we process your data, please contact [email protected]