PRIVACY NOTICE

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This Privacy Notice (“Privacy Notice”) applies to the processing of personal data in connection with the provision of the Superframe website at www.superframe.agency  (the “Site”), and all of the goods and services that Superframe (“Superframe”, “we”, “us, “our”) offer. We respect the privacy of every person who visits our Site and/or uses our Services - this includes those people participating in our research endeavours.

1. Purpose of this privacy notice

This Privacy Notice explains our approach to any personal data that we might collect from you or which we have obtained about you from a third party and the purposes for which we process your personal data. This Privacy Notice also sets out your rights in respect of our processing of your personal data.

When we talk about “personal data”, we mean any information which relates to an identified or identifiable living individual. Individuals might be identified by reference to a name, an identification number, location data, an online identifier (such as an IP address) or to other factors that are specific to them, such as their physical appearance.

This Privacy Notice informs you of the nature of the personal data about you that is processed by us and how you can request that we delete it, update it, transfer it and/or provide you with access to it.

This Privacy Notice is intended to assist you in making informed decisions when using the Site and our Services. Please take a moment to read and understand it. It should be read in conjunction with our Cookie Policy.

This Privacy Notice only applies to the use of your personal data obtained by us, whether from you directly or from a third party. It does not apply to personal data collected by third parties during your communications with those third parties or your use of their products or services (for example, where you follow links to third party websites over which we have no control, or you purchase goods or services from those third parties).

 

2. About us

The Site and our Services are made available by Superframe. Superframe is the data controller responsible for your personal data.

Superframe Limited (company no: 13348919) is an English company with its registered office at 23 Chiltern Drive, Surbiton, Surrey, United Kingdom, KT5 8LP.

 

3. How to contact us

If you have any questions about this Privacy Notice or want to exercise your rights set out in this Privacy Notice, you can contact us by:

sending an email to sebastien.vanlaere@superframe.agency;
writing to 69 Anerley Road, SE192AS, London, England.

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4. How we collect and receive personal data

We collect and receive personal data using different methods:

Personal data you provide to us
You may give us your personal data directly. This will be the case when, for example, you contact us with enquiries, participate in our research or complete forms on our Site or provide feedback to us.

Personal data we collect using cookies and other similar technologies
When you access and use our Site, we will collect certain technical information about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies (see the “Our use of cookies and similar technologies” section below).

Personal data received from third parties
From time to time, we will receive personal data about you from third parties. Such third parties may include analytics providers, payment providers and third parties that provide technical services to us so that we can operate our Site and provide our Services.

Publicly available personal data
From time to time we may collect personal data about you (including your contact details, biography, interests or affiliations) from publicly available sources (including open source data sets), media reports or that you or a third party may otherwise make publicly available (for example through speeches at events or publishing articles or other news stories or posts on social media platforms).

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5. Who we collect personal data about

We collect and process personal data from the following people:

Site visitors
If you browse our Site, register for updates on our Site, contact us with an enquiry through our Site, submit a complaint through our Site or use any Services available on our Site, we will collect and process your personal data in connection with your interaction with us and our Site.

Customers
If you buy products or services from us, we may collect and process your personal data in connection with the supply of goods or services to you.

 

Research participants

If you take part in our research, we may collect and process your personal data in connection with the project.

Personnel that work for our partners and suppliers (including subcontractors)
If you (or your organisation) supply products or services to us or otherwise partner with us, we may collect and process your personal data in connection with our receipt of those products and services and/or partnership. This may include personal data included in any email or telephone communications or recorded on any document relating to an order for the products or services.
 

 

6. Personal data we collect

We use your personal data for the following purposes:

Fulfilment of our Services
We collect and maintain personal data that you submit to us for the purpose of supplying Services that you have requested from us via our Site or where we contract with you to provide our Services. We may collect and process your personal data whether you are interacting with us on your own behalf or on behalf of any organisation you represent.

The personal data we process may include your name and contact information (such as email address, postal address and telephone number) and your payment information (where applicable). We process this information so that we can fulfil the supply of Services, maintain our user databases and to keep a record of how our Services are being used.

Our legal basis for processing: It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you, or it is in our legitimate interest or a third party’s legitimate interest to use personal data in such a way to ensure that we provide the our Services in an effective, safe and efficient way.

Linking to social media sites and interacting with our social media pages
If you click on one of the social media links on our Site or otherwise interact with our social media pages such as on Linkedin (including interacting with any ‘like’ or similar embedded features on our Site or social media accounts) we and the relevant social media platform may receive information relating to such interaction and may share your personal data in connection with this purpose. For more information about how we use this personal data, please see the Insight and Analysis section below.

Please note that we are a joint controller with the relevant social media platform in respect of the personal data we use which is collected via your use of our social media pages. Your personal data may be used by the relevant social media platform for additional purposes. For details of how the relevant social media platform uses your personal data, please see the privacy policy of the relevant social media platform.

Our legal basis for processing: It is in our legitimate interest or a third party’s legitimate interest to use personal data in such a way to ensure that we provide the Site and our Services in an effective way and to promote our Site and our Services via social media.

Customer service and general enquiries
Our Site feature a “Get in touch” page which invites you to submit general enquiries about our Site and our Services by email, telephone or post.

When you make an enquiry, we will collect and process your name, contact information (including email address and/or telephone number) and any other personal data that is relevant to your enquiry. We use this information to manage and respond to your enquiry.

Our legal basis for processing: It is in our legitimate interest to use your personal data in the ways described above to ensure that we are able to help you with your enquiry and provide a good standard of service to you.

Email marketing activities
We use your name and email address to send you (or the organisation you represent) marketing communications by email. Our email  marketing communications will include press releases, information, thought pieces, articles and details for events, as well as general information about our organisation, our Site and the Services we provide.

We may share your personal information with a variety of this party email who assist us in delivering our email marketing campaigns, newsletters and other mass emails  to you.

Our legal basis for processing: Where data that we process is anonymised, we do not require a legal basis to use it as the information does not constitute personal data. However, our collection and use of such anonymised information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.

Where your personal data is not in an anonymous form (for example, your email address), it is in our legitimate interest to use your personal data for e-mail marketing purposes.

We will only send you marketing communications by email where you have consented to receive such communications, or where we have another lawful right to send such communications to you.

Receipt of services from suppliers
If we have engaged you or the organisation you represent to provide us with products or services (for example, if you or the organisation you represent provide us with services such as IT support, production or financial advice), we will collect and process your personal data in order to manage our relationship with you or the organisation you represent, to receive products and services from you or the organisation you represent and, where relevant, to provide our Services to others.

The personal data we collect from you may include your name, job title, contact information (including email address, telephone number and postal address), bank account or other payment details and any other personal data you volunteer which is relevant to our relationship with you or the organisation you represent.

Our legal basis for processing: It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you or it is in our legitimate interest to use personal data in such a way to ensure that we have an effective working relationship with you or the organisation you represent and are able to receive the services that you or your organisation provides, and provide our Services to others, in an effective way.

Business administration and legal compliance
We use your personal data for the following business administration and legal compliance purposes:

- to comply with our legal obligations;

- to enforce our legal rights;

- to protect the rights of third parties; and

- in connection with a business transition such as a merger, reorganisation, acquisition by another company, or sale of all or a portion of our assets.

Our legal basis for processing: Where we use your personal data in connection with a business transition, to enforce our legal rights or to protect the rights of third parties, it is in our legitimate interest to do so. For all other purposes described in this section, we have a legal obligation to use your personal data to comply with any legal obligations imposed upon us such as a court order.

Any other purposes for which we wish to use your personal data that are not listed above, or any other changes we propose to make to the existing purposes, will be notified to you using the contact details we hold for you.

 

7. If you fail to provide your personal data

Where we are required by law to collect your personal data, or we need to collect your personal data under the terms of a contract we have with you, and you fail to provide that personal data when we request it, we may not be able to perform the contract we have or are trying to enter into with you. This may apply where you do not provide the personal data we need in order to provide the Services you have requested from us or to process an application for employment with us. In this case, we may have to cancel your application or the provision of the relevant Services to you, in which case we will notify you.

8. How we obtain your consent

Where our use of your personal data requires consent, you can provide or withdraw such consent:

at the time we collect your personal data following the instructions provided; or
by informing us using the contact details set out in the “About” section.

 

9. Our use of cookies and similar technologies

Our Site may use certain cookies, web beacons, pixel tags, log files and other technologies. Please see our Cookie Policy to find out more about the cookies and other similar technologies we use, the purposes for which we use them and how to manage, block or delete them.

 

10. Third party links and services

This Privacy Notice does not apply to your interaction with services provided by third parties.

Our Site may contain links to third party websites and services.

When you use a link to go from our Site to another website (even if you don’t leave our Site) or you request a service from a third party, this Privacy Notice shall not apply to the processing of your personal data carried out by the relevant third party provider.

Your browsing and interactions on any other websites, or your dealings with any other third party service provider, is subject to that website’s or third party service provider’s own rules and policies.

We do not monitor, control or endorse the privacy practices of any third parties.

We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you use in connection with your interaction with us and to contact them if you have any questions about their respective privacy notices and practices.

This Privacy Notice applies solely to personal data processed by us through your use of our Site, your receipt of our Services and/or in connection with our business operations. It does not apply to the processing of your personal data by these third party websites and third party service providers.

 

11. Sharing personal data

We will only share personal data with others when we are legally permitted to do so. When we share personal data with others, we put contractual arrangements and security mechanisms in place to protect the personal data shared and to comply with our data protection, confidentiality and security standards and obligations.

When processing your personal data, we may need to share it with third parties as follows:

Third-party organisations that provide applications/functionality, data processing or IT services: We share personal data with third parties who support us in providing our Services and help provide, run and manage our internal IT systems. Such third parties may include, for example, providers of information technology, cloud-based software as a service providers, identity management, website hosting and management, data analysis, data back-up, security and storage services. We also share your personal data with third-party service providers to assist us with insight analytics. These providers are described in our Cookie Policy.

Payment providers and banks: We share personal data with third parties who assist us with the processing of payments and refunds.
Event partners and suppliers: When we run events, we will share your personal data with third-party services providers that are assisting us with the operation and administration of that event. If we are running an event in partnership with other organisations, we will share your personal data with such organisations for use in relation to the event.

Third-party email marketing and CRM specialists: We share personal data with specialist suppliers who assist us in managing our marketing database and sending out our email marketing communications and membership-related communications.

Recruitment agencies and related organisations: We share personal data with external recruiters, third-party providers that undertake background checks on our behalf.

Auditors, lawyers, accountants and other professional advisers: We share personal data with professional services firms who advise and assist us in relation to the lawful and effective management of our organisation and in relation to any disputes we may become involved in.
Law enforcement or other government and regulatory agencies and bodies: We share personal data with law enforcement or other government and regulatory agencies or other third parties as required by, and in accordance with, applicable law or regulation.
Sharing with other third parties: Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, or to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.
This list is non-exhaustive and there may be circumstances where we need to share personal data with other third parties in order to operate our Site and to provide our Services.

 

12. How long we keep your personal data

In respect of personal data that we process in connection with the supply of our Services, we may retain your personal data for up to six years from the date of supply of the relevant Services and in compliance with our data protection obligations. We may then destroy such files without further notice or liability.

In respect of any other personal data that we process, we will retain relevant personal data for up to three years from the date of our last interaction with you and in compliance with our data protect obligations. We may then destroy such files without further notice or liability.

If any personal data is only useful for a short period (e.g. for a specific event or marketing campaign or in relation to recruitment), we will not retain it for longer than the period for which it is used by us.

If you have opted out of receiving marketing communications from us, we will need to retain certain personal data on a suppression list indefinitely so that we know not to send you further marketing communications in the future.

 

13. Confidentiality and security of your personal data

We are committed to keeping the personal data you provide to us secure and we will take reasonable precautions to protect your personal data from loss, misuse or alteration.

We have implemented information security policies, rules and technical measures to protect the personal data that we have under our control from:

unauthorised access;
improper use or disclosure;
unauthorised modification; and
unlawful destruction or accidental loss.
All our employees and data processors (i.e. those who process your personal data on our behalf, for the purposes listed above) who have access to and are associated with the processing of personal data are obliged to respect the confidentiality of the personal data of all users of our Site and our Services.

 

14. Personal data of children

We do not specifically target our Site or our Services at children. However, due to the nature of our organisation and the Services we provide, we may from time to time collect and process personal data relating to individuals under the age of 18. Where we do so, we will comply with all applicable laws and regulations relating to the processing of personal data of minors.

 

15. How to access your information and your other rights

You have the following rights in relation to the personal data we hold about you. If you would like to exercise any of these rights, please contact us using the details set out in on our About page.

Your right of access
If you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a copy of that personal data (along with certain other details). If you require additional copies, we may charge a reasonable fee for producing those additional copies.

Your right to rectification
If the personal data we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have shared your personal data with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you who we’ve shared your personal data with so that you can contact them directly.

Your right to erasure
You can ask us to delete or remove your personal data in some circumstances, such as where we no longer need it or where you withdraw your consent (where applicable). If we have shared your personal data with others, we will let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal data with so that you can contact them directly.

Your right to restrict processing
You can ask us to ‘block’ or suppress the processing of your personal data in certain circumstances such as where you contest the accuracy of that personal data or you object to us processing it for a particular purpose. This may not mean that we will stop storing your personal data but, where we do keep it, we will tell you if we remove any restriction that we have placed on your personal data to stop us processing it further. If we’ve shared your personal data with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal data with so that you can contact them directly.

Your right to data portability
You have the right, in certain circumstances, to obtain personal data you have provided to us (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer it to a third party of your choice.

Your right to object
You can ask us to stop processing your personal data, and we will do so, if we are:

- relying on our own or someone else’s legitimate interest to process your personal data, except if we can demonstrate compelling legal grounds for the processing; or

- processing your personal data for the purposes direct marketing.

Your rights in relation to automated decision-making and profiling
You have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for the entering into, or the performance of, a contract between you and us.

Your right to withdraw consent
If we rely on your consent (or explicit consent) as our legal basis for processing your personal data, you have the right to withdraw that consent at any time. You can exercise your right of withdrawal by contacting us using our contact details in the “Get in touch” section above or by using any other opt-out mechanism we may provide, such as an unsubscribe link in an email.  

Your right to lodge a complaint with the supervisory authority
If you have a concern about any aspect of our privacy practices, including the way we have handled your personal data, please contact us using the contact details provided in the “About” section. You can also report any issues or concerns to a national supervisory authority in the Member State of your residence or the place of the alleged infringement. You can find a list of contact details for all EU supervisory authorities at: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. As we are incorporated in the UK, our regulatory authority is https://ico.org.uk.

 

16. Changes to this privacy notice

We may make changes to this Privacy Notice from time to time

To ensure that you are always aware of how we use your personal data, we will update this Privacy Notice from time to time to reflect any changes or proposed changes to our use of your personal data. We may also make changes to comply with changes in applicable law or regulatory requirements.

We will notify you by e-mail of any significant changes to this Privacy Notice. However, we encourage you to review this Privacy Notice periodically to be informed of how we use your personal data.

Last updated 28 April 2021

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