We Are Creative Equals Limited, also know as Creative Equals (“we”, “our”, and “us”) is a UK based consultancy. We are committed to protecting and respecting your privacy. 

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, or that we have received from a third party source will be processed by us.

Our site may, from time to time, contain links to and from clients, partners and social network sites. If you follow a link to any of these websites, please note that these sites have their own privacy policies and that we do not accept any responsibility or liability for those policies. Please check their privacy policies before you submit any personal data to those websites as they may not be on the same terms as ours.

In accordance with the Market Research Society Code of Conduct for Internet Surveys, in order to take part in any survey or questionnaire run by us you need to be of 16 years of age or older.

References in this policy to “data protection law” mean (as applicable) the Data Protection Act 1998, the General Data Protection Regulation (Regulation (EU) 2016/679) and all related data protection legislation having effect in the United Kingdom.

References in this policy to “data” or “information” include “sensitive personal data” and “special categories of data” (as defined under data protection law) where applicable.

1. Our details

1.1 For the purposes of our business we are the data controller.

1.2 In respect of processing that we undertake on behalf of our clients we are the data processor and our client is the data controller who determines the purpose and means of the processing of personal data which they provide us with. 

1.3 Our data protection officer can be reached at info@creativeequals.org.

2. How we use your information

2.1 The following sections set out why we are processing your information, what information we collect, the legal basis for and duration of our processing of your information and (if applicable) who your information will be shared with and where those recipients are based.

Which information do we process and for what purpose?

2.2 We process the following information from you:

2.2.1 Information you give us. This is an email address that you give us by filling in the subscription form on our site or name, email address and website URL you give when leaving a comment under our posts. It also includes any information you might provide when contacting us, such as your name, address, email address, phone number, place or work, position and gender.

2.2.2 Surveys. Where information is volunteered by you and subsequently collected that can identify you is used to provide insights and information that allow our clients to create more efficient and effective products and services for their customers or improve their practices and wellbeing of their employees. You will not be contacted by us unless you have specifically consented to us doing so.

2.2.3 Competitions and Draws. Where your information is required to identify whether you are the winner of a competition or draw this may be revealed to the appropriate client. Please refer to the individual competition rules which will refer to the requirements for publicity of winners’ names.

2.2.4 Like most other website operators, we collect non-personally identifying information of the sort that web browsers and servers typically make available. This includes technical information and information about your visit, such as records of how you navigate the pages on our site and how you interact with the pages.

2.2.5 We process information you give us and that we collect about you for the following purposes:

2.2.5.1 to fulfil our obligations under the contracts between us and our clients;

2.2.5.2 to improve our services;

2.2.5.3 to ensure that content from our site is presented in the most effective manner for you and for your computer; and

2.2.6 We process information we obtain from or are provided by third parties in order to fulfil the contractual obligation between us and our clients the purpose of which is to understand and improve the service provided by our clients.

What are the grounds for processing your information?

2.3 We are processing your data on the following ground(s):

2.3.1 you have previously given your consent to our client to the processing for the purposes stated in section 2.2, above; and/or

2.3.2 the processing is necessary for achieving our clients’ legitimate interest of receiving your feedback in respect of the goods or services you have used or purchased from them, or experience of being their partners or employees. In accordance with data protection law, we have carefully weighed your interests and fundamental rights and freedoms against our clients’ interest to process your information and are satisfied that we are justified in processing your information for this purpose

Duration and further processing

2.4 We will regularly review the personal data which we are holding about you, and will delete it as appropriate. We will store your personal data for no longer than is necessary for us to fulfil the purpose for which it was obtained, provided that we have a reasonable commercial case for doing so, and in any event for no longer than 6 months after the project has completed.

2.5 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. 

Who is your information shared with?

2.6 In order to achieve the purpose(s) set out in section 2.2 above, we will share your data in an anonymous and aggregated way only with our clients to whom your personal data is relevant.

2.7 Subject to paragraph 2.6, we will never sell, share, or rent your personal data. It should be noted that, because we do not control the privacy practices of our clients, we advise that you read and fully understand their privacy policies in addition to this privacy policy.

2.8 We share aggregated demographic information with our partners and clients; this is not linked to any personal information that can identify any individual person or organisation.

2.9 The data that we collect from you will not be transferred to or stored at a destination outside the European Economic Area (“EEA”) without your prior consent.

Automated decision making

2.10 We do not make automated decisions about you based on your information.

2.11 Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmission to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

3. Your Rights

3.1. Under data protection law you have the following rights:

3.1.1 the right to be informed as to what we do with your information. This includes but is not limited to the right to know what information we gather, process and store, what we do with it, who we share it with and how long we keep it for;

3.1.2 if we are processing your data on the basis of your consent then you have the right to withdraw that consent at any time. Consent can be withdrawn by and notifying us using the details set out in section 8 below. The lawfulness of our historic processing based on your consent will not be retrospectively affected by your withdrawal of consent;

3.1.3 the right to access a copy of your information which we hold. This is called a ‘subject access request’. Additional details on how to exercise this right are set out in section 5, below;

3.1.4 the right to object to processing of your information where it is likely to cause or is causing damage or distress. You can notify us of your objection to us processing your personal data using the contact details set out in section 8;

3.1.6 the right to object to decisions being made about you by automated means. We will inform you if your information is subject to automated processing;

3.1.7 the right, in certain circumstances, to have your information rectified, blocked, erased or destroyed if it is inaccurate;

3.1.8 the right, in certain circumstances, to claim compensation for damages caused by us breaching data protection law;

3.1.9 enhanced rights to request that we erase, rectify, cease processing and/or delete your information; and

3.1.10 in certain circumstances, the right to request the information we hold on you in a machine readable format so that you can transfer it to other services. This right is called ‘data portability’. Additional details on how to exercise this right are set out in section 5, below.

3.2 For further information on your rights under data protection law and how to exercise them, you can contact Citizens Advice Bureau (www.citizensadvice.org.uk) or the Information Commissioner’s Office (www.ico.org.uk).

4. Cookies

Our site uses cookies to distinguish you from other users of our site. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

4.2 We use “cookies” to gather statistical information that helps us understand what users find interesting and useful on both our own and our clients’ websites. Users can decline the cookies by adjusting the “accept cookies” setting on their browser, however, this may affect the functionality of our surveys on client web sites.  We may also embed a piece of code into pages of certain client sites. This gives us statistical site usage information about how the site is used. We aggregate this information to provide our clients with a closer understanding of how visitors use their site. We do not use this code to collect any personally identifiable information.

5. Access to Information

5.1 You have the right to access information held about you by making a written request to us. You must send us proof of your identity, or proof of authority if making the request on behalf of someone else, before we can supply the information to you. Requests should be sent to data.protection@creativeequals.org. In certain circumstances, you will be entitled to receive the information in a structured, commonly used and machine readable form.

5.2 We will be allowed to charge you for our reasonable administrative costs in collating and providing you with details of the requested information which we hold about you, if your request is clearly unfounded or excessive.

6. Access to Information Changes to our privacy policy

6.1 Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

7. Complaints

7.1 You have the general right to complain to us (in the first instance) and to the Information Commissioner’s Office (if you are not satisfied by our response) if you have any concerns about how we hold and process your information. Our contact details are set out in section 8, below. The Information Commissioner’s Office website is www.ico.org.uk.

8. Contact

8.1 Questions, comments and requests, including any complaints, regarding us or this privacy policy are welcomed and should be addressed to info@creativeequals.org.