CREATIVE BLOOM'S PRIVACY POLICY
1.0 CREATIVE BLOOM'S COMMITMENT TO USER PRIVACY AND DATA PROTECTION
User privacy and data protection are important rights that we take seriously
We have a responsibility to ensure that any data we process or control is handled appropriately & safely
We will only collect and process data when absolutely necessary
We do not spam, nor do we advise our clients to do so
We will never sell, rent or otherwise pass on to third parties or make public your personal data
2.0 RELEVANT LEGISLATION
As well as our own internal systems & processes, our website and marketing practices comply with the following national & EU legislation with regards to data protection & user privacy:
3.0 THE PERSONAL INFORMATION THAT THIS WEBSITE COLLECTS AND WHY WE COLLECT IT
This website collects and uses personal information for the following reasons:
3.1 Site visitation tracking
Like most websites, this site uses Google Analytics (GA) to track user interaction. We use this data to determine the number of people using our site, to better understand how they find and use our web pages and to see their journey through the website.
Although GA records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us. GA also records your computer’s IP address which could be used to personally identify you but Google do not grant us access to this. We consider Google to be a third party data processor (see section 6.0 below).
GA makes use of cookies, details of which can be found on Google’s developer guides. FYI our website uses the analytics.js implementation of GA.
Disabling cookies on your internet browser will stop GA from tracking any part of your visit to pages within this website.
In addition to Google Analytics, this website may collect* information (held in the public domain) attributed to the IP address of the computer or device that is being used to access it. The information is supplied to us from Whoisvisiting.com. Whoisvisiting.com is a service offered by Whoisdata Limited. The Whoisvisiting system does not use your IP address to identify you, the individual, in any way. No cookies are used by the Whoisvisiting system.
* The Whoisvisiting system will only lookup information when a static IP address is being used. Differences between a static and dynamic IP address.
More information about how Whoisvisiting uses IP addresses.
3.2 Our blog
We do not currently collect comment on our blog, however, should we change that in the future & you choose to add a comment to any posts that we have published on our blog, the name and email address you enter with your comment will be saved to this website’s database, along with your computer’s IP address and the time and date that you submitted the comment. This information is only used to identify you as a contributor to the comment section of the respective blog post and is not passed on to any of the third party data processors detailed below. Only your name will be shown on the public-facing website.
Your comment and it’s associated personal data will remain on this site until we see fit to either 1.) remove the comment or 2.) remove the blog post. Should you wish to have the comment and it’s associated personal data deleted, please email us here using the email address that you commented with.
If you are under 16 years of age you MUST obtain parental consent before posting a comment on our blog.
NOTE: You should avoid entering personally identifiable information to the actual comment field of any blog post comments that you submit on this website.
3.3 Contact forms and email links
Should you choose to contact us using the contact form on our Contact us page or an email link like this one, none of the data that you supply will be stored by this website or passed to / be processed by any of the third party data processors defined in section 6.0. Instead the data will be collated into an email and sent to us over the Simple Mail Transfer Protocol (SMTP). Our SMTP servers are protected by TLS (sometimes known as SSL) meaning that the email content is encrypted using SHA-2, 256-bit cryptography before being sent across the internet. The email content is then decrypted by our local computers and devices.
3.4 Email newsletter
If you choose to join our email newsletter, the email address that you submit to us will be forwarded to Hubspot who provide us with email marketing services. We consider Hubspot to be a third party data processor (see section 6.0 below). The email address that you submit will not be stored within this website’s own database or in any of our internal computer systems.
Your email address will remain within Hubspots’s database for as long as we continue to use Hubspot’s services for email marketing or until you specifically request removal from the list. You can do this by unsubscribing using the unsubscribe links contained in any email newsletters that we send you or by requesting removal via email. When requesting removal via email, please send your email to us using the email account that is subscribed to the mailing list.
If you are under 16 years of age you MUST obtain parental consent before joining our email newsletter.
While your email address remains within the Hubspot database, you will receive periodic (approximately four times a year) newsletter-style emails from us.
4.0 HOW WE STORE YOUR PERSONAL INFORMATION
As detailed in section 3.2 above, if you submit a comment to a blog post published on this website some personal information will be stored within this website’s database. This is currently the only occasion where personal data will be stored on this website. This data is currently stored in an identifiable fashion; a limitation of the content management system that this website is build on (Squarespace). In the near future we aim to change the storage of this data to a pseudonymous fashion meaning that the data would require additional processing using a separately stored ‘key’ before it could be used to identify an individual.
Pseudonymisation is a recent requirement of the GDPR which many web application developers & marketers are currently working to fully implement. We are committed to keeping it as a high priority and will implement it on this website & in our marketing practices as soon as we are able to.
5.0 ABOUT THIS WEBSITE’S SERVER
6.0 THIRD PARTY DATA PROCESSORS WE USE
We use a number of third parties to process personal data on our behalf. These third parties have been carefully chosen and all of them comply with the legislation set out in section 2.0. 3 of these third parties are based in the USA and are EU-U.S Privacy Shield compliant.
Google (Privacy policy)
Hubspot (Privacy policy)
Facebook (Privacy policy)
Hotjar (Privacy policy)
7.0 DATA BREACHES
We will report any unlawful data breach of this website’s database or the database(s) of any of our third party data processors to any and all relevant persons and authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.
The data controller of this website is: Creative Bloom limited, a UK Private limited Company with company number: 09095685
Whose registered office is:
6, 15 Brunswick Square, Hove, East Sussex.
BN3 1EH
And whose production office is:
The Projects, 8a Ship Street, Brighton, East Sussex.
BN1 1AD
8.0 DATA CONTROLLER
9.0 DATA PROTECTION OFFICER
Mr. Stuart Davies
Director, Creative Bloom Ltd.
Telephone: 01273 03333
10.0 CHANGES TO OUR PRIVACY POLICY
This privacy policy may change from time to time inline with legislation or industry developments. We will not explicitly inform our clients or website users of these changes. Instead, we recommend that you check this page occasionally for any policy changes. Specific policy changes and updates are mentioned in the change log below.
10.1 CHANGE LOG
25/4/2018 Privacy policy instigated
19/8/2019 Address & licence change
24/8/2020 Third party processors update
The copyright in this privacy policy is owned by Fellowship Productions Ltd, and is under licence.