We ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.

Who we are

3 Creative collects, uses and is responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.

The personal information we collect and use

Information collected by us

In the course of our business, when you email us for example, we collect the following personal information when you provide it to us:

  • Contact information from our clients and suppliers
  • Limited financial information

Information collected from other sources

We also obtain personal information from other sources as follows:

  • IP addresses from visitors to our website
  • Email address and name when you fill in our online enquiry form or sign up to our newsletter

How we use your personal information

We use your contact details so that we can:

  • Build, maintain and host websites for our clients
  • Help our clients with designing for their website
  • To enable us to process payments with our clients and suppliers

Some of our work is providing web hosting for our clients. In this connection 3 Creative processes some personal data stored on our client’s websites. Where we do this 3 Creative acts only as a data processor and does not interact with data or process in any way other then securely to store the it on behalf of the data controller. We have relevant contracts in place with the data controllers. For more information about our data processing contract please contact us.

Who we share your personal information with

We routinely share information with 3rd party providers who help us to deliver our services.

We sometimes share your personal data with trusted third parties which act only on our instruction (known as “data processors”). 

Data processors might be, for example, our 3rd party accounting apps or subcontractors or delivery drivers or those companies who store data for us:

Where we share information with these companies or individuals we make sure that they also keep your data secure and that they also protect your rights. To this end we make sure that:

  • We provide only the information they need to perform their specific services.
  • They may only use your data for the exact purposes we specify in our contract with them or where their terms and conditions of processing contain the correct data processor clauses under GDPR
  • If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.

Sharing your data with third parties for their own purposes (“joint controllers”) eg HMRC, accountants, legal advisors:

We will only do this in very specific circumstances, for example:

  • With your consent
  • Where we have a contract in place with the other party
  • Where we are obliged to share the information for legal reasons

Currently we share information with the following:

  • TSO Host
  • Cloudways
  • 20i
  • Gsuite / Google
  • Microsoft
  • Mailchimp
  • Dubsado CRM
  • Evernote
  • Onenote
  • Quickbooks
  • HMRC

Some of those third party recipients may be based outside the European Economic Area — for further information including on how we safeguard your personal data when this occurs, see ‘Transfer of your information out of the EEA’.

We will share personal information with law enforcement or other authorities if required by applicable law.

We will not share your personal information with any other third party.

How long your personal information will be kept

We will hold name, address and contact details (a) for the time that you are our client  or supplier; (b) for 5 years after the end of a contract ends so that we can have continuous working relationships (c) for as long as you are subscribed to our newsletters and (d) for timeframes prescribed by other provisions such as by applicable UK tax law (currently 6 years after the accounting period).

Reasons we can collect and use your personal information

The law on data protection sets out a number of different reasons for which a company may collect and process your personal data. Some of these reasons, set out below, are the bases we have for processing your personal data:

 Consent

In specific situations, we can collect and process your data with your consent.

For example, when you tick a box to receive email newsletters.

When collecting your personal data, we always make clear to you which data is necessary in connection with a particular service and give you a clear and simple option to unsubscribe at any time

Contractual obligations

In certain circumstances, we need your personal data to comply with our contractual obligations. We need to collect and retain your contact details so we can for example:

  • deliver our service, or
  • to enter into contract with you to supply us with goods or services

Legal obligations

If the law requires us to, we may need to collect and process your data.  

For example we are obliged to retain certain information for HMRC reporting purposes or to comply with other legislative provisions

Legitimate interest

In particular circumstances, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.

For example, we retain customer, client and supplier information 5 years in order maintain a good working relationship with these individuals

Transfer of your information out of the EEA

We do not routinely transfer your personal information outside the European Economic Area (EEA). However, from time to time we may pass personal data such as your name and email address to other services that we use to send out newsletters and other communications (both electronic and print).

However, your personal data will remain in the EU or countries considered by the EU to have equivalent policies such as Jersey, Guernsey, Switzerland, New Zealand and Canada. Companies based in the USA that have certified with the EU-US Privacy Shield programme are also considered to be permitted destinations by the EU (this includes popular US products like Gmail, Office 365 and MailChimp).

If you would like further information please contact us.

Your rights

Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:

  • fair processing of information and transparency over how we use your use personal information
  • access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address
  • require us to correct any mistakes in your information which we hold
  • require the erasure of personal information concerning you in certain situations
  • receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
  • object at any time to processing of personal information concerning you for direct marketing
  • object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
  • object in certain other situations to our continued processing of your personal information
  • otherwise restrict our processing of your personal information in certain circumstances
  • claim compensation for damages caused by our breach of any data protection laws

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

  • email, call or write to us
  • let us have enough information to identify you (eg account number, user name, registration details)
  • let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
  • let us know the information to which your request relates - including any account or reference numbers, if you have them

If you would like to unsubscribe from any newsletter you can also click on the ‘unsubscribe’ button at the bottom of the newsletter.

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

We take the following steps to maintain the security of your personal information:

  • Our servers are located in the United Kingdom
  • we keep all of your information in systems that are secure,
  • We limit access to your personal information to those who have a genuine business need to know it.
  • we have password protected systems
  • we maintain firewalls and anti-virus software
  • any data which is accessed off site or on a mobile device is kept locked when not in use and never left unattended

We do not retain paper copies of any information that could be classified as containing personal identifiable information

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

We hope that we can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: [0303 123 1113].

Changes to this privacy notice

This privacy notice was published on [insert date] and last updated on [insert date].

We may change this privacy notice from time to time, when we do we will inform you via [insert mechanism for informing the data subject of changes to the notice].

How to contact us

Please contact us if you have any questions about this privacy notice or the information we hold about you.

If you wish to contact us please send an email to [email protected] 

Do you need extra help?

If you would like this notice in another format (for example: audio, large print, braille) please contact us (see ‘How to contact us’ above).]