People of Print Privacy Notice
Last updated: May 19 2021
OUR PRIVACY PROMISE
Your privacy is important to PEOPLE OF PRINT LTD ("we", "us" and "our"). We are committed to protecting your personal data and being transparent about the personal data we hold and use and, wherever possible, giving you control over how we use your personal data.
This notice is intended to be communicated to you in a concise, transparent, intelligible, and easily accessible manner, but we appreciate that you may have queries or want to seek clarification as to its terms. If so, please contact us (using the details set out at paragraph 2 below) and we will endeavour to respond to you as soon as possible.
We may make changes to this notice from time to time, including as may be necessary or prudent to reflect any changes in the ways in which we process personal data or any changes in data protection laws. Any changes and updates to this notice will be posted on the Website. Please check this notice regularly so that you are aware of any changes.
1 INTRODUCTION
Please read this notice carefully. Among other things, it explains:
• What personal data we collect about you;
• Why we collect and use your personal data and the legal bases we rely on;
• Who we disclose your personal data to;
• Where we store your personal data;
• How long we keep your personal data; and
• Your rights regarding the personal data you provide to us.
We may collect, use, disclose and store information about you when:
• you access or use our website at [please confirm the website to be used for the project] (Website) [(including automatically by way of cookies or other similar technologies as set out in our Cookie Policy )];
• [you correspond/interact with us via our contact form, email, phone, social media or other channels;]
• you submit a design;
• your design is chosen to form part of the Typeface;
• you download the Typeface;
• you post content on our social media pages or any of our other channels.
2 WHO WE ARE AND OUR CONTACT DETAILS
For the purposes of data protection laws, the data controller is PEOPLE OF PRINT LTD, a company registered in England and Wales (company no. 08519899) with its registered office at [Suite 447, 91 Western Road, Brighton, United Kingdom, BN1 2NW].
We are aiming to create a new typeface, in collaboration with The Distillery London Ltd (our Partner) using contributions from various different designers from a variety of backgrounds in order to represent our goal, being diversity (the Typeface).
If you have any queries regarding this notice or the way in which we process your personal data, please contact us at:
Email: info@weardistillery.co
Address: Preston Park House, South Road, Brighton, East Sussex, BN1 6SB
3 CHANGES TO YOUR PERSONAL INFORMATION
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes or if you become aware that any personal data that we hold is not accurate.
4 WHAT PERSONAL DATA WE COLLECT
4.1 The type of personal data we process may include (as applicable) the following:
Categories of Data Description of Data
Identity Data
Name, date of birth, age, marital status, title, gender, nationality, country of residence, job title, role and employer.
Contact Data
Email address, address, telephone number, mobile number, other information in an email signature.
Transaction Data
Payment information and other transaction information provided by or obtained in connection with any purchase from us.
Correspondence Data Information which you provide in, or we learn about you from, any correspondence or communications with us, including feedback and details of any enquiries on our contact page.
Usage Data Device IP address, the pages of the Website that you visit, usage information for the Website.
Technical Data
Type of device, unique device identifier (e.g. an IMEI number, IP, or Mac address), network information, the type of operating system and browser you use, time zone settings and other device related information.
Marketing and Communications Data Your marketing preferences and communication preferences and any information you provide to us in any polls, survey and questionnaires that we may run from time to time.
4.2 Analytics Data – we may receive aggregated statistics and insights from advertising, analytics and attribution providers regarding your use of the Website. This information does not contain any personally identifiable information.
4.3 Sensitive Personal Data / Special Categories of Data - we may process special categories of personal data (also known as sensitive personal data) as described in paragraph 6 below.
4.4 Information about why we process the above personal data and the lawful basis we rely upon is set out in the table at paragraph 5 below.
4.5 Where lawful, we may also obtain personal data from third parties or public sources (for example, third party websites such as Facebook and Instagram) and we may process that information where it is needed in order to provide our products and services to you, including access to our services or where it is needed for our internal administrative purposes.
5 THE PURPOSES FOR WHICH WE PROCESS YOUR PERSONAL DATA
5.1 We use your personal data for a number of purposes but only where we are allowed to by the law.
5.2 We may process your personal data in any circumstances where such processing is necessary:
5.2.1 in order to perform any agreement we have entered into with you or in anticipation of any agreement we may enter into with you;
5.2.2 to comply with any applicable law or regulation; and/or
5.2.3 for the purposes of the legitimate interests pursued by us or a third party. These legitimate interests include the purposes identified in the table below at paragraph 5.7 but also include other commercial interests and our internal administrative purposes. Where we rely on legitimate interests as the lawful basis for processing your personal data, we will put in place appropriate safeguards to protect your data and to ensure that your interests or fundamental rights and freedoms are not overridden by those legitimate interests.
5.3 We may also process your personal data where we have your consent. Where we rely on consent as the lawful basis for processing your personal data, you have the right to withdraw your consent at any time and if you wish to do so, you should contact us using the contact details set out in paragraph 2 above. Where we obtain your consent to send you marketing communications, you can unsubscribe by following the unsubscribe link within the communication. The withdrawal of consent does not affect the lawfulness of processing based on consent before withdrawal or the lawfulness of processing based on other lawful grounds.
5.4 We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
5.5 Information about the purposes for which we use your personal data, the types of personal data we process to achieve these purposes, and the lawful basis by which we process it, is set out in the table below:
Purpose/Activity Type of Personal Data Processed Lawful Basis for Processing
Submission of Design
• To register you as a new submission
• To contact you if we need any further information from you in order to assess your submission
• To contact you if we choose your design to form part of the Typeface
• Identity Data
• Contact Data
• Correspondence Data
• Usage Data
• Technical Data
• Marketing and Communications Data • Consent
• Performance of a contract
• Compliance with a legal obligation
• Our legitimate interests to operate our business and fulfil our legal and contractual obligations
Download of the Typeface
• To provide the Typeface for you to download, including processing and managing [ donations].
• Identity Data
• Contact Data
• Transaction Data
• Correspondence Data
• Usage Data
• Technical Data
• Marketing and Communications Data
• Performance of a contract
• Compliance with a legal obligation
• Our legitimate interests to operate our business and fulfil our legal and contractual obligations
Business Operation and Maintenance
• To operate and protect the Website, our social media channels and the Typeface, (including troubleshooting, incident management and data breach management, data analysis, system testing, system maintenance, support, reporting and hosting of data)
• Identity Data
• Contact Data
• Transaction Data
• Correspondence Data
• Usage Data
• Technical Data
• Performance of a contract
• Compliance with a legal obligation
• Our legitimate interests to operate and improve our business, fulfil our legal and contractual obligations and for the purposes of IT security
Customer Relationship Management
• To manage and improve our relationship with our customers which includes notifying you of any changes to our terms or this notice or to our services, responding to enquiries and messages.
• Identity Data
• Contact Data
• Correspondence Data
• Usage Data
• Technical Data
• Marketing and Communications Data
• Consent
• Performance of a contract
• Compliance with a legal obligation
• Our legitimate interests to respond to enquiries, messages and requests, operate, develop and improve our business, define types of customers for our services, inform our marketing strategy and to fulfil our legal and contractual obligations
Business Development and Management
• To manage our business including improving the Website, keeping financial and accounting records, carry out audits, testing, comply with our reporting requirements and other corporate governance requirements
• To exercise our rights set out in agreements including enforcement of our intellectual property rights
• To publish reviews and testimonials
• Identity Data
• Contact Data
• Transaction Data
• Correspondence Data
• Usage Data
• Technical Data
• Marketing and Communications Data
• Performance of a contract
• Compliance with a legal obligation
• Our legitimate interests to exercise our rights (including enforcement of such rights), to operate our business (including internal administration and IT services, network security, to prevent fraud and in the context of a business reorganisation, sale or group restructuring exercise) and to fulfil our legal and contractual obligations
Marketing and Advertising
• To market our services
• To make suggestions and recommendations to you about other services and products that may be of interest to you
• To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
• To use data analytics to improve our business, the Website, our services, marketing, customer relationships and experiences • Identity Data
• Contact Data
• Marketing and Communications Data
• Consent
• Our legitimate interests to develop our business and to inform our marketing strategy
5.6 We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
5.7 If we need to use your personal data for an unrelated purpose, we will notify you (which may be by way of update to this notice) and we will explain the legal basis which allows us to do so.
5.8 Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.
6 HOW WE USE PARTICULARLY SENSITIVE PERSONAL DATA
6.1 We may process special categories of personal data (also known as sensitive personal data) including details about your race or ethnicity, gender identity, disability status, religious or philosophical beliefs, sex life, sexual orientation, and political opinions.
6.2 We will mostly only process sensitive personal data where it is necessary for carrying out our rights and obligations under law or where we have your explicit consent to do so. Where we request your consent, we will provide you with full details of the personal data we wish to process and the reason for processing so that you can carefully consider if you wish to consent. You can withdraw your consent at any time. Please note that we may not always need your explicit consent to process your sensitive personal data and we may also process sensitive personal data where:
6.2.1 you have made such personal data publicly known in a clear and obvious way; and
6.2.2 the processing is necessary for reasons of substantial public interest because of the law, such as equal opportunities monitoring.
6.3 We may use information about your gender, race, ethnic origin, age or nationality to ensure meaningful equal opportunity monitoring and reporting with regard to the creation of our Typeface.
7 WHAT IF YOU REFUSE TO PROVIDE US WITH ANY PERSONAL DATA?
7.1 Where we need to collect personal data by law, or under the terms of an agreement we have with you, and you fail to provide that data when requested (or fail to consent to the processing of that data, if necessary), we may not be able to perform the agreement or arrangement we have or are trying to enter into with you.
8 SHARING INFORMATION WITH THIRD PARTIES
8.1 We will not share any of your personal data with third parties except as set out in this paragraph 7 or otherwise notified to you or agreed between you and us from time to time.
8.2 We may share personal data with our group companies (including our subsidiaries, ultimate holding company and its subsidiaries) and partnered companies, including our Partner, for the purposes outlined in this notice. We may also share personal data with third party service providers who we engage to provide services which facilitate our business and we may need to share personal data with other third parties in order to comply with our legal and regulatory obligations. Below is a list of specific third parties and other categories of third parties with whom we may share your personal data:
8.2.1 [Google Analytics and Google Ads, operated by Google LLC, our provider of online marketing tools;]
8.2.2 Payment service providers;
8.2.3 Any third party buyer of our business or assets;
8.2.4 Law enforcement or a regulator;
8.2.5 Legal counsel and other professional advisers including accountants and auditors;
8.3 We ensure that any third party engaged by us who processes your personal data in connection with the purposes listed above has policies and procedures in place to ensure compliance with data protection laws.
8.4 For any third parties that are based, or process data, outside of the EEA and the United Kingdom, we engage such third parties in accordance with paragraph 8 below.
8.5 We will remain the controller responsible for the processing of your personal data notwithstanding that third parties may operate as a joint controller with us. For some processing activities we may act as a processor for a third party and, in such circumstances, the third party will be responsible for providing you with the processing information required under data protection laws.
8.6 We may share your personal data with third parties where we are required to do so by law or regulation (such as in connection with an investigation of fraud or other legal enquiry) or in connection with other legal proceedings (including where we believe that your actions violate applicable laws or any agreement with us).
8.7 In the event that our business or any part of it is sold or integrated with another business, your details may be disclosed to our advisers and those of any prospective purchaser and will be passed to the new owners of the business.
9 INTERNATIONAL TRANSFERS OF PERSONAL DATA
9.1 From time to time it may be necessary for us to transfer your information internationally. In particular, your information may be transferred to and/or stored on the servers of third parties identified in paragraph 7 which are based outside of the UK and the EEA.
9.2 However, we will not transfer your personal data outside of the UK and the EEA unless:
9.2.1 such transfer is to a country or jurisdiction which the EU Commission or the UK has approved as having an adequate level of protection; or
9.2.2 appropriate safeguards are in place in accordance with data protection laws. These safeguards include the use of standard contractual clauses or binding corporate rules; or
9.2.3 the transfer is otherwise allowed under data protection laws (including where we have consent or the transfer is necessary for the performance of a contract with the data subject).
9.3 We will ensure that where your personal data is transferred outside of the UK and the EEA, it is afforded the same protection as would be afforded to it within the EEA and UK.
10 YOUR RIGHTS AS A DATA SUBJECT
10.1 Subject to any conditions and requirements set out in data protection laws, you may have some, or all, of the following rights in relation to the personal data we hold about you:
10.1.1 the right to request a copy of your personal data held by us;
10.1.2 the right to correct any inaccurate or incomplete personal data held by us;
10.1.3 the right to request that we erase personal data we hold about you;
10.1.4 the right to request that we restrict the processing of your data;
10.1.5 the right to have your personal data transferred to another organisation;
10.1.6 the right to object to certain types of processing of your personal data by us; and
10.1.7 the right to complain (please see paragraph 13 of this notice).
10.2 PLEASE NOTE that these rights are not absolute in all situations and may be subject to conditions and provisions set out in data protection laws. We cannot, therefore, guarantee that we'll be able to honour any request from you in connection with the rights set out above. (For example, even if you request that we delete your personal data, we may be required by law to retain some personal data for accounting and record keeping purposes or in order that we comply with our legal and regulatory obligations.)
10.3 For further information, or to exercise any particular right, please contact us at [please confirm].
11 STORAGE AND RETENTION OF YOUR PERSONAL DATA
11.1 As a minimum, we need to store your personal data for as long as is necessary to enable us to fulfil the purpose for which it is processed, including to fulfil our legal and regulatory obligations (e.g. relating to record keeping) and to exercise or defend any legal claims.
11.2 We will notify you without undue delay in accordance with the requirements of data protection laws, if we have reason to believe that there has been a personal data breach by us which could adversely affect your rights and freedoms and we are required by law to notify you.
12 LINKS TO THIRD PARTIES
12.1 The Website may link or redirect to other websites, social media accounts or other content which is not under our control. Such links or redirections are not endorsements of such websites or representation of our affiliation with them in any way and such third party websites are outside the scope of this notice.
12.2 If you access such third party websites, please ensure that you are satisfied with their respective privacy policies before you provide them with any personal data. We cannot be held responsible for the activities, privacy policies or levels of privacy compliance of any website operated by any third party.
13 COOKIES
13.1 The Website uses some cookies as detailed in the [Cookies Policy].
14 QUESTIONS AND COMPLAINTS
14.1 We take our data protection obligations seriously. If you have any questions or complaints about this notice or the way that we handle your personal data, we would appreciate the chance to deal with your concerns in the first instance before you approach the relevant data protection authority. Please contact us using the details provided in paragraph 2 above.
14.2 You have the right to make a complaint at any time to the relevant supervisory authority for data protection issues, which in the UK is the Information Commissioner's Office (ICO) (www.ico.org.uk).
