Privacy Policy

Privacy Policy – Creative CX Limited

1. Who are we?

We are Creative CX Limited, registered in England & Wales, with company number 10887310 and with registered office at 57 Southwark Street, London, England, SE1 1RU.

This Privacy Policy sets out the basis on which we may collect, use, disclose and/or otherwise process your personal data in connection with and/or for the purposes of our operations. Please read this Privacy Policy carefully as it sets out how we use your personal data and the rights you have relating to that use.

Creative CX Limited is the controller of your personal data, which means we are responsible for your personal data and determining how it is used. In this Privacy Policy Creative CX Limited is collectively referred to as “Creative CX”, “we”, “us” or “our”.

If you have any questions about this Privacy Policy, please contact us using the details set out below.

Contact details:

Name of Data Protection Officer: Rachael Haywood
Email address: dataprotection.cx@creative-cx.com
Postal address: City Bridge House, 57 Southwark Street, London, SE1 1RU
Telephone: +44 (0)20 7682 2820

2. Purpose and scope of this Privacy Policy.

To comply with applicable data protection laws including the UK GDPR and Data Protection Act 2018 (the “Data Protection Legislation”), Creative CX must ensure that individuals are fully aware of the way their personal data is processed, why and how it’s being used, and how long it will be kept. The purpose of this Privacy Policy is therefore to make it easier for you to understand how we use and protect your personal data, and how you can get in touch with us if you need to.

This Privacy Policy does not deal with the processing of the personal data of Creative CX employees, as this is dealt with in a separate employee privacy notice. It also does not deal with the processing of job applicant data, as this is dealt with in Creative CX’s Recruitment Privacy Notice available here.

3. Personal data we collect about you.

Personal data is any information about an individual from which that person can be identified. It does not include data where the identity of an individual has been removed (anonymous data). We may collect, use, store, transfer and otherwise process different kinds of personal data about you, as set out below.

3.1 Information you give us.

This is information about you that you give us by filling in the “get in touch” form on our website www.creative-cx.com or if you report a problem with our website. It includes information you provide when you register to use our site, subscribe to our service or join our mailing list, including signing up to our newsletter.

This information also includes information we receive when you (as a client or prospective client) contact us to submit a request for proposals or request for information. In such cases we will collect certain information about you so that we can supply you with the requested information. We may receive this information from face-to-face meetings, networking events, exchanged business cards or through information you give us via email, telephone, social media or otherwise.

We will also collect and store certain personal data from you if you agree to do user-testing or qualitative research for us, this includes information you provide to us regarding a third party (i.e., if you refer a friend to us to take part in research). Before you provide another person’s details to us, please make sure you get their consent. You can refer them to this document, so they can understand how we will use and process their information.

The information you give us will depend on you, although if you fill in the “get in touch” form on our website, you’ll need to give us your email address so that we can respond to your query. If you do user-testing we will record your interview (provided you consent to this). Other personal data you may give us could be your full name, job title, email address (including business email), contact details, details about other members of your team or any data which is capable of identifying an individual.

If you sign up to our email newsletters, we will send them to you until you unsubscribe or ask us to stop sending them. We keep records of who has unsubscribed from the newsletter list so that we comply with the Privacy & Electronic Communications Regulations (PECR).

3.2 Information we collect about you.

Cookies. When you visit our website we receive information from cookies and/or other tracking technologies, which are pieces of data your browser stores and sends back to us when making requests. We use this information to improve your experience, understand user activity and improve the quality of our services. You can manage your cookie preferences for all non-necessary cookies. Please see our for further information.

Google analytics. We use Google Analytics to analyse user activity on our website in order to improve our websites. We can use such analysis to gain insights about how to improve the functionality and experience of the website. The information is anonymous; we can’t and won’t contact you unless you specifically enter your contact information into the “get in touch” form on our website. The cookies used to provide this analysis calculate visitor, session and campaign data and also keeps track of site usage for the site’s analytics reports. For further information about these cookies, please see our cookie policy available at Cookie Notice.

If you don’t want to be tracked while using our site (or other websites) then Google provide a tool to allow you to opt-out: https://tools.google.com/dlpage/gaoptout.

3.3 Information we receive from other sources

This is information we receive about you from other sources, such as:

if you get in touch via any of the other websites operated by a Creative affiliate, including https://www.creative-group.tech – the group website operated by Creative Network Consulting Limited;
if we purchase or license your professional details from a third-party provider for marketing purposes;
if we receive personal information about you from our partners in the event that we hold joint webinars, provided you’ve consented to our partner sharing such information with us;
if we use a user-testing recruitment agency in order to find individuals to participate in qualitative research/user-testing on behalf of our end clients. The recruitment agent we currently use for this purpose is Face Facts Fieldwork Ltd (trading as Face Facts Research). Please review their privacy policy at https://facefactsresearch.com/privacy-policy/.

3.4 Special category data

We do not expect to collect or otherwise process any special categories of personal data about you for the purposes of our business operations as specified within this Privacy Policy (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).

4. How do we use your personal data?

We collect, use, store and transfer your personal data for a number of different purposes. By law we are required to have a lawful basis for processing your personal data. We process your information on the following legal bases:

You have consented for us to do so for a specific purpose.
Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.

We have set out below, in a table format, a description of all the ways we may use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Lawful basis for processing including basis of legitimate interest
To respond to any enquiry you make through the “get in touch” form of our website, or any other enquiry you make (whether by email, telephone, social media or otherwise), including requests for information or requests for proposals.	Necessary for our legitimate interests (to respond to your enquiry).
To send you our newsletter via email.	Consent.
To manage our relationship with you which will include: (a) Notifying you about changes to our website terms or privacy policy. (b) Asking you to leave a review or take a survey.	(a) Performance of a contract with you. (b) Necessary to comply with a legal obligation. (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).
To enable you to partake in a prize draw, competition or complete a survey.	(a) Performance of a contract with you. (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business).
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise). (b) Necessary to comply with a legal obligation.
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.	(a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy). (b) Consent.
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences.	(a) Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy). (b) Consent.
Direct marketing – to make suggestions and recommendations to you about goods or services that may be of interest to you.	Necessary for our legitimate interests (to develop our products/services and grow our business).
To carry out qualitative research/user testing by recording participant interviews and sharing these with our end client.	Consent.

5. Who do we share your personal data with?

5.1 We may have to share your personal data with the parties set out below for the purposes set out in the table above:

Our affiliate, Creative Network Consulting Limited, who carries out website maintenance and hosting services on our behalf.
Our partners, in the event we hold joint webinars (and provided we’ve obtained your consent to such sharing).
- analytics and search engine providers that assist us in the improvement and optimization of our site.
- Our end clients – for qualitative research purposes, including user testing. If you consent to your interview being recorded and shared, we will share this recording with our end client.

5.2 We may also disclose your personal information to third parties if the follow events occur:

In cases where we sell or negotiate to sell Creative CX to a buyer or prospective buyer, in which case personal data held by us about our clients will be one of the transferred assets. This would also be the case for any proposed or actual merger, joint venture or other type of acquisition or business combination of all or any portion of Creative CX assets, or transfer of all or a portion of Creative CX’s business to another company.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or to protect the rights, property, or safety of Creative CX our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
To professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance, accounting or other similar services.

We require all third parties to respect the security of your personal data and to treat it in accordance with the Data Protection Legislation.

6. Marketing

We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You may receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing.

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

7. How do we keep your personal data safe?

All information you provide to us is stored on our secure servers. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; 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. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know – they will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

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

With the exception of our use of Mailchimp (please see section 11 of this Privacy Policy), we do not transfer any of your personal data outside of the EEA.

8. How long do we keep your personal data?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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.

9. Your rights

Under the Data Protection Legislation, you have rights in respect of your personal data, and these depend on the reason why we are processing your information. These rights are the rights to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with applicable law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Please contact us at dataprotection.cx@creative-cx.com (or by using any other of the contact methods detailed at section 1 of this Privacy Policy) if you’d like to exercise any of the rights set out above.

10. Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

11. Mailchimp

Mailchimp is the platform we use for distribution of newsletters. Mailchimp is a third-party party data processor. Please read more about Mailchimp’s privacy policy here: https://mailchimp.com/legal/privacy/.

Mailchimp is headquartered in and has offices in the United States and its servers are also located in the United States. This means data Mailchimp process for us may be transferred to, stored, or processed in the United States. Standard contractual clauses are in place between Creative CX and Mailchimp to ensure that this transfer of personal data is subject to appropriate safeguards

12. How to complain

We take our responsibilities in relation to personal data very seriously, so please contact us at dataprotection.cx@creative-cx.com (or by using any other of the contact methods detailed at page 1 of this Privacy Policy) if you have any queries or concerns about how we are processing your personal data.

You can also contact the Information Commissioners Office at www.ico.org.uk, by writing to them at Wycliffe House Water Lane, Wilmslow, Cheshire, SK9 5AF or by phone on 0303 1231113 for further information or advice, or if we have not addressed your concerns and you would like to make a complaint.