Updated: 11 May 2020
This privacy notice describes how we collect and use personal information about you during and after your relationship with us, in accordance with the General Data Protection Regulation (GDPR). If you have any questions regarding this privacy statement or do not feel that your concerns have been addressed, please direct your questions to our website administrator via firstname.lastname@example.org
This notice applies to:
(i) All Client’s
(ii) All Third Parties and Suppliers with whom we have dealings in the ordinary course of our business including those individuals with whom we send marketing information regarding any reference to ‘we’, ‘us’, ‘our’, ‘the company’ shall mean ‘Truffle Social’.
Any reference to ‘you’ or ‘Data Subject’ shall mean any individual receiving this notice for whom we hold personal data. This Privacy Statement does not include information relating to the retention of data on limited companies as such data is not incorporated within the provisions of GDPR. This Privacy Notice also applies to our websites listed as follows:
In many circumstances we hold your data as a “Data Controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice. In some circumstances we may acquire or handle your data as a ‘Data Processor’ which means we have been asked to handle your data by a third party other than yourself and do not directly store your data. We may update this notice at any time. It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
Data Protection Principles
We will comply with data protection laws including GDPR. This says that the personal information we hold about you must be:
Used lawfully, fairly and in a transparent way.
Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
Relevant to the purposes we have told you about and limited only to those purposes.
Accurate and kept up to date.
Kept only as long as necessary for the purposes we have told you about.
The kind of information we hold about clients:
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). There are “special categories” of more sensitive personal data which require a higher level of protection.
We will collect, store, and use some or all of the following categories of personal information about you:
Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
National Insurance number.
Bank account details
Business related information including website information, email addresses, contact numbers and addresses
Information relating to your business website which may include basic information regarding visitors to the website such as IP addresses, email addresses and information completed on contact forms.
We will not ordinarily collect, store and use any data which is defined under GDPR as “special categories” of more sensitive personal information.
Why we hold information on clients:
It is necessary for us to retain data on clients in order for us to fulfil our contractual obligations and we must hold data for our legitimate business needs.
We will only retain data which we reasonably require and for a period which is reasonably necessary.
We will not disclose your data to the third parties unless you have consented for us to do so or we are otherwise required to do either contractually or under another law or enactment.
We will hold limited information on visitors to our client’s websites. This may include basic information on customers of our clients who have completed contact forms or other personal information.
We retain this data only insofar as it is necessary to appropriately optimise the website and in order to ensure appropriate functionality of our clients websites.
How is client personal information collected:
We collect personal information about clients from the information Clients provide to us and what information may be held publicly, for instance with Companies House. And from general market research. We may sometimes collect additional information from third parties including credit reference agencies or other background check agencies or credit agencies if deemed necessary.
We will collect additional personal information in the course of our contract with you. This information may include:
Information about your Clients, both existing and future Clients;
Company accounts, profit and loss / turnover / revenue statistics;
Information regarding your employees.
Some of the above data is not covered by GDPR but we have provided information on this to you for your records.
How we will use information about clients:
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
Where we need to perform the contract we have entered into with you.
Where we need to comply with a legal obligation.
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.
We may also use your personal information in the following situations, which are likely to be rare:
Where we need to protect your interests (or someone else’s interests).
Where it is needed in the public interest (or for official purposes).
Situations in which we will use your personal information:
We need all the categories of information in the list above primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests.
The situations in which we will process your personal information are listed below:
Administering the contract we have entered into with you.
Business management and planning, including accounting and auditing.
Conducting performance reviews, managing performance and determining performance requirements.
Dealing with legal disputes involving you
To prevent fraud.
To market other products or services which we offer which may be of interest to you.
To inform you about updates about the Company and advise you of an opportunities or promotions.
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information. In certain circumstances listed above, we hold your data in order to market other services to you. We have a legitimate business interest in retaining your data for this purpose but you may ‘opt out’ of receiving marketing communications from us.
We may exchange your personal information if all, or substantially all, our assets are merged or acquired by a third party, or we expand or re-organise our business, in which case your personal information may form part of the transferred or merged assets or we may need to transfer your information to new entities or third parties through which our business will be carried out. If you fail to provide personal information If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you or we may be prevented from complying with our legal obligations. Change of purpose We will only use your personal information 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. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. The kind of information we hold about individuals other than clients and how this data is used. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). During the course of our day to day basis we acquire information regarding individuals other than our Clients and we will retain this data where we have a legitimate business reason to do so.
Typically we acquire personal data on individuals other than our clients in the following circumstances:
Where we have met individuals at networking or other marketing events;
Where individuals have made enquiries with us regarding possible goods or services but have not subsequently become clients of the business;
Where we have dealt with individuals in the capacity as suppliers of goods or services to the Company;
Where we have regular business related dealings with you;
Data that has come to our attention as a result of our service to you as our Client.
In many circumstances the extent of the data we hold is limited and may be publicly available by way of other websites but usually the information we will retain is limited to:
Contact information including but not limited to email addresses, contact telephone numbers, business addresses and in some cases personal addresses.
We have a legitimate business interest in retaining this data on the basis that we must retain some personal data on third parties and suppliers in the ordinary course of business. We may also use this data to send marketing information to you in respect of promotions, events or other updates relating to us. We have a legitimate interest in retaining your data for this purpose however you have the right to ask us to erase or rectify your data and the right to opt out of receiving marketing information.
Transient email data:
Some of our services can optionally involve the relaying of email to and from your correspondents. We do not normally manually inspect and do not store the content (message body and attachments) of the email messages. We do machine inspection and rewrite part of the email message to enable its inclusion into the digital service. Once the transmission of an email message through our servers is completed, no trace of it is left on our servers but the data may exist in a repurposed form on one of our digital services.
Why might you share my personal information with third parties:
We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.
How secure is my information with third-party service providers and other entities in our group:
All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions. We will put in place appropriate security measures to protect your data proportionate to the size of our operation, the resources available to us and the nature of the data we store on you.
When might you share my personal information with other entities in the group:
We will share your personal information with other entities in our group or with the third party providers detailed above. We will only share this data insofar as it is necessary to further our legitimate business interests which will include, but is not limited to, monitoring our business accounts including accounting forecasts and to provide services to clients in accordance with our contractual conditions.
We have put in place measures to protect the security of your information. Details of these measures are available upon request. Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure. We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so. The transmission of information via the internet is not completely secure. We cannot guarantee the security of your data transmitted online and transmission is made at your own risk. If you communicate with us by email then you assume the risks of such communications being intercepted, not received or delivered or are received by individuals other than the intended recipient.
How long will you use my information for:
We will only retain your personal information 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. In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
Under certain circumstances, by law you have the right to:
Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected. Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below). Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes. Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Changes to this privacy notice:
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
Contact and further information:
If you have any questions about this privacy notice, please contact us on email at: email@example.com
If you have any questions or wish to submit a complaint then please submit this to:
Second Floor, HubHub, 20 Farringdon St, London EC4A 4EN
You have the right to make a complaint to the Information Commissioners Office or such other regulatory body or supervisory authority as may be appointed from time to time.
If you make a complaint then we will respond to let you know how your complaint will be handled.
To request access/change/removal/restriction of information we may hold, please
use one of the following methods of contact our Data Protection Officer:
Call: +44 (0)207 1930808
Postal Mail: Second Floor, HubHub, 20 Farringdon St, London EC4A 4EN