This policy explains when and why we collect personal information about you, how we use it, the conditions under which we may disclose it to others, how we keep it safe and secure and your rights and choices in relation to your information.
Any questions regarding this policy and our privacy practices should be sent by email to firstname.lastname@example.org or by writing to: The Data Protection Officer, The Creative Conversation Company, c/o Dialogics Consultancy Ltd, 63 Meadvale Road, London W5 1LP.
We are The Creative Conversation Company, an initiative that aims to improve the quality of human connection worldwide through promoting the skills of creative conversation.
The Creative Conversation Company is a project of Dialogics Consultancy Ltd, whose directors are Peter Osborn, Eddy Canfor-Dumas and Ben Freedman.
We obtain information about you in the following ways:
For example, we may obtain information about you when you contact us by email or register to receive information from us, leave a comment, or purchase products and services through our website.
Your information may be shared with us by third parties; for example, subcontractors acting on our behalf who provide us with technical, payment or delivery services, our business partners, advertising networks, analytics providers and search information providers.
Cookies are text files placed on your computer’s hard drive to collect information such as *Log Data. This information is used to track visitor use of the website and to compile statistical reports on website activity. You can set your browser not to accept cookies or to indicate when a cookie is being sent. If you choose to not accept cookies, you may not be able to use some features of our site.
Like many site operators, we collect information that your browser sends whenever you visit our website (‘Log Data’). This Log Data may include information such as: your computer’s Internet Protocol (‘IP’) address, browser type, the time and date of your visit, the pages of our website that you visit, the time you spend on those pages, and other site usage statistics.
Elements on this site may include embedded content (e.g. videos, images, articles). Embedded content from other websites behaves in the exactly same way as if the visitor has visited the other website.
When you interact with us on social media platforms such as LinkedIn and Twitter we may obtain information about you (for example, when you publicly tag us in an event photo). The information we receive will depend on the privacy preferences you have set on those types of platforms.
The personal information we collect, store and use might include:
Data protection laws recognise certain categories of personal information as sensitive and therefore requiring greater protection, for example information about your health, ethnicity and religion.
We will not knowingly collect sensitive data about you and will not store it unless you share it with us voluntarily and unasked – on a comments page, for example.
We may use your information for a number of different purposes, which may include:
We keep your information for no longer than is necessary for the purposes it was collected for. The length of time we retain your personal information for is determined by operational and legal considerations. For example, we are legally required to hold some types of information to fulfil our statutory and regulatory obligations (e.g. health/safety and tax/accounting purposes).
If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognise and approve any follow-up comments automatically instead of holding them in a moderation queue.
For users who register on our website, we also store the personal information you provide in your user profile. You can see, edit or delete your personal information at any time (except you cannot change your username). Website administrators can also see and edit that information.
We review our retention periods on a regular basis.
We do not sell or rent your information to third parties.
We do not share your information with third parties for marketing purposes.
However, we may disclose your information to third parties working on our behalf in order to achieve the other purposes set out in this policy. For example, we may pass your information to our third party service providers, suppliers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (for example, to process the purchase of products and services).
However, when we use these third parties, we disclose only the personal information that is necessary to deliver the services and will not release your information to third parties for them to use for their own direct marketing purposes, unless you have requested us to do so, or we are required to do so by law; for example, by a court order or for the purposes of prevention of fraud or other crime.
Data protection law requires us to rely on one or more lawful grounds to process your personal information. We consider the following grounds to be relevant:
Where you have provided specific consent to us using your personal information in a certain way, such as to send you email, text and/or telephone marketing.
Where we are entering into a contract with you or performing our obligations under it, like when you buy The Creative Conversation Company products and services.
Where necessary so that we can comply with a legal or regulatory obligation to which we are subject.
Where it is necessary to protect life or health (for example, in the case of medical emergency suffered by an individual at one of our events) or a safeguarding issue which requires us to share your information with the emergency services.
Where it is reasonably necessary to achieve our or others’ legitimate interests (as long as what the information is used for is fair and does not duly impact your rights).We consider our legitimate interests to be running The Creative Conversation Company as a project of the social enterprise Dialogics Consultancy Ltd in pursuit of our aims and ideals. For example to:
When we legitimately process your personal information in this way, we consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. We will not use your personal information where our interests are overridden by the impact on you, for example, where use would be excessively intrusive (unless, for instance, we are otherwise required or permitted to by law).
When we use sensitive personal information, we require an additional legal basis to do so under data protection laws, so will either do so on the basis of your explicit consent or another route available to us at law.
We may use your contact details to provide you with information about the progress of The Creative Conversation Company and opportunities to support us, as well as the products and services you can buy, if we think it may be of interest to you.
We will only send you information and marketing communications by email, text and telephone if you have explicitly provided your prior consent. You may opt out of these communications at any time by clicking the ‘unsubscribe’ link at the end of our marketing emails.
You have a choice about whether or not you wish to receive information from us. If you do not want to receive information and marketing communications from us about The Creative Conversation Company, you’re free to change your preferences at any time by emailing email@example.com or writing to The Data Protection Officer, The Creative Conversation Company, c/o Dialogics Consultancy Ltd, 63 Meadvale Road, London W5 1LP.
We will not use your personal information for marketing purposes if you have indicated that you do not wish to be contacted and will retain your details on a suppression list to help ensure that we do not continue to contact you. However, we may still need to contact you for administrative purposes; for example, when we are processing a payment.
We may analyse your personal information to create a profile of your interests and preferences so that we can tailor and target our communications in a way that is timely and relevant to you. We may make use of additional information about you when it is available from external sources to help us do this effectively. This allows us to be more focused, efficient and cost effective with our resources and also reduces the risk of someone receiving information they may find inappropriate or irrelevant.
We’re committed to putting you in control of your data so you’re free to opt out of your information being used in this way at any time by emailing firstname.lastname@example.org or writing to The Data Protection Officer, The Creative Conversation Company, c/o Dialogics Consultancy Ltd, 63 Meadvale Road, London W5 1LP.
We may also use your personal information to detect and reduce fraud and credit risk.
Under UK data protection law, you have certain rights over the personal information that we hold about you. Here is a summary of the rights that we think apply:
You have a right to request access to the personal data that we hold about you.
You also have the right to request a copy of the information we hold about you, and we will provide you with this unless legal exceptions apply.
If you want to access your information, please send a description of the information you would like to see and proof of your identity by post to the address provided below
You have the right to have inaccurate or incomplete information we hold about you corrected. If you change email address, or if you believe any of the other information we hold is inaccurate or out of date, please email email@example.com or write to The Data Protection Officer, The Creative Conversation Company, c/o Dialogics Consultancy Ltd, 63 Meadvale Road, London W5 1LP.
You have a right to ask us to restrict the processing of some or all of your personal information if there is a disagreement about its accuracy, or we’re not lawfully allowed to use it.
You may ask us to delete some or all of your personal information and in certain cases, and subject to certain exceptions; we will do so as far as we are required to. In many cases, we will anonymise that information, rather than delete it.
If we are processing your personal information (1) based on your consent, or in order to enter into or carry out a contract with you, and (2) the processing is being done by automated means, you may ask us to provide it to you or another service provider in a machine-readable format.
You have the right to object to processing where we use your personal information (1) based on legitimate interests, (2) for direct marketing or (3) for statistical/research purposes.
If you want to exercise any of the above rights, please email firstname.lastname@example.org or write to The Data Protection Officer, The Creative Conversation Company, c/o Dialogics Consultancy Ltd, 63 Meadvale Road, London W5 1LP.
We may be required to ask for further information and/or evidence of identity. We will endeavour to respond fully to all requests within one month of receipt of your request, and if we are unable to do so we will contact you with reasons for the delay.
Please note that exceptions apply to a number of these rights, and not all rights will be applicable in all circumstances. For more details we recommend you consult the guidance published by the UK’s Information Commissioner’s Office.
When you give us personal information, we take steps to ensure that appropriate technical and organisational controls are in place to protect it.
Any sensitive information (such as credit or debit card details) is encrypted and protected with the following software: 128 Bit encryption on SSL. When you are on a secure page, a lock icon will appear on the bottom of web browsers such as Microsoft Internet Explorer.
Non-sensitive details (your email address etc.) are transmitted normally over the internet and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems. Where we have given (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
We take reasonable steps to ensure your information is accurate and up to date. We really appreciate it if you let us know when your contact details change.
Our website may contain links to other websites run by other organisations. This policy applies only to our website‚ so we encourage you to read the privacy statements on the other websites you visit. We cannot be responsible for the privacy policies and practices of other websites even if you access those using links from our website.
We are concerned to protect the privacy of children aged 16 or under. If you are aged 16 or under‚ please get your parent/guardian’s permission beforehand whenever you provide us with personal information.
We are committed to protecting vulnerable supporters and customers, and appreciate that additional care may be needed when we use their personal information. In recognition of this, we observe good practice guidelines in our interactions with vulnerable people.
As part of the services offered to you through this website, the information which you provide to us may be transferred to countries outside the European Economic Area (EEA). You should be aware that these countries may not have similar data protection laws to the UK. By submitting your personal data, you’re agreeing to this transfer, storing or processing.
If you use our services while you are outside the EEA, your information may be transferred outside the EEA in order to provide you with those services.
Any changes we may make to this policy in the future will be posted on this website so please check this page occasionally to ensure that you’re happy with any changes. If we make any significant changes we’ll make this clear on this website.
We keep this policy under regular review. This policy was last updated in November 2020.