Privacy Notice

Who are we?

We are Creative Network Consulting Limited, registered in England & Wales, with company number 07695745 and with registered office at Birchin Court, 20 Birchin Lane, London, England, EC3V 9DU.

This Privacy Notice 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 Notice carefully as it sets out how we use your personal data and the rights you have relating to that use.

Creative Network Consulting 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 Notice Creative Network Consulting Limited is collectively referred to as “Creative ITC”, “we”, “us” or “our”.

If you have any questions about this Privacy Notice, please contact us by emailing dataprotection@creative-itc.com.

Purpose of this Privacy Notice.

This Privacy Notice explains our practices with respect to the personal data we collect and process in connection with your relationship with us. This includes personal data we collect and process:

through our website; and
through business relationships that you or your organisation maintain with us.

The purpose of this Privacy Notice 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.

Please note that we have a separate Recruitment Privacy Notice, which can be found here: https://www.creative-itc.com/recruitment-privacy-notice/. Similarly, if you become employed or otherwise engaged by us, a suitable privacy notice will be made available to you when you start with us.

If you are a California resident, please see the section of this Privacy Notice which is specific to you, at pages 7-10.

Personal data we collect about you.

Personal data is any information about an individual from which that person can be identified, whether directly or indirectly. 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.

Information you give us.This is information about you that you give us by filling in “contact us” forms or using the chat/messaging functionality on our websites (creative-itc.com, www.vdipod.com or www.creative-group.tech), or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site (if registration is necessary), join any of our mailing lists, or if you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number, personal description, or any other data which identifies you.
Information we collect about you. With regard to each of your visits to our site we will automatically collect the following information:
- Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- Information about your visit, including the full URL, clickstream to, through and from our site (including date and time), products/services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page and any phone number used to call our customer service (+44) (0) 845 533 2186.
Information we receive from other sources.This includes professional details (name, job title, business email) that we may purchase or license from a third-party provider for marketing purposes.
CCTV. Creative ITC also operates CCTV systems at certain of its premises. Any recording is limited to video footage only and will not contain audio capture. CCTV recordings are only accessible by authorised personnel within Creative ITC on a strict need-to-know basis, and the retention period is limited to thirty-one days. CCTV recordings will only be used to aid in the prevention of crime, assist in identifying perpetrators, reviewing compliance with regulatory requirements and verifying that resources are available to support the contractual requirements of our customers (this is relevant to our managed service offerings).
Special category data. We do not knowingly collect any special categories of personal data about you (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).

Cookies

We may receive information from cookies and/or other tracking technologies. Cookies 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. Please see the applicable website’s Cookie Notice for more information about how we use cookies.

How do we use your personal data?

In the table below, we have set out the purpose and 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.

Purpose/Activity	Lawful basis for processing including basis of legitimate interest
To respond to any enquiry you may make through the “get in touch” form or chat/messaging functionality on 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 administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).	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).
Where we provide services to your organisation, we are likely to process to collect and process your name, job title, employer business address and business email if you are a key contact for the service we provide.	Necessary for our legitimate interests (to collect and process information about individuals working at client organisations for the purpose of providing them with services, communicating about requirements, promoting our services and taking instructions).
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.
To make suggestions and recommendations to you about goods or services that may be of interest to you. This includes situations where we may contact you using data provided by a third party B2B data provider. We do this to promote our services and hopefully build a sales relationship with you. The data we receive normally constitutes your name, business email address, job title, business email address, employer title and telephone number.	Necessary for our legitimate interests (to develop our products/services and grow our business), also to promote our services to individuals at organisations that we think may be interested in or would benefit from those services.
CCTV recording (non-audio only).	Necessary for our legitimate interests (to aid in the prevention of crime, assist in identifying perpetrators, assist in ensuring suitable security measures are in place, reviewing compliance with regulatory requirements and verifying that resources are available to support the contractual requirements of Creative ITC customers).

Who do we share your personal data with?

We share your personal data with our cloud service provider, Microsoft, whose Office 365 services we use for file storage and email. Our Microsoft hosting is located in the UK and they act as our processor.

We may also add your contact information to other cloud platforms we use to manage customer relationships. All such suppliers are our processors, and we carry out data protection compliance and information security due diligence on all suppliers with access to our data before working with them and during the period they provide services to us.

In the event that we sell or negotiate to sell Creative ITC to a buyer or prospective buyer, personal data held by us about our clients/prospects 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 ITC assets, or transfer of all or a portion of Creative ITC’s business to another company.

We may also be required to share your personal data to comply with applicable laws or with valid legal processes, such as in response to a court order.

Lastly, there may be situations where we need to share your personal data with professional advisers including lawyers, auditors, and insurers. We will only do this where it is strictly necessary.

International Transfers

It is unlikely that we will ever share your personal data outside the UK or European Union (EU) or European Economic Area (EEA). If, however, it becomes necessary for the purposes of providing our services to you, we will only share it with organisations located in countries based on the UK adequacy regulations or benefiting from a European Commission adequacy decision or on the basis of Standard Contractual Clauses approved by the European Commission or the IDTA approved UK government. The aforementioned documents contractually oblige the recipient to process and protect your personal data to the standard expected within the EU/EEA or UK.

How do we keep your personal data safe?

Our ISMS (information security management system) is certified to ISO/IEC 27001. We are also Cyber Essentials Plus certified.

All information you provide to us is stored on our secure servers. Unfortunately, the transmission of information via the internet is not completely secure, and although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site – 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. Such personnel 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.

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.

For further information about retention periods, or to view our retention policy, please contact us at: dataprotection@creative-itc.com.

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@creative-itc.com (or by using any other of the contact methods detailed at page 1 of this Privacy Notice) if you’d like to exercise any of the rights set out above.

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.

How to complain

For any queries or concerns regarding the processing of personal data, please contact us at dataprotection@creative-itc.com.

You can also contact the Information Commissioners Office using the information provided at: https://ico.org.uk/concerns/.

Rights of California Residents

This section of our Privacy Notice supplements the information contained in the main body of our Privacy Notice. This section applies solely to California residents whose personal information is processed by Creative ITC pursuant to the California Consumer Privacy Act as amended by the California Privacy Rights Act 2020 (the “CCPA”). Any terms defined in the CCPA have the same meaning when used in this notice.

This section applies to “Personal Information”, which is defined in the CCPA as information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. This section does not address or apply to our handling of Personal Information that is exempt under the CCPA, such as publicly available information or deidentified or aggregated information.

Categories of Personal Information We Collect and Disclose. The following bullet points identify the categories of Personal Information we may collect about you, or have collected in the prior 12 months, as enumerated by the CCPA:

Identifiers. Such as name, email, phone number, address, IP address or other similar identifiers.

Internet or Other Electronic Network Activity. Such as usage data, which includes information about your visit, including the full URL, clickstream to, through and from our site (including date and time), products/services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page
Audio, Electronic, Visual, or Similar Information. Such as information collected via call recordings if you are interacting with us in a customer service capacity.

Sources of Personal Information. We generally collect Personal Information either directly from you or from marketing/advertising agencies. Please see the “Personal data we collect about you” section at page 3 of this Privacy Notice for further information.

Purposes for Collecting and Disclosing Personal Information. In general, we collect and otherwise process Personal Information for the following business or commercial purposes. Please see the “How do we use your personal data” section at page 3 for further information.

Sensitive Personal Information. Creative ITC does not collect sensitive personal information from you.

Retention. We retain your Personal Information for as long as needed, or permitted, based on the reason we obtained it (consistent with applicable law). When deciding how long to keep your Personal Information, we consider whether we are subject to any legal obligations (e.g., any laws that require us to keep records for a certain period of time before we can delete them) or whether we have taken any legal positions (e.g., issued any legal holds or otherwise need to preserve the information). In accordance with our retention policies, rather than delete your Personal Information we may also deidentify your Personal Information in compliance with CCPA.

For further information about retention periods, or to view our retention Notice, please contact us at: dataprotection@creative-itc.com.

Disclosure of Personal Information to Third Parties and Other Recipients. The categories of third parties and other recipients to whom we may have disclosed this information for a business or commercial purpose are set out at the “who do we share your personal data with” section of this Privacy Notice at page 4.

Sales and Sharing of Personal Information. The CCPA defines “sale” as disclosing or making available Personal Information to a third-party in exchange for monetary or other valuable consideration, and “sharing” includes disclosing or making available Personal Information to a third-party for purposes of cross-contextual behavioural advertising. We do not disclose Personal Information to third parties in exchange for monetary compensation, and neither do we share Personal Information with third parties for the purposes of cross-contextual behavioural advertising.

Your California Privacy Rights.

In general, California residents have the following rights with respect to their Personal Information, subject to certain conditions and exceptions:

Right to Know/Access. With respect to the Personal Information we have collected about you, you have the right to request:

The categories or Personal Information we collected about you;
The categories of sources from which the Personal Information is collected;
Our business or commercial purposes for collecting, selling, or sharing Personal Information;
The categories of third parties to whom we have disclosed Personal Information; and
A copy of the specific pieces of Personal Information we have collected about you.

Right to Correct. You have the right to request that we correct inaccuracies in your Personal Information.

Right to Delete. Subject to certain exceptions, you have the right to request we delete Personal Information we have collected from you.

Right to Opt-Out of Sales and Sharing. You have the right to opt-out of “sales” and “sharing” of your Personal Information, as those terms are defined under the CCPA. If you come to our website or use our services from a different device or from a different browser on the same device, you will need to opt-out, or use an opt-out preference signal, for that browser and/or device as well.

Right to Limit Use of Sensitive Personal Information. We do not engage in uses or disclosures of “Sensitive Personal Information” that would trigger the right to limit use of Sensitive Personal Information under the CCPA.

Right to Non-Discrimination. We will not discriminate against you for exercising any of the rights described in this section.

Exercising Your Rights. If you are a California resident and would like to exercise your CCPA rights, you may do so by emailing us at dataprotection@creative-itc.com

Verification. Before responding to your request, we must first verify your identity using the Personal Information you recently provided to us. We will take steps to verify your request by matching the information provided by you with the information we have in our records. In some cases, we may request additional information in order to verify your identity, or where necessary to process your request. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for the denial.

Authorized Agent. You may designate someone as an authorized agent to submit requests and act on your behalf. Authorized agents will be required to provide proof of their authorization in their first communication with us, and we may also require that the relevant consumer personally verify their identity and the authority of the authorized agent.

Shine the Light. Under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California residents who provide us certain Personal Information are entitled to request and obtain from us, free of charge, information about the Personal Information (if any) we have shared with third parties for their own direct marketing use. Such requests may be made once per calendar year for information about any relevant third party sharing in the prior calendar year. California residents who would like to make such a request may contact us by emailing us at dataprotection@creative-itc.com. The request should attest to the fact that the requester is a California resident and provide a current California address.