Essentially, we want you to know that we take your privacy seriously. If you’d like to know how this breaks down, or you just want to read a collection of words that are drier than a camel’s underpants, please read on. You have been warned.
Last updated: 24th October 2023
We commit to handling data fairly and legally, and being transparent about what data we collect/process and how we use it.
- how we use your data;
- what personal data we collect/process;
- how we ensure your privacy is maintained; and
- your legal rights relating to your personal data.
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how 2Forks collects and/or processes your personal data through our client work or provided by you direct to 2Forks.
We will comply with data protection law. This includes General Data Protection Regulation 2018 (“GDPR”) and the Privacy in Electronic Communication Regulation (“PECR”). At the heart of data protection laws are the “data protection principles” which say 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; and
- kept securely.
CONTROLLER AND PROCESSOR
2Forks Ltd is both a controller and processor of your data, depending on our business interaction with you – see below for details – which means that we at 2Forks (collectively referred to here in this privacy notice as 2Forks, “we”, “us” or “our”) are responsible for your personal data.
|Client Customer Data
|Customers of 2Forks clients
|As determined by the Client – Data Controller – for provision of Customer Research or Marketing Campaigns.
|Legitimate Interest or Soft Opt In, when existing customers.
|To service the client requirements and send additional marketing information where relevant. For ongoing client research.
|Existing customers; Legitimate Interest to communicate for marketing purposes.
|To send relevant marketing communications by channel, as per the relevant legal basis. Market Research.
|Combination of consent, 3rd party data Legitimate Interest and 2Forks Legitimate Interest for B2B marketing.
THE DATA WE PROCESS ABOUT YOU
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). We may process and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes username, first name, last name, date of birth and gender.
- Contact Data includes email address and telephone numbers, address.
- Usage Data includes information about how you respond to campaigns.
We do not process 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).
We do not knowingly process personal data from anyone under the age of 18. If we are made aware that we have received information from anyone under the age of 16 or Special Categories of Personal Data, we will use reasonable efforts to locate and remove that information from our records.
HOW WE RECEIVE YOUR DATA
We use different methods to collect data from and about you including through:
- Clients who provide your data under contract for services to support their customer activities
- Direct interactions. You may give us your Identity, Contact, Profile and Marketing and Communications Data by filling in forms on our website, or our product / event-specific landing pages.
HOW WE USE YOUR PERSONAL DATA
We will only use your personal data under the relevant data protection laws (GDPR and PECR). Most commonly, we will use your personal data in the following circumstances:
- To produce reports and analysis for our clients
- To support marketing campaigns for our clients
- To provide customer support
- To provide and maintain our service
- To notify you about changes to our service
- To allow you to participate in interactive features of our service when you choose to do so
- To gather analysis or valuable information so that we can improve our service
- To monitor the usage of our service
- To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information
- To detect, prevent and address technical issues
DISCLOSING YOUR PERSONAL DATA
2Forks may disclose your Personal Data in the good faith belief that such action is necessary to:
- Where we need to comply with a legal or regulatory 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
- To protect and defend the rights or property of 2Forks
- To prevent or investigate possible wrongdoing in connection with our service
- To protect the personal safety of users of the service or the public
- To protect against legal liability
We may use your Identity, Contact, Technical, Usage and Profile 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.
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.
2Forks may on occasion need to transfer data and processing to a non-EEA country in order to utilise digital tools. 2Forks commit to uphold GDPR Clause 45.2(b) and ensure that any such use of these tools is only done under GDPR clauses to ensure the security of data as required by GDPR.
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.
Unfortunately, the transmission of information via the internet is never completely secure. 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.
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.
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 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. In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights. If you wish to exercise any of the rights set out above, please contact us at firstname.lastname@example.org.
You are entitled 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 local 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.
Of course, you will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee or refuse a request that is clearly repetitive or excessive.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond: We try to respond to all legitimate requests within 30 days. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us first.
Last updated: 27.09.23