Privacy

This Privacy Policy sets out how we, Cai and Kyn Ltd, T/A Once Upon a Town, collect, store and use information about you when you use or interact with our website, onceuponatown.co.uk and where we otherwise obtain or collect information about you. This Privacy Policy is effective from 18th March 2019.

Contents

  • Summary
  • Our details
  • When you visit our website
  • When you use our website
  • Marketing communications
  • Information obtained from third parties
  • Disclosure and additional uses of your information
  • How long we retain your information
  • How we secure your information
  • Transfers of your information outside the European Economic Area
  • Your rights in relation to your information
  • Changes to our Privacy Policy
  • Children’s Privacy
  • Summary

Summary

This section summarises how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Policy.

  • Data controller: Cai and Kyn Ltd. ICO Registration Number: ZA501922
  • How we collect or obtain information about you:
    • when you provide it to us e.g. by contacting us, placing an order onour website, completing registration forms or signing up for content such as newsletters.
    • from your use of our website, using cookies and
    • occasionally, from third parties such as mailing list providers.
  • Information we collect: name, contact details, payment information e.g. your credit or debit card details, IP address, information from cookies, information about your computer or device (e.g. device and browser type), information about how you use our website (e.g. which pages you have viewed, the time when you view them and what you clicked on, the geographical location from which you accessed our website (based on your IP address), company name or business name (if applicable), VAT number (if applicable), your job function, company type, engagement history and transaction history.)
  • How we use your information: for administrative and business purposes (particularly to contact you and process orders you place on our website, to improve our business and website, to fulfil our contractual obligations, to advertise our and other’s goods and services, to analyse your use of our website, and in connection with our legal rights and obligations.)
  • Disclosure of your information to third parties: user information can be shared with partners for specific types of content and events where a user has registered their information. Other disclosures are only to the extent necessary to run our business, to our service providers, to fulfil any contracts we enter into with you and where required by law or to enforce our legal rights.
  • Do we sell your information to third parties (other than in the course of a business sale or purchase or similar event): No, Once Upon a Town does not sell data. However, when you register or sign up for certain types of content, your registration data can be shared with sponsors and partners. We will always make it clear where any information provided will be shared with other parties and give you the option to opt out of this.
  • How long we retain your information: for no longer than necessary, taking into account any legal obligations we have (e.g. to maintain records for tax purposes), any other legal basis we have for using your information (e.g. your consent, performance of a contract with you or our legitimate interests as a business) and certain additional factors described in the main section below entitled How long we retain your information.
  • How we secure your information: using appropriate technical and organisational measures such as storing your information on secure servers, encrypting transfers of data to or from our servers using Secure Sockets Layer (SSL) technology, encrypting payments you make on or via our website using Secure Sockets Layer (SSL) technology and only granting access to your information where necessary.
  • Use of cookies and similar technologies: we use cookies and similar information-gathering technologies such as marketing automation tracking on our website including essential, functional, analytical and targeting cookies.
  • Use of profiling: we use automated decision making and profiling to understand our users better through web and marketing analytics, provide targeted advertising and deliver a personalised user experience.
    • Your rights in relation to your information
    • to access your information and to receive information about its use
    • to have your information corrected and/or completed
    • to have your information deleted
    • to restrict the use of your information
    • to receive your information in a portable format
    • to object to the use of your information
    • to withdraw your consent to the use of your information
    • to complain to a supervisory authority
  • Sensitive personal information: we do not knowingly or intentionally collect what is commonly referred to as ‘sensitive personal information’. Please do not submit sensitive personal information about you to us. For more information, please see the main section below entitled Sensitive Personal Information.

Our details

If you have any questions about this Privacy Policy, please contact the data controller.

The data controller in respect of our website is Cai and Kyn Ltd, (company registration number: 6044308) of Studio G01 Adelphi Court, 1 East Street, Epsom, Surrey KT17 1BB.

You can contact the data controller by writing to Cai and Kyn Ltd at the address above or by sending an email to hello@onceuponatown.co.uk.

When you visit our website

We collect and use information from website visitors in accordance with this section and the section entitled Disclosure and additional uses of your information.

Web server log information

We use a third party server to host our website called Fasthosts, the privacy policy of which is available here: https://www.fasthosts.co.uk/terms/privacy-notice.

Our website server automatically logs the IP address you use to access our website as well as other information about your visit such as the pages accessed, information requested, the date and time of the request, the source of your access to our website (e.g. the website or URL (link) which referred you to our website), and your browser version and operating system.

Use of website server log information for IT security purposes

We collect and store server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber attacks, by detecting unusual or suspicious activity.

Unless we are investigating suspicious or potential criminal activity, we do not make, nor do we allow our hosting provider to make, any attempt to identify you from the information collected via server logs.

Legal basis for processing: compliance with a legal obligation to which we are subject (Article 6(1)(c) of the General Data Protection Regulation).

Legal obligation: we have a legal obligation to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals. Recording access to our website using server log files is such a measure.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: we and Fasthosts have a legitimate interest in using your information for the purposes of ensuring network and information security.

Use of website server log information to analyse website use and improve our website
We use the information collected by our website server logs to analyse how our website users interact with our website and its features. For example, we analyse the number of visits and unique visitors we receive, the time and date of the visit, the location of the visit and the operating system and browser use.

We use the information gathered from the analysis of this information to improve our website. For example, we use the information gathered to change the information, content and structure of our website and individual pages based according to what users are engaging most with and the duration of time spent on particular pages on our website.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: improving our website for our website users and getting to know our website users’ preferences so our website can better meet their needs and desires.

Cookies

Cookies are data files which are sent from a website to a browser to record information about users for various purposes.

We use cookies on our website, including essential, functional, analytical and targeting cookies. For further information on how we use cookies, please see our cookies policy which is available here.

You can reject some or all of the cookies we use on or via our website by changing your browser settings or non-essential cookies by using a cookie control tool, but doing so can impair your ability to use our website or some or all of its features. For further information about cookies, including how to change your browser settings, please visit www.allaboutcookies.org or see our cookies policy.

When you contact us
We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and additional uses of your information.

Email
When you send an email to the email address displayed on our website we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Transfer and storage of your information
We use a third-party email provider to store emails you send us. Our third-party email provider is Fasthosts. Their privacy policy is available here: https://www.fasthosts.co.uk/terms/privacy-notice.

Post
If you contact us by post, we will collect any information you provide to us in any postal communications you send us.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

When you use our website

We collect and use information from individuals who interact with particular features of our website in accordance with this section and the section entitled Disclosure and additional uses of your information.

Newsletters
When you sign up for any of our newsletters from us by completing the newsletter sign up form, we collect your name, email address and location. We will also record the time and date of completion.

Legal basis for processing: your consent (Article 6(1)(a) of the General Data Protection Regulation). Consent: you give your consent to us sending you our newsletters by signing up to receive them using the steps described above.

We will also use this information to tailor any follow up sales and marketing communications with you. For further information, see the section of this privacy policy titled ‘Marketing Communications’.

Information you submit to subscribe for our e-newsletter will be stored outside the European Economic Area on our third-party mailing list provider’s servers in the United States.

For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

Use of tracking in emails
We use technologies such as tracking pixels (small graphic files) and tracked links in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates, click through rates and content engagement which our emails achieve.

For more information on how we use tracking our newsletter emails, see our cookies policy which is available here.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: registering and administering accounts on our website to provide access to content, allows you to buy goods and services and facilitates the running and operation of our business.

We will also use this information to tailor any follow up sales and marketing communications with you. For further information, see the section of this privacy policy titled ‘Marketing Communications’.

Transfer and storage of your information
Information you submit to us via the registration form on our website will be stored within the European Economic Area on our third-party hosting provider’s servers.

Our third-party hosting provider is Fasthosts.

Their privacy policy is available here: https://www.fasthosts.co.uk/terms/privacy-notice
Registration information is also transferred to our CRM system where it will be matched against any existing information we hold for you. Our CRM provider is MailChimp.

Their privacy policy is available here: https://mailchimp.com/legal/privacy/

This is stored outside the European Economic Area on our CRM provider’s servers in the United States.

For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

Marketing communications

Our content, goods and services
When signing up for content or registering on our website, we will use the information you provide in order to contact you regarding related content, products and services.

We will continue to send you marketing communications in relation to similar goods and services if you do not opt out from receiving them.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: Sharing relevant, timely and industry-specific information on related business services, in order to assist your organisation grow, or to further develop you as a professional.

Transfer and storage of your information
We use a third-party service to send out our marketing emails and administer our mailing list, MailChimp.

Their privacy policy is available here: https://mailchimp.com/legal/privacy/

Information for marketing campaigns will be stored outside the European Economic Area on our third-party mailing list provider’s servers in the United States.

For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

Use of tracking in emails
We use technologies such as tracking pixels (small graphic files) and tracked links in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates, click through rates and content engagement that our emails achieve.

For more information on how we use tracking in our marketing emails, see our cookies policy which is available here: https://www.onceuponatown.co.uk/cookies

For more information about MailChimp and their use of tracking technology, see their privacy policy which is available here: https://mailchimp.com/legal/privacy/

Third party goods and services
In addition to receiving information about our products and services, you can opt in to receiving marketing communications from us in relation third party goods and services by email by ticking a box indicating that you would like to receive such communications.

Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).

Consent: you give your consent to us sending you information about third party goods and services by signing up to receive such information in accordance with the steps described above.

Transfer and storage of your information
We use a third-party service to send out our marketing emails and administer our mailing list, MailChimp.

Their privacy policy is available here: https://mailchimp.com/legal/privacy/

Information for marketing campaigns will be stored outside the European Economic Area on our third-party mailing list provider’s servers in the United States.

For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

Use of tracking in emails
We use technologies such as tracking pixels (small graphic files) and tracked links in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates, click through rates and content engagement that our emails achieve.

For more information on how we use tracking in our marketing emails, see our cookies policy which is available here: https://www.onceuponatown.co.uk/cookies

For more information about MailChimp and their use of tracking technology, see their privacy policy which is available here: https://mailchimp.com/legal/privacy/

Information obtained from third parties
This section sets out how we obtain or collect information about you from third parties.

Information received from third parties
We can often receive information about you from third parties. The third parties from which we receive information about you can include partner events within the marketing industry and other organisations that we have a professional affiliation with.

It is also possible that third parties with whom we have had no prior contact may provide us with information about you.

Information we obtain from third parties will generally be your name and contact details, but will include any additional information about you which they provide to us.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where a third party has passed on information about you to us (such as your name and email address) in order for us to provide services to you, we will process your information in order to take steps at your request to enter into a contract with you and perform a contract with you (as the case may be).

Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).

Consent: where you have asked that a third party to share information about you with us and the purpose of sharing that information is not related to the performance of a contract or services by us to you, we will process your information on the basis of your consent, which you give by asking the third party in question to pass on your information to us.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: where a third party has shared information about you with us and you have not consented to the sharing of that information, we will have a legitimate interest in processing that information in certain circumstances.

For example, we would have a legitimate interest in processing your information to perform our obligations under a sub-contract with the third party, where the third party has the main contract with you. Our legitimate interest is the performance of our obligations under our sub-contract.

Similarly, third parties may pass on information about you to us if you have infringed or potentially infringed any of our legal rights. In this case, we will have a legitimate interest in processing that information to investigate and pursue any such potential infringement.

Disclosure and use of your information for legal reasons

Indicating possible criminal acts or threats to public security to a competent authority.

If we suspect that criminal or potential criminal conduct has been occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that we fraud or a cyber crime has been committed or if we receive threats or malicious communications towards us or third parties.

We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: preventing crime or suspected criminal activity (such as fraud).

In connection with the enforcement or potential enforcement our legal rights.

We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: enforcing our legal rights and taking steps to enforce our legal rights.

In connection with a legal or potential legal dispute or proceedings.

We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): resolving disputes and potential disputes.
For ongoing compliance with laws, regulations and other legal requirements.

We will use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena if we receive one or to the National Crime Agency in connection with suspected or potential money laundering matters.

Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).

Legal obligation(s): legal obligations to disclose information which are part of the laws of England and Wales or if they have been integrated into the United Kingdom’s legal framework (for example in the form of an international agreement which the United Kingdom has signed).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: where the legal obligations are part of the laws of another country and have not been integrated into the United Kingdom’s legal framework, we have a legitimate interest in complying with these obligations.

How long we retain your information

This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.

Retention periods
Server log information: we retain information on our server logs for 3 months.

Order information: when you place an order for goods and services, we retain that information for seven years following the end of the financial year in which you placed your order, in accordance with our legal obligation to keep records for tax purposes.

Correspondence and enquiries: when you make an enquiry or correspond with us for any reason, whether by email or via our contact form or by phone, we will retain your information for as long as it takes to respond to and resolve your enquiry, and for 36 further month(s), after which point we will archive your information.

Newsletter: we retain the information you used to sign up for our newsletter for as long as you remain subscribed (i.e. you do not unsubscribe).

Criteria for determining retention periods
In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:

  • [the purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);
  • whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);
  • whether we have any legal basis to continue to process your information (such as your consent);
  • how valuable your information is (both now and in the future);
  • any relevant agreed industry practices on how long information should be retained;
  • the levels of risk, cost and liability involved with us continuing to hold the information;
  • how hard it is to ensure that the information can be kept up to date and accurate; and
  • any relevant surrounding circumstances (such as the nature and status of our relationship with you).]

How we secure your information

We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:

  • only sharing and providing access to your information to the
  • minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
  • using secure servers to store your information;
  • verifying the identity of any individual who requests access to information prior to granting them access to information;
  • using Secure Sockets Layer (SSL) software to encrypt any payment transactions you make on or via our website;
  • only transferring your information via closed system or encrypted data transfers;

Transmission of information to us by email
Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.

We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.

Transfers of your information outside the European Economic Area

Your information will be transferred and stored outside the European Economic Area (EEA) in the circumstances set out earlier in this policy.

We will also transfer your information outside the EEA or to an international organisation in order to comply with legal obligations to which we are subject (compliance with a court order, for example). Where we are required to do so, we will ensure appropriate safeguards and protections are in place.

Currently, the only non-EEA country where Once Upon a Town share your information with is the United States.

Every provider we use has self-certified their compliance with the EU-U.S. Privacy Shield.

The EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation. You can access the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm

You can check this directory to verify and obtain further information about Privacy Shield registered vendors: https://www.privacyshield.gov/list.

Your rights in relation to your information
Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by writing to the data controller using the details provided at the top of this policy.

  • to request access to your information and information related to our use and processing of your information;
  • to request the correction or deletion of your information;
  • to request that we restrict our use of your information;
  • to receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another data controller (including a third party data controller);
  • to object to the processing of your information for certain purposes (for further information, see the section below entitled Your right to object to the processing of your information for certain purposes); and
  • to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time
  • when you withdraw your consent.

In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.

For the purposes of the UK, the supervisory authority is the Information Commissioner’s Office (ICO), the contact details of which are available here: https://ico.org.uk/global/contact-us/

Further information on your rights in relation to your personal data as an individual
The above rights are provided in summary form only and certain limitations apply to many of these rights. For further information about your rights in relation to your information, including any limitations which apply, please visit the following pages on the ICO’s website:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/; and

https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/

You can also find out further information about your rights, as well as information on any limitations which apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection Regulation, which is available here: http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf

Verifying your identity where you request access to your information

Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.

These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.

How we verify your identity
Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.

If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.

We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.

Your right to object

You have the following rights in relation to your information, which you may exercise in the same way as you may exercise by writing to the data controller using the details provided at the top of this policy.

  • to object to us using or processing your information where we use or process it in order to carry out a task in the public interest or for our legitimate interests, including ‘profiling’ (i.e. analysing or predicting your behaviour based on your information) based on any of these purposes; and
  • to object to us using or processing your information for direct marketing purposes (including any profiling we engage in that is related to such direct marketing).

You may also exercise your right to object to us using or processing your information for direct marketing purposes by:

  • clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link;
  • sending an email to data@thedrum.com, asking that we stop sending you marketing communications or by including the words “OPT OUT”.

Sensitive Personal Information

‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.

We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.

If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulation. We will use and process your sensitive personal information for the purposes of deleting it.