Welcome to Space PR Limited’s privacy notice.
Space PR Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data.
1. Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how Space PR Limited collects and processes your personal data.
Space PR Limited is the controller and responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
We have appointed a data privacy contact who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy champion using the details set out below.
Our full details are:
Full name of legal entity: Space PR Limited
Name of data privacy contact: Faye Rivington
Email address: firstname.lastname@example.org
Postal address: Windsor House, Cornwall Road, Harrogate, North Yorkshire HG1 2PW
Telephone number: 01423 611542
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 in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated in June 2018.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Our 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.
2. The data we collect 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 collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, maiden name, last name, marital status, title and gender, photographs of you.
- Contact Data includes address, email address and telephone numbers
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you, including invoicing, if you are a client of ours;
- Marketing and Communications Data includes any communication preferences, records of conversations, website testimonials.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you (if you are a client) and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact, Transaction, Communications and Financial Data by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you ask us to carry out our services for you, you carry out services for us or you are a journalist or contact of ours.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services;
- Identity and Contact Data from our clients, who may send us information such as event invitation databases for us to review and work on, details of project teams and wider contacts we may need to undertake our work such as contact information for associates and other PR professionals.
- Identity and Contact Data from publicly availably sources such as Companies House or information available through the internet (for instance if you are employed by a Council and we wish to contact you for PR purposes). We may obtain journalist’s details through Gorkana (media database), online or telephone searches (including calls to the publication) or via our existing network of contacts.
- Identity and Contact Data from our clients if you are considered to be of interest in relation to a story our clients wish us to write, such as a new occupier within our client’s scheme or development.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where you are providing services to us and we are about to enter into or have entered into a contract with you.
- 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.
- Where we need to comply with a legal or regulatory obligation.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to 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.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new client or make a note of you as a prospective client||(a) Identity
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (keeping a list of prospective customers)
|To process and deliver our services including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(c) Other processing necessary to comply with our legal obligations
(d) ensuring business policies are adhered to, such as security policies.
(e) dealing with clients, extended team networks and journalists/ media contacts.
(f) undertaking day to day PR activities
(e) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests so we can deliver the service to you.
|To manage our relationship with you which will include:
(b) Asking you to complete feedback forms or take a survey and collecting testimonials
(c) Updating client records
(c) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how clients use our products/services)
|To make suggestions and recommendations to you about services that may be of interest to you||(a) Identity
(c) Marketing and Communications
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
Marketing details from us
We may use your Identity and Contact 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 (we call this marketing).
You will receive marketing communications from us if you have requested information from us or used our services and, in each case, you have not opted out of receiving that marketing. .
We will get your express opt-in consent before we share your personal data with any company outside of Space PR Limited for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of providing our services to you or for another reason listed above.
Change of purpose
We will only use your personal data 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 data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
5. Disclosures of your personal data
We routinely share data with:
- Companies that provide services to help us to run our business more efficiently, such as media contacts, extended team networks with our clients, consultants who work with us and our clients and their respective networks and any consultants we use in our business, such as a bookkeeper and photographer.
- our bank and professional advisors;
- HMRC and other regulatory bodies;
In addition we may share your data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
8. Data retention
How long will you use my personal data for?
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.
We will hold data about clients on our database and we will continue to hold records for as long as is necessary and in case any historic information is required.
We keep journalistic contacts for an indefinite period, but only during the period which we consider it necessary to hold it for the purposes we collected it for.
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.
YOUR LEGAL RIGHTS
You have the right 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.
No fee usually required
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 if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
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 one month. 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.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.