GDPR Privacy Policy

Introduction – Who we are

Swan Graphics Limited trading as Imaginators and its group businesses (“we”, “us”, or “our”) are committed to protecting and respecting the personal data that we hold. This privacy statement describes why and how we collect and use personal data and provides information about individuals’ rights. It applies to personal data provided to us, both by individuals themselves or by others on behalf of individuals. We may use personal data provided to us for the purposes described in this privacy statement or as made clear in another form before collecting personal data.

Personal data is any information relating to an identified or identifiable living person. When collecting and using personal data, our policy is to be transparent about why and how we process personal data.

We process personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose are set out in the relevant sections below.

The personal data that is provided to us is provided either directly from the individual concerned, from a third party or from publicly available sources (such as but not limited to internet searches and Companies House).

Where we receive personal data that relates to an individual from a third party, we request that this third party inform the individual of the necessary information regarding the use of their data. Where necessary, reference may be made to this privacy statement.

Security

We take the security of all the data we hold seriously. Staff are trained on data protection, confidentiality and security, and we maintain a culture of confidentiality across the business.

We have a framework of policies and procedures which ensure we regularly review the appropriateness of the measures we have in place to keep the data we hold secure.

All information you provide to us is stored both on our internal secure servers and GDPR compliant cloud based services. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website or internal server, you are responsible for keeping this password confidential. We ask you not to share any password with anyone. We reserve the right to remove access to our website or server at any time. We also reserve the right to change your password when/if necessary.

Unfortunately, the transmission of information via the internet is not 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.

Subscribers

We provide services to businesses who use our services and other corporate organisations.

Where data is collected for our business services, it is used for a number of purposes, such as:

To promote our products, services and news

To improve our products and services

To offer you other services we believe may benefit you unless you ask us not to

For providing services to clients. Data is processed in order to provide the service detailed in our letter of engagement between our clients and us, and may sometimes be further clarified in written documentation supplied before any data processing may occur;

For client management. When communicating with and assessing the needs of clients, personal data may be processed in order to ensure that their needs are appropriately satisfied. This may include assessing whether the right collection of services is being provided to our clients.

For administration. In order to manage and administer our business and services, we may collect and process personal data. This may include (but is not limited to) maintaining internal business records, managing client relationships, hosting events, event management, news updates, administering client facing applications, and maintaining internal operating processes.

The data that is processed is necessary for the functionality of the services we provide and is dependent on the services that are being provided and on the recipient of this service.

We process the personal data of individuals associated with our client’s business. Personal data may include any relevant financial or non-financial information necessary for us to provide our services. As an example, this may include contact details, email address, job title, corporate banking, financial information and lists of shareholders of both clients and suppliers and any other specifically relevant data.

In addition, personal data of individuals previously, currently or potentially employed by Imaginators is stored. As an example, this may include contact details, email address, home address, next of kin, payroll information and other financial data specific to the individual and for the purpose of employment.

We collect information about you from different places including:

• directly from you
• from other third-party companies
• from publicly available sources
• when we generate it ourselves
• from other organisations

We retain the personal data processed by us in a live environment for as long as is considered necessary for the purpose(s) for which it was collected (including as required by applicable law or regulation, typically 6 years). We may keep data for longer to establish, exercise, or defend our legal rights and the legal rights of our clients.

In addition, personal data may be securely archived with restricted access and other appropriate safeguards where there is a need to continue to retain it.

We collect personal data for our people as part of the administration, management and promotion of our business activities.

Our staff handbook explains further how personal data is held for our Directors and staff.

Where an individual is applying to work for Imaginators, personal data is collected through the application process. Some data is collected through forms on the website, details of which can be found in the section describing people who use our website.

There are several purposes that personal data for applicants are collected.

We process an applicant’s personal data to assess their potential employment at Imaginators.

We may also use this personal data to make informed management decisions and for administration purposes.

Personal data collected for applicants is held for as long as necessary to fulfil the purpose for which it was collected, or for a maximum of two years where those purposes no longer become necessary.

When people visit our website, personal data is collected both through automated tracking and interacting with various forms on the website or apps (collectively referred to as the websites).

Personal data may be collected when individuals fill in forms on our websites or by corresponding with us by phone, e-mail or otherwise. This includes information provided when an individual registers to use our website, subscribe to our service, make an enquiry, request a sample, comment on publications, enter a competition, promotion or survey, attend an event, apply to work for Imaginators and report a problem with our website.

When individuals visit our website, certain personal data may be automatically collected.

Our website uses cookies. Cookies are internet files used by the system to view websites and their content. We utilise analytical cookies to help us monitor and develop our site. None of the cookies we use are intrusive on your system. You are at liberty to turn off cookies through your browser but you should be aware that this may affect your viewing experience.

Often, individuals who visit our website additionally fall into another category as listed by this privacy statement. For instance, users of our websites may be current subscribers. Where this is the case, data held and processed for individuals who use our website may also become data that is held and processed for another purpose.

Personal data from our contacts, which covers both potential and prior customers, as well as potential and prior employees, are held in our Management Information System (MIS) and Customer Relationship Management (CRM) tool.

We use technology to profile our business contacts, so that we can assess both the requirements and health of our relationship with them. Where we process the data of business contacts, we rely on legitimate interests or consent, depending on the situation.

There are several reasons why we will process the personal data that an individual may provide to us when visiting our websites. As examples, these include;

To allow individuals to use some functionality of our website, certain personal data must be entered for features to work as intended.

To keep our site safe and secure, we may sometimes collect personal data, for instance login information and other data that can be used to vouch an individual’s identity.

The data that we hold depends on what data was entered and for what purpose.

Personal data that may be stored in the CRM tool includes, but is not limited to, name, email address, physical address, job title, and details of the initial meeting.

In addition, personal data may be securely archived with restricted access and other appropriate safeguards where there is a need to continue to retain it.

Where data was entered to engage with functionality of our website, that personal data may include their name, address, e-mail address and phone number, financial and credit card information, personal description and photograph.

Where data is collected automatically, the data that we may collect includes technical information, including the Internet protocol (IP) address used to connect an individual’s computer to the Internet, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

Other data about an individual’s visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products 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), and methods used to browse away from the page and any phone number used to call our customer service number.

Our website uses cookies to distinguish individuals from one another. This helps us to provide a better experience when individuals browse our website and allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie policy.

We retain the personal data processed by us in a live environment for as long as is considered necessary for the purpose(s) for which it was collected (including as required by applicable law or regulation, typically 6 years).

In addition, personal data may be securely archived with restricted access and other appropriate safeguards where there is a need to continue to retain it.

We will only share personal data with others when we are legally permitted to do so.  When we share data with others, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality and security standards.

Personal data held by us may be transferred to:

Third party organisations that provide applications/functionality, data processing or IT services to us

We use third parties to support us in providing our services and to help provide, run and manage our internal IT systems.  For example, providers of information technology, cloud-based software as service providers, identity management, website hosting and management, data analysis, data back-up, security and storage services.  The servers powering and facilitating that cloud infrastructure are in secure data centres around the world, and personal data may be stored in any one of them.

Third party organisations that otherwise assist us in providing goods, services or information

Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, to establish, exercise or defend legal rights.  We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.

Where possible, personal data resides within the UK territory but may be transferred to, and stored at, a destination outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. We will take all reasonable steps to ensure that your data is treated securely, in accordance with this privacy statement.

We have taken steps to ensure all personal data is provided with adequate protection and that all transfers of personal data outside the EU are done lawfully.  Where we transfer personal data outside of the EU to a country not determined by the European Commission as providing an adequate level of protection for personal data, the transfers will be under an agreement which covers the EU requirements for the transfer of personal data outside the EU.

Individuals have certain rights over their personal data and data controllers are responsible for fulfilling these rights as follows:

Individuals may request access to their personal data held by us as a data controller.

Individuals may request us to rectify personal data submitted to us or, where appropriate, contact us via the relevant website registration page or by amending the personal details held on relevant applications with which they registered.

Where we process personal data based on consent, individuals may withdraw their consent at any time by contacting us or clicking on the unsubscribe link in an email received from us.

Individuals may have other rights to restrict or object to our processing of personal data and the right to data portability.

Individuals may request information about, or human intervention into, any automated data processing that we may undertake.

If you wish to exercise any of these rights, please send an email to dpo@imaginators.co.uk

We hope that you won’t ever need to, but if you do want to complain about our use of personal data, please send an email with the details of your complaint to dpo@imaginators.co.uk

We will investigate and respond to any complaints we receive.

You also have the right to lodge a complaint with the UK data protection regulator, the Information Commissioner’s Office (“ICO”). For further information on your rights and how to complain to the ICO, please refer to the ICO website https://ico.org.uk/concerns

If you have any questions about this privacy statement or how and why we process personal data, please contact us at:

Imaginators

51 Hillgrove Business Park

Nazeing Road

Nazeing

Essex

EN9 2HB

Updates to this privacy statement will appear on this website. This privacy statement was last updated in October 2018.