PRIVACY POLICY

WHO WE ARE

This is the privacy policy of Black & White Thinking Limited (“we”, “us”, “our), a company registered in England and Wales (number 08001061) whose registered office address is 2nd Floor, 130 Shaftesbury Avenue, London W1D 5EU.

We are committed to protecting and respecting your privacy.

This privacy policy aims to give you information on how we collect and process your personal data through your use of this website.

This website is not intended for children and we do not collect personal data relating to children. Should we ask you to provide certain personal data by which you can be identified when using the website, you can be assured that it will only be used in accordance with this privacy policy.

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.

WHEN WE COLLECT PERSONAL DATA AND WHAT PERSONAL DATA WE COLLECT

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 and store the following personal data about you, which we have grouped into the following categories:

• If you fill in the form on our website, we will collect your name, email address and any other information you provide in the form.
• If you contact us by any other means (e.g. email or telephone), we may keep a record of that contact and the information you provide us with at that time.
• If you ask to be added to our marketing database, we will collect your name, the name of your company/organisation (if any), email address and your preferences as to the types of marketing information you would like to receive from us.
• If you engage us to provide you with any of our services, we will collect your billing address, your professional email address and work telephone numbers. We will also collect information about transaction details about payments to and from your organisation and other details of services you have purchased from us including any testimony you are willing to write about us and our performance.
• If we engage you to provide us with services or goods, we will collect your billing address, your professional email address and work telephone numbers. We will also collect details of your rate cards, your quotations, transaction details about payments to the organisation you work for and other details of services or goods we have purchased from you.
• If you partake in any of our live events, we will collect your contact details and any videography and/or photography material of you, provided we have obtained your consent to do so.
• If you attend any of our live events, we may collect videography and photography material of you. We will have notices at our live events notifying you that we are doing this.
• If your personal data is on publicly available sources (such as LinkedIn and Companies House) then we may collect your personal data that is available on these sources.

OTHER INFORMATION COLLECTED VIA OUR WEBSITE AND COOKIES

As you interact with our website, we may automatically collect information about your website usage such as information about your equipment, browsing actions and patterns. We collect this information by using cookies, server logs and other similar technologies.

Our website uses a limited number of cookies, namely:

• Cookies which stores your acceptance to the use of cookies on our website.
• Cookies required by Google Analytics and Squarespace in order to measure your website usage and improve the experience for our visitors on an ongoing basis. These cookies collect the information about your website usage, namely what pages you visit, how long you stay on each section of the website, and what links you click on.

We may use data analytics to improve our website, services, marketing, customer relationships and experiences.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

PURPOSE FOR WHICH WE USE YOUR PERSONAL DATA

• To manage our relationship with you which will include pitching for business with you, registering you as a new client, notifying you about changes to our terms or privacy policy, asking you to leave a review or take a survey. We will do so on the basis that it is necessary in order to review our performance of our contract with you and also to comply with a legal obligation.
• To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) on the basis that it is necessary to comply with a legal obligation and that we have a legitimate interest to do so (for running our business, provision of administration and IT services, network security and to prevent fraud).
• To deliver relevant website content and send marketing information to you and measure or understand the effectiveness of these activities. We will do so on the basis that you have consented to us processing your personal data in this way. You can always stop receiving marketing information from us at any time as these communications provide easy ways to unsubscribe or update your preferences.
• To process and deliver our services to the organisation you work for, including providing you with a quote, reviewing our clients’ campaign evaluations, managing payments, fees and charges and collecting and recovering money owed to us on the basis of our performance of our contract with you.
• To process your goods and/or services delivered to us, including but not limited to the processing of payments to the organisation your work for on the basis of our performance of our contract with the organisation you work for.
• To use the videography and photography material during the course of our business (including by displaying the material on our clients’ website and social media platforms) on the basis that you have consented for us to do so or that we have a legitimated interest to do so (to secure contracts with our clients and to grow and promote our business and our clients’ business).

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.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

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.

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.
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.

WHO WE SHARE YOUR PERSONAL DATA WITH

We may disclose your personal data to third parties as follows:

• If we are under a duty to disclose or share it in order to comply with any legal obligation (for example our auditors, our insurers and HMRC).
• With media publications applicable to our industry. We make use of these publications to promote our services and we will only share your personal data with these media publications if they have agreed with us that they will only process your personal data on our instructions and that they will keep it confidential and secure.
• With sub-contractors who we engage to assist us in providing our services on the basis that we have a legitimate interest to do so and then only if they have agreed with us that they will only process your personal data on our instructions and that they will keep it confidential and secure.
• With our clients who engage or have engaged us to provide our services to, in order to provide feedback on the success of their campaign or to improve the provision of our services on the basis that we have a legitimate interest to do so and then only if they have agreed with us that they will only process your personal data on our instructions and that they will keep it confidential and secure.

DATA RETENTION

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.

The table below sets out further details:

Circumstances in which personal data was provided How long do we keep it?
When you contact us via our website. 7 years from the date of our last communication with you.
When you contact us by any other means (e.g. email or telephone) which does not lead to a contractual relationship. 7 years from the date of our last communication with you.
When we receive your information from publicly available sources or when you are added to our marketing database. Until you request the information to be removed or we refresh our database to suppress dormant entries (typically on an annual basis).
When we collect videography/photography material of you at any of our live events. 7 years from the date of the live event.
When you engage us to provide you with any of our services. 7 years from termination or expiry of our contract with you.
When we engage you to provide us services or goods. 7 years from termination or expiry of our contract with you.


WHERE WE STORE YOUR PERSONAL DATA AND HOW IT IS KEPT SECURE

Some of the information you provide to us will be transmitted electronically, e.g. information provided via our website or by email. We would remind you that information transmitted via the internet is not completely secure and although we will do our best to protect any information transmitted in this way, we cannot guarantee its complete security.

We have put in place appropriate security measures to prevent your personal data being accidently lost, accessed or used in an unauthorised way, altered or disclosed. All information you provide to us is stored in locked cupboard at our offices with a 24 hours security system in place. We also store your personal data on our secure servers located in Surrey in the United Kingdom.

We do not transfer your personal data outside the European Economic Area (EEA).

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.

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.

YOUR RIGHTS IN RELATION TO THE PERSONAL DATA WE HOLD

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.

Contacting us

If you would like to communicate with us about any of the rights mentioned above, or if you have any other queries about the matters mentioned in this privacy policy, please contact us using one of the following options:

• Website: https://blackandwhitethinking.co.uk/
• Email: Info@blackandwhitethinking.co.uk
• Post: 2nd Floor, 130 Shaftesbury Avenue, London W1D 5EU
• Telephone: 0207 036 2965

Complaints

You have the right to complain to the Information Commissioner about the way in which we collect and use your personal data: www.ico.org.uk/concerns or telephone 0303 123 1113.

Changes to this privacy policy

This policy is effective from 25 November 2019. We may change this privacy policy from time to time by updating this webpage.