1. Important information and who we are
Big Bite is the “controller” of the Personal Information that we collect about you, and as such we’re responsible for your personal data and for ensuring that it’s handled legally and safely.
Full name of legal entity: Big Bite Creative Ltd
Postal address: Big Bite Creative Ltd, 16-26 Albert Road, Middlesbrough, TS1 1PR
Name of Data Privacy Manager: Sarah McCormick
Email address: firstname.lastname@example.org
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 in the first instance please contact us.
Your duty to inform us of changes
It’s important that the personal information we hold about you is accurate and current, so please keep us informed if your personal information changes during your relationship with us.
Third party links
When using our website it may include links to third party websites, plug-ins and applications, and by clicking on those links or enabling those connections, you may allow third parties to collect or share data about. Please note that we don’t control these third party websites, and therefore Big Bite is not responsible for their privacy policies or similar statements.
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 doesn’t include data where the identity has been removed (anonymous data).
Big Bite may collect, use, store and transfer different kinds of personal data about you which we’ve grouped together as follows:
Identity data – This includes your first name, last name, title, job title, username or similar identifier.
Contact data – This includes your postal address, billing address, email address and telephone numbers.
Transaction data – This includes details of services that you’ve purchased from us.
Technical data – This includes your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Big Bite website.
Usage data – This includes information about how you use our website, products and services.
Financial data – This includes bank account and payment card details.
Profile data – This includes your username and password if applicable, as well as feedback, survey responses, and correspondence and communication with Big Bite
Marketing and communications data – This includes your preferences on the type and frequency of marketing material you’d like to receive from us, details of your enquiries with us and our third parties, and your communication preferences.
This list is not exhaustive and in specific instances we may need to collect additional data for the purposes set out in this Policy.
We also collect, use and share aggregated data – such as statistical or demographic data – for any purpose, such as calculating the percentage of users accessing a specific feature on our website. While aggregated data may be derived from your personal data, it isn’t considered personal data in law as it doesn’t directly or indirectly reveal your identity, however in the event that it’s combined or connected with any personal data that can be used to identify you, it will be regarded as personal data in accordance with this policy.
Big Bite does not collect any special categories of personal data about you – which 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 – and we do not collect any information about criminal convictions and offences.
In addition, our services and our website are not aimed at anyone under the age of 16, and we don’t knowingly collect personal data from children. If you’re a parent or legal guardian and you become aware that your child has provided Big Bite with personal information without your consent, please contact us so we can delete the data from our files.
If you fail to provide personal data
Where we need to collect personal data either by law, or under the terms of a contract we have with you, 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 (for example, to provide you with services). In this case, we may have to cancel any services you’re receiving from Big Bite, however we’ll notify you at the time if this is the case.
3. How we collect your personal information
We use a number of different methods to collect personal information, which include:
Direct interactions – You may give us your personal information by filling in forms or by corresponding with us by post, phone, email, video calls, in person, or otherwise. This includes personal data you provide when you do any of the following:
- Enquire about our services
- Utilise our services
- Correspond with Big Bite
- Request marketing or published material to be sent to you
- Participate in surveys
- Register for an event
- Access resources, including videos, podcasts and white papers
- Give us some feedback
Third parties or publicly available sources – We may receive personal information about you from various third parties our publicly available sources including (but not limited to):
- Analytics providers
- Advertising networks
- Search information providers
- Providers of technical, payment and delivery services
- Data brokers or aggregators
- Companies House
- Credit reference agencies
- Social media and company websites
4. How we use your personal information
Big Bite will only use your personal data when we have a legitimate basis for doing so, and will process it in a fair and lawful way for limited purposes. Normally, we’ll use the information when any of the following valid reasons apply:
- Where we need to deliver agreed services to you, or to take necessary steps prior to entering into a contract with you
- Where it’s necessary for our legitimate interests – or those of a third party – and your fundamental rights don’t override those interests
- Where we need to comply with a legal or regulatory obligation
- Where we have consent to do so
Generally we don’t rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you, and you have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we’ll use your personal information
We may use your personal information for a number of different purposes and for each of those purposes, we’re required to confirm the ‘legal basis’ that permits us to do so. For your reference, we’ve outlined this information in the table below:
|Purpose / activity||Type of data||Lawful basis for processing|
|To register you as a new client||(a) Identity (b) Contact (c) Profile||Performance of a contract with you|
|To deliver agreed services and collect payments, charges and fees owed to us in relation to those services||(a) Identity(b) Contact(c) Financial(d) Transaction(e) Marketing and communications(f) Profile||(a) Performance of a contract with you(b) Necessary for our legitimate interests (to recover debts due to us)|
|To administer and protect our business and our Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity(b) Contact(c) Technical||(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)(b) Necessary to comply with a legal obligation|
|To deliver relevant Website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity(b) Contact(c) Profile(d) Usage(e) Marketing and communications(f) Technical||Necessary for our legitimate interests (to study how clients use our services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our Website, products/services, marketing, customer relationships and experiences||(a) Technical(b) Usage||Necessary for our legitimate interests (to define types of clients for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity(b) Contact(c) Technical(d) Usage(e) Profile||Necessary for our legitimate interests (to develop our services and grow our business)|
|To enable you to complete a survey or provide feedback||(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and communications||(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how clients use our products/services, to develop them and grow our business) c) To improve the services we offer you|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
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 (we call this marketing).
We may use your personal information to send you updates – by email, telephone or post – about our services or new services, as well as developments related to our industry that we believe may be of interest to you. As we have a legitimate interest in processing your personal information for our business development purposes, we do not usually need your consent to send you such information if you are an existing client, however where consent is needed, we’ll ask for it separately and clearly. We’ll also advise you of how to opt-out of receiving such communications where we are required to do so in accordance with applicable law.
Third party marketing
We’ll obtain your express opt-in consent before we share your personal data with any company outside of Big Bite for marketing purposes.
You have the right to opt out of receiving marketing communications from us at any time by either contacting us directly or using the ‘unsubscribe’ (or similar opt out) link included in our marketing emails.
We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
Change of purpose
Big Bite 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 you’d like to request an explanation on how the processing for the new purpose is compatible with the original purpose, please email us at email@example.com.
In the event that we need to use your personal data for an unrelated purpose, we’ll notify you and 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.
5. Disclosures of your personal information
We may have to share your personal data with the parties set out below for the purposes set out in the table in section 4 of this policy:
- Internal third parties
- External third parties as set out in the glossary of this policy
- Third parties that 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 information and to treat it in accordance with the law. We don’t allow our third party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
6. International transfers
We share your Personal Information within Big Bite, and although this will not usually involve transferring your data outside the UK, due to the global nature of the internet and cloud-based infrastructure, it may sometimes be necessary for us to share your personal information with external third parties that are based outside of the UK. This means that their processing of your personal information will involve a transfer of data outside the UK, however we’ll ensure that a similar degree of protection is implemented and that at least one of the following points applies:
- We’ll only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
- Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
If none of the above safeguards are available, we may request your explicit consent to the specific transfer and you will have the right to withdraw this consent at any time.
7. Keeping your information secure
We have appropriate security measures in place to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
We also ensure that your personal information can only be accessed by employees, agents, contractors and other third parties who have a need to know, are all aware of their privacy and data security obligations, will only process your personal data on our instruction, and are subject to a duty of confidentiality.
In addition we have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Retaining your information
How long will you use my personal information for?
We’ll only retain your personal information for as long as it’s necessary to fulfil the purposes we collected it for – this can include the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.
We assess the appropriate retention period for different types of personal information based on the potential risk of harm to you from unauthorised use or disclosure of that information, as well as the size, volume, nature and sensitivity of the information, the purposes for which we collect and process the information, and whether or not we achieve those purposes without using that information.
In some circumstances, you can ask us to delete your data – please refer to section 9 of this policy for further information.
In some circumstances, we may anonymise your personal data – so 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.
If you apply for a job with us and your application is successful, we’ll provide further information during the course of your employment on how we use your personal information.
In instances where your application for employment with us is unsuccessful, we’ll keep your personal information for 12 months only.
Employees of our clients and suppliers
Where we have collected your personal information during the course of your and our organisations doing business, we’ll keep your information for as long as this business carries on, or for as long as we have a commercial interest in holding your personal information, for example, with a view to doing business in the future.
Any information collected for security purposes is stored only for as long as needed for the purposes stated above, which is not normally longer than two years.
Any videos or images captured of you by the CCTV system on our UK premises are kept for no longer than 12 months.
9. Your legal rights
Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:
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’re lawfully processing it.
The right to 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 that you provide us with.
The right to 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’ve successfully exercised your right to object to processing (see below), or where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Please 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.
The right to 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.
The right to 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.
The right to 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.
The right to withdraw consent at any time where we are relying on consent to process your personal data.
If you wish to exercise any of the rights set out above, please contact our Data Privacy Manager at firstname.lastname@example.org.
No fee usually required
You won’t have to pay a fee to access your personal data, or to exercise any of the other rights, however, if your request is clearly unfounded, repetitive or excessive, we may charge a reasonable fee or refuse to comply with your request.
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, however where this is the case, we’ll notify you and keep you updated.
|Legitimate interest||This means the interest of our business in conducting and managing our business to enable us to give you the best service/deliverable 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 don’t 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. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.|
|Personal information or personal data||This means any information relating to an identified or identifiable natural person (“data subject”), which is someone who can be identified – directly or indirectly – in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.|
|Performance of contract||This 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.|
|External third parties||This means service providers acting as processors based in and outside of the EU, and can include:IT and system administration service providersProfessional advisers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting servicesHM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.|
|Consent||This means obtaining your explicit, informed and freely given consent to the processing of your personal data by an unambiguous statement or clear affirmative action on your part.|
|Website||This means the website at this address: www.bigbite.net|