1. WHO WE ARE
Independent Creative Academy Ltd (“ICA” or “we” or “us”). We care about your privacy and are committed to processing your personal information fairly and transparently and in accordance with data protection law, including the General Data Protection Regulation (“Data Protection Law”). Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. If after reading this Privacy Notice you still have questions, feel free to drop us a line by using the contact details set out below and our customer services team will be happy to help.
For the purpose of the Data Protection Law, the data controller is Independent Creative Academy Ltd, contact is: firstname.lastname@example.org
2. WHAT TYPE OF INFORMATION IS COLLECTED FROM YOU?
We collect personal information about you when you use our website www.independentcreativeacademy.com (the/our “Website”) or interact with us via other channels such as social networks.
We collect information that you provide to us when filling out a form, communicating with us, making enquiries or visiting our Website. This includes or may include your name, username, address, password, date of birth, email address, telephone number, your location, social media profile information (where you reach out via social media such as Facebook or Instagram) and content of your communications. We also collect transaction information from when you make a purchase including your payment credit card information and the products you buy. This also includes profile information such as the Independent Creative Academy Ltd products and services you like.
Other personal data can be collected automatically, for example your browsing or shopping activity. We may also log general information about your browser or device whenever you visit our Website. This information may include your computer’s Internet Protocol (IP) address, your browser type and version, the pages you visit on our Website, the time and date of your visit, and the time spent on each page. Like most website operators, we collect this data to better understand how our visitors use our services, and how we may improve your experience of our Website in future.
In specific instances, we may need to collect additional data for the purposes explained to you at that time.
3. INFORMATION THAT WE RECEIVE FROM OTHER PEOPLE
We work closely with third parties (including, for example sub-contractors in technical and delivery services, advertising networks, online analytics providers and search information providers) who may collect personal information from you and pass it on to us. Where this is the case, the relevant third party is responsible for notifying the details of the same to you and for obtaining the relevant consents from you (if necessary) to ensure you are happy with the ways in which your personal data will be used.
4. HOW IS YOUR INFORMATION USED AND WHAT IS THE LEGAL BASIS FOR THIS USE?
We process your information for the following purposes:
To fulfil a contract, or take steps linked to a contract: this is relevant where you make a purchase from us or enter a competition we run. This includes:
to process and fulfil any orders, subscriptions or other purchase made online and via our delivery service;
to communicate with you about your orders, subscriptions or purchase you have made and provide customer service;
to process your payments;
to verify your identity;
to process any entries that you make into competitions run by us;
As required to conduct our business and pursue our legitimate interests, in particular:
to communicate with you about Independent Creative Academy Ltd products, services and offers that may be of interests to you where we do not need you consent to do so;
to provide products and services you have requested and for customer services purposes to respond to any comments or complaints you send us;
to continuously improve our products and services and personalise your experience online;
where necessary, to notify you about changes to our services or our Website;
to provide you access to our Website, to administer it and for internal operations;
to keep our Website and other Independent Creative Group systems safe and secure;
to improve your user experience, by ensuring that content is presented in the most effective manner;
to better understand our customers, how often they come to and how long they spent in our Website and use other Independent Creative Academy Ltd services;
for market research purposes – so that we can understand your needs better;
for customer service purposes – so that we can talk and interact with you;
to process a job application and where we have a legal right or duty to use or disclose your information (for example in relation to an investigation by a public authority or in a legal dispute).
Enforce or apply our website terms of service and any other agreement or protect the rights, property, or safety of Independent Creative Academy Ltd , customers, employees, agents, instructors and contractors or others. Where you give us your consent:
We send you marketing communications about relevant Independent Creative Academy Ltd products, services and offers that we believe are of interest to you, or other products and services provided by us and our affiliates.
we place cookies and use similar technologies to personalise your experience on our Website and offer you products and services tailored to your interests in accordance with our cookies notice and the information provided to you when those technologies are used
on other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time.
We also process information relating to you and your online behaviour less directly by:
combining data you provide to us with other data (such as transaction data from our till and vouchering system) to help personalise any marketing and communications that you have consented to receive; and
For purposes which are required by law:
responding to court orders, subpoenas or other legal processes with which Independent creative Academy Ltd is required to comply;
for crime and fraud prevention, detection and related purposes.
In certain circumstances, some of the above grounds for processing will overlap and there will be several grounds which justify our use of your personal information.
Where we process personal data on the basis of your legitimate interests, then – as required by data protection law – we have carried out a balancing test to document our interests, to consider what the impact of the processing will be on individuals and to determine whether individual´s interests outweigh our interests in the processing taking place. You can obtain more information about this balancing test by using the contact details at the end of the notice.
5. WITH WHOM DO WE SHARE YOUR INFORMATION?
a. Third Party Service Providers working on our behalf
In order to make certain services available to you, we may pass your information to our third-party service providers, agents and subcontractors. These include IT, Website hosting, delivery and marketing service providers and payment processors (for example, to process deliveries and send you your order confirmation).
b. Third Party partners
If you have consented, we allow carefully selected third parties, including marketing and advertising companies, or our business partners, to contact you occasionally about services that may be of interest to you. They may contact you by telephone, post, SMS as well as by e-mail, if you have consented. We also share your information with third party delivery providers and employ third-party companies and individuals to help us analyse and reach out to customers or potential customers (for example, analytics providers, content partners; and social media partners such as Facebook).
c. Third Party Providers we work with
Independent Creative Academy Ltd works closely with our third party suppliers to bring you high quality services and products. When you send us feedback or comment on any of our products or services we may need to share such feedback/comment with our relevant supplier(s).
d. Third Parties with whom we transact
If any of our businesses enter into a joint venture with, purchase or are sold to or merge with another business entity, or in the unlikely event that we go out of business or enter bankruptcy; your information may be disclosed or transferred to the target company, our new business partners, administrators, or owners or their advisors.
e. Sharing to comply with legal obligations
We may use the information that you provide to us if we are under a duty to disclose or share your information in order to (a) comply with (and/or where we believe we are under a duty to comply with) any legal obligation; (b) enforce or apply our website terms of service and any other agreement; or (c) protect the rights, property, or safety of Independent Creative Academy Ltd , customers, employees, instructors, contractors or others. This includes exchanging information with other companies and other organisations for the purposes of fraud protection and prevention, or where we have to carry out an internal investigation.
6. YOUR RIGHTS
We will usually inform you (before collecting your information) if we intend to use your information for marketing or research purposes or if we intend to disclose your information to any third party for such purposes. Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by following the instructions to unsubscribe in the relevant marketing communication, by changing your marketing preferences through our preference centre or by contacting us via the details set out in section 11 below. You have the right to see the information we hold about you and to ask us to: (a) make changes to ensure that any information we hold about you is accurate and up to date; (b) erase or stop processing any information we hold about you where there is no longer a legal ground for us to hold it; or (c) in some cases, transfer any information we hold about you to a specified third party. In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement). These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep. Should you have any queries or complaints in relation to how we use your information, please contact us via the details set out at section 14 below. Should you wish to take any complaints or queries further, you have the right to contact your local data protection regulator (which, in the UK, is the Information Commissioner’s Office) regarding such issues.
7. HOW LONG DO WE RETAIN YOUR INFORMATION?
Where we process registration data, we do this for as long as you are an active user of our sites and for 6 years after this.
Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely so that we can respect your request in future.
Where we process personal data in connection with performing a contract , subscription or for a competition, we keep the data for 6 years from your last interaction with us.
8. LINKS TO OTHER WEBSITES
Our Website may contain links to other websites run by other organisations (for example, we use social media sites such as Instagram and YouTube). ICA privacy notice applies only to our Website and company‚ so we encourage you to read the privacy notices on the other websites you visit. We cannot be responsible for the privacy notices and practices of other sites even if you access them using links from our website.
10. DATA TRANSFERS
In addition to the data sharing described in section 5, the information that we collect from you may also be transferred to, and stored at, a destination outside the UK or the European Economic Area (“EEA”). It may also be processed by staff operating outside the UK or the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, the provision of support services. Where information is transferred outside the UK or the EEA, and where this is to a stakeholder or vendor in a country that is not subject to an adequacy decision by the UK or the EU Commission, data is adequately protected by EU Commission approved standard contractual clauses or a vendor’s Processor Binding Corporate Rules. You can obtain additional information about the relevant mechanism by using the contact details below.
If you have any questions feel free to visit our contact page. This is also an ideal place to send us feedback and comments; you’ll always get a response from our lovely customer services team. Alternatively you can contact us at: email@example.com