Date of last revision: 1st June 2018
Martin Kemp Design takes your privacy seriously, and is committed to protecting and respecting it.
We want you to understand how we collect and use information about you. We also value your comments about the way in which we do this.
The privacy notice describes to you:
Who we are
What personal data we collect and store about you, and how we collect it
Why we collect personal data and what we do with it
The categories of third parties with whom we share your personal data
How we retain your information and keep it secure
Your rights and how to exercise them
How to contact us.
It also contains information on the correct people to contact in the unlikely event that you have a complaint.
WHO WE ARE?
Here are some key details about us:
OUR NAME: Martin Kemp Design Limited (we will refer to ourselves using the word “we” and related words such as “us” and “our” in this privacy notice)
PLACE OF INCORPORATION: England and Wales (this is where we are registered)
COMPANY NUMBER: 07721852
REGISTERED ADDRESS: Fifth Floor, 2 More London Riverside, London SE1 2AP
VAT NUMBER: GB 132303858
Under data protection law, we are considered to be a “controller”. As a controller, we are responsible for, and control the processing of, your personal data. We are registered as a data controller with the Information Commissioner’s Office, which is the UK’s supervisory authority for data protection matters.
WHAT INFORMATION DO WE COLLECT FROM YOU?
In the course of our business – namely, operating as a design studio for individuals and businesses – we collect the following personal data when you provide it to us:
Personal Details, such as
Name and title
Date of birth
Vehicle make, model and registration numbers
Contact Data, such as
Telephone and mobile number(s)
Image Data, namely
Biographical Data from job applications and CVs, such as
Academic and other results gained
Any other personal information you provide
Payment Details, such as
Transaction Data, such as
Details about payments to and from you
Details of products and services you have purchased from us and our contacts
Details about your future interior design plans
Technical Data, such as
Internet protocol (IP) address
Your login data (to the extent relevant to you), 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 our website
Usage Data, such as
Information about how you use our website, products and services
Marketing Data, such as
Your preferences in receiving marketing and communications.
We do not knowingly collect “special category” personal data. This is a type of particularly sensitive data to which more stringent processing conditions apply, and comprises data concerning your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation, and genetic data and/or biometric data.
We also do not collect information about criminal convictions or offences.
HOW DO WE COLLECTION PERSONAL DATA?
We obtain personal data from sources as follows:
Directly from you when you interact with us, for example when you
Engage our services
Subscribe to mailing lists
Attend an event
Write to us
Give us feedback
Apply for a job or send a CV
From others, if they provide your details (for example, if you are copied on an e-mail that is sent to us, and your e-mail address identifies you, we will have collected your personal data): if you are providing another person’s details, please ensure you have that person’s explicit consent to do so
From automated technologies such as cookies and tags when you use our website – for more information, please see our cookies policy at http://martinkempdesign.com/2017/05/31/martin-kemp-design/
From suppliers who may deliver products to you, if they collect personal data from you in addition to the personal data that we collect
In some circumstances from our professional advisers and service providers, such as our accountants and bank.
HOW DO 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:
To perform a contract we are about to enter into, or have entered into, with you
if it is necessary for our legitimate interests (or those of a third party) and these are not overridden by your own rights and interests
where we need to comply with a legal or regulatory obligation.
In order to process personal data, we must have a lawful reason (sometimes called a lawful basis). We always ensure that this is the case, and we set out our lawful bases below – but please note that more than one may apply at any given time: for example, if we inform you of changes to our privacy notice, we may process your personal data on the ground of complying with law and on the ground of legitimate interests.
We will use your personal data only for the purposes for which we collected it, unless we fairly consider that we need it for another reason that is compatible with the original purpose.
Please contact us if you would like more information on this, and on situations in which more than one lawful basis applies.
If you are our customer or applying for a job, we will process your personal data for the following purposes, on the legal basis that it is necessary for us to provide our products and services to you:
To identify you
To respond to your enquiries
To the extent necessary to provide pre-contractual information about our services
To provide our services, including enabling them to be delivered to you and contacting you about your order (for example, regarding stock or availability)
To carry out billing and administration activities, including refunds and credits
To evaluate your job application and take any next steps, and to evaluate your suitability for roles where you have asked to be considered for future opportunities.
We process your personal information for our legitimate business purposes, which include the following:
To conduct and manage our business
To enable us to carry out our services
To ensure our website and systems are secure (for example, by conducting security penetration tests on our website to ensure our security tools are effective)
To analyse, improve and update our services for the benefit of our customers
To deal with complaints
To let you know about our services, promotions or events that we consider may be of interest to you (and which may be tailored to your interests as construed from your purchase history): we carry out this processing on the legal basis that we have a legitimate interest in marketing our products and services, and only to the extent that we are permitted to do so by applicable direct marketing laws. Please see section 8 below for further information about our marketing activities and regarding your right to opt out.
Whenever we process your personal data for these purposes, we ensure that your interests, rights and freedoms are carefully considered.
COMPLIANCE WITH LAWS
We may process your personal data in order to comply with applicable laws (for example, if we are required to co-operate with an investigation pursuant to a court order).
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third-party direct marketing communications to you via electronic means where we are not otherwise entitled to do so. You have the right to withdraw consent to marketing at any time. This will not affect the lawfulness of processing that took place prior to the withdrawal of consent.
We will always be clear whenever we intend to process on the basis of consent, and we will process lawfully and only for the purpose for which consent was given.
DO WE SHARE YOUR PERSONAL DATA?
We may provide your personal data to the following recipients for the purposes set out in this notice:
Our service providers, including
Logistics providers, such as those who deliver our orders
Manufacturers and/or sellers of items that will be delivered to you
E-mail and mail service providers
Technical and support partners, such as the companies who host our website and who provide technical support and back-up services
Recruitment service providers
Merger or acquisition partners, to the extent that sharing your personal data is necessary
Law enforcement agencies, government or public agencies or officials, regulators, and any other person or entity that has the appropriate legal authority where we are legally required or permitted to do so, to respond to claims, or to protect our rights, interests, privacy, property or safety
Any other parties, where we have your specific consent to do so.
DO YOU HAVE TO PROVIDE PERSONAL DATA – AND, IF SO, WHY?
To form a contract with you, we will need some or all of the personal data described above so that we can perform that contract or the steps that lead up to it: this is set out above in this notice. If we do not receive the data, it will not be possible to perform that contract.
FOR HOW LONG WILL WE KEEP YOUR PERSONAL DATA?
We carefully consider the personal data that we store, and we will not keep your information in a form that identifies you for longer than is necessary for the purposes set out in this notice or as required by applicable law. In some instances, we are required to hold data for minimum periods: for example, UK tax law currently specifies a minimum six-year period for retention of some of your personal data.
We may store your contact details, and carry out marketing profiling activities, for direct marketing purposes. If you have given your consent, or if we are otherwise permitted to do so, we may contact you about our products or services that may be of interest to you. You will be given the opportunity to opt out each time you are contacted, and you may also opt out at any other time by e-mailing firstname.lastname@example.org. This will not affect the lawfulness of processing that took place prior to your opt-out.
DO WE TRANSFER PERSONAL DATA OUTSIDE THE EEA?
Although we are based in England, we may transfer your personal information to a location (for example, to a secure server) outside the European Economic Area, if we consider it necessary or desirable for the purposes set out in this notice.
In such cases, to safeguard your privacy rights, transfers will be made to recipients to which a European Commission “adequacy decision” applies (this is a decision from the European Commission confirming that adequate safeguards are in place in that location for the protection of personal data), or will be carried out under standard contractual clauses that have been approved by the European Commission as providing appropriate safeguards for international personal data transfers, or by the adoption of EU-US Privacy Shield.
For more information, please contact us using the details in section 15 below.
HOW DO WE KEEP YOUR PERSONAL DATA SECURE?
We have security measures in place designed to prevent data loss, to preserve data integrity, and to regulate access to the data. Only our authorised employees and third parties processing data on our behalf have access to your personal data.
The security measures we have in place include:
Regular reviews of information collection, storage and processing practices to protect against unauthorised access
Restriction of access to personal information
Monitoring of systems storing and processing information
Use of secure technologies (e.g. SSL, encryption)
Scenario planning and crisis-management exercises to ensure we are ready to respond to cyber security attacks and data security incidents.
We take all reasonable steps to keep your data safe and secure and to ensure the data is accessed only by those who have a legitimate interest to do so. 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 us. Any transmission over the internet is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.
Please contact us using the details in section 15 below if you would like more information about this.
YOUR INFORMATION RIGHTS
We draw your attention to your following rights under data protection law:
Right to be informed about the collection and use of your personal data
Right of access to your personal data, and the right to request a copy of the information that we hold about you and supplementary details about that information – you will be asked to provide proof of your identify and residential address, and we may ask you to provide further details to assist us in the provision of such information
Right to have inaccurate personal data that we process about you rectified – we want to ensure that the personal information that we process and retain about you is accurate, so please do remember to tell us about any changes, for example if you have moved house or changed your contact details. It is your responsibility to ensure you submit true, accurate, and complete information to us – and please also update us if this information changes
Right of erasure – in certain circumstances you have the right to require us to block, erase or destroy personal data that we process about you
Right to object to, or restrict:
Processing of personal data concerning you for direct marketing
Decisions being taken by automated means which produce legal effects concerning you or that similarly significantly affect you in certain other situations, our continued processing of your personal data
The right of portability of your data in certain circumstances.
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.
Please contact us using the details in section 15 below if you would like to know more about, or to exercise, these rights.
These rights are subject to certain limitations that exist in law. Further information about your information rights is available on the ICO’s website: https://ico.org.uk/.
For more information on which cookies we use and how we use them, please see our cookies policy at http://martinkempdesign.com/2017/05/31/martin-kemp-design/.
CHANGES TO THIS PRIVACY NOTICE
We may change this notice from time to time. You should check this notice on our website occasionally, in order to ensure you are aware of the most recent version.
WHAT SHOULD YOU DO IF YOU HAVE A COMPLAINT?
We hope that you will be satisfied with the way in which we approach and use your personal data.
Should you find it necessary, you have the right to raise a concern with our supervisory authority, the Information Commissioner’s Office: https://ico.org.uk/.
However, we do hope that if you have a complaint about the way we handle your personal data, you will contact us in the first instance using the contact details in section 15 below, so that we have an opportunity to resolve it.
DO YOU WANT TO CONTACT US?
If you would like to contact us about this notice, including if you wish to receive further information about any aspect of it, our details are as follows:
Martin Kemp Design Limited
London SW1P 1DH
For the attention of: Charlotte Marshall
0207 183 3885