Who we are
We are Truth Be Told Communications Limited, a company registered in Scotland (company number SC717486) whose registered office is at 64a Cumberland Street, Edinburgh, Scotland, EH3 6RE.
We are a controller for the purposes of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27th April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation) as it forms part of the law of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018 (the UK GDPR), the Data Protection Act 2018 and related data protection legislation.
How to contact us
If you have any questions about this privacy notice or our data protection policies generally please contact us at Fiona.Robertson@Truthbetold.co.uk.
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 please contact us in the first instance.
Privacy notice
We are committed to protecting your personal data and your privacy. This privacy notice sets out the basis on which any personal data we collect from you, or that you provide to us, or that we acquire through a third party, will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
Before we process your personal data, we are obliged to inform you of who we are, why we need to process your personal data, what we will do with your personal data and to whom we will pass your personal data.
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.
This privacy notice does not apply to employees, workers or other staff of Truth Be Told Communications Limited.
This version of our privacy notice was last updated on 24 January 2022.
What personal data do we collect and process?
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 of the individual has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
· Identity Data includes first name, last name, marital status, title., date of birth and gender.
· Contact Data includes home or work address, email address and telephone numbers.
· Financial Data includes bank account and payment card details.
· Transaction Data includes details about payments to and from you.
· Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
· Employment Data includes job title and role.
· Usage Data includes information about your visit and how you use our website at www.truthbetold.co.uk (Website).
We may collect, use and share "Aggregated Data" such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any “Special Categories of Personal Data” about you (this 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). Nor do we collect any information about criminal convictions and offences.
How is your personal data obtained?
We use different methods to collect personal data from and about you including through:
Failure to provide personal data
Where we need to collect personal data 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 services for you.
Cookies
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.
Marketing
If you are a sole trader or another type of non-corporate data subject, we will only provide you with direct marketing communications where you have consented to receive such communication or you have contacted us directly to request specific information about our services. You can subscribe to such marketing communications, and you can adjust your marketing preferences at any time by contacting us at Fiona.Robertson@Truthbetold.co.uk
If you represent another business, we may provide you with direct marketing communications where we feel that this may be relevant to your business (provided that you have not opted out of such communications). When we use your personal data for such purposes, we do so on the basis that it is in our legitimate interests to pursue direct marketing, provided that it constitutes fair processing of your personal data to do so.
You can also opt-out or unsubscribe from all or some of these marketing communications at any time by contacting us at Fiona.Robertson@Truthbetold.co.uk
Where you opt out of receiving these marketing communications, this opt-out will not apply to personal data provided to us for any other purpose.
How will we use your personal data?
Personal data may be processed by us where you consent to the processing or where that processing is necessary for 1) the performance of a contract with you and/or to provide services to you; or 2) compliance with a legal obligation to which we are subject; or 3) the purposes of our legitimate interests (or those of a third party).
Legitimate interests means the interest of our business in conducting and managing our business to enable us to give you the best service/product 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 do not 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.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.
We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground or grounds we are relying on to process your personal data.
Purpose/Activity: Where you are a business customer
Type of data: Identity, Contact, Financial, Transaction, Marketing and Communications, Employment
Lawful basis for processing (including basis of legitimate interest):
Performance of a contract with you, Necessary for our legitimate interests (to recover debts due to us and to manage customer relationships), Necessary to comply with a legal obligation, With your consent where we provide marketing information to you and you are an individual customer, sole trader or another type of non-corporate customer
Purpose/Activity: Where you are a business contact (other than a client)
Type of data: Identity, Contact, Marketing and Communications, Employment
Lawful basis for processing (including basis of legitimate interest): Necessary for our legitimate interests (to manage our business relationships), Necessary to comply with a legal obligation, With your consent where we provide marketing information to you and you are a sole trader or another type of non-corporate business contact
Purpose/Activity: Where you use our Website
Type of data: Identity, Contact, Marketing and Communications, Usage, Employment
Lawful basis for processing (including basis of legitimate interest): Necessary for our legitimate interests (to maintain network security and Website relevance for visitors to our Website), Necessary to comply with a legal obligation, With your consent where we provide marketing information to you and you are an individual, sole trader or another type of non-corporate
Purpose/Activity: To establish, exercise and defend our legal rights
Type of data: All data
Lawful basis for processing (including basis of legitimate interest): Necessary for our legitimate interests (in protecting our legal rights)
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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at Fiona.Robertson@Truthbetold.co.uk
With whom do we share your personal data?
We may have to share your personal data with the parties set out below for the purposes set out in the table above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party processor service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Any sharing of your personal data will only take place:
International transfers
We generally do not transfer your personal data out of the UK. However, whenever we are required to transfer your personal data out of the UK (for example where a third-party supplier is located outside of the UK), we ensure a similar degree of protection is afforded to it by ensuring that appropriate safeguards are implemented, including any of the following:
Where you use the Website in a country outside the UK, your personal data will be transferred to and processed in the country from where you have accessed it. You acknowledge and agree that such a transfer of your personal data outside the UK in such circumstances is entirely your responsibility.
Automated decision making and profiling
We do not use automated decision-making (including profiling) to make any decisions which would produce a legal effect or similarly significantly affect a data subject.
How long do we retain your personal data?
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.
For tax purposes, we retain basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers.
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 the Information Commissioner's Office of a breach where we are legally required to do so.
Your rights
Your personal data is protected by legal rights, which include your rights to:
If you wish to exercise any of these rights, please contact us using the details above.
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.
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.
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. In this case, we will notify you and keep you updated.
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