Introduction
Brand 22 Ltd (“Brand Twenty Two”, “we, “us”, “our”) is committed to protecting the privacy and security of the personal data we collect about end customers and users of our services (“you”, “your”).
The purpose of this privacy notice is to explain what personal data we collect about you when you visit our website or use our services. When we do this, we are the Controller of the personal data we process, registered in the UK with the Information Commissioner’s Office (“ICO”), registration number ZB319539.
Please read this privacy notice carefully as it provides important information about how we handle your personal information and your rights. If you have any questions about any aspect of this privacy notice, you can contact us using the information provided below (in the Contact us section).
We update this privacy notice from time to time in response to changes in applicable laws and regulations, to our processing practices and to the products and services we offer. When changes are made, we will update the date at the top of this document. Please review this privacy notice periodically to check for updates.
Personal data we collect
Brand Twenty Two is primarily a business-to-business service provider, as such we may collect the personal data of employees of our business customers. We may collect the following categories of personal data:
For the provision of our products and services:
first name and surname;
job title;
business name;
business email address; and
business or personal phone numbers.
Relating to use of our cloud-based secure storage solution:
username;
password;
IP addresses (logged for data security purposes);
files and folders accessed; and
time stamp of all activity.
With regard to each of your visits to our website or our cloud-based secure storage solution, we may automatically collect technical information, including:
the IP address used to connect your computer to the internet;
your login information;
browser type and version;
time-zone setting;
browser plug-in types and versions; and
operating system and platform.
We may also collect other information about your visit, including:
the full URL clickstream to, through and from our site (including date and time);
products and services you viewed or searched;
page response times;
download errors;
length of visits to certain pages;
page interaction information (such as scrolling, clicks and mouse-overs);
methods used to browse away from the page; and
any phone number used to call us.
Information we receive from other sources.
We may receive information about you from any other websites we operate or from other third parties including:
business partners;
sub-contractors in technical, payment and delivery services;
advertising networks;
analytics providers; and
search information providers.
Purposes for which we use personal data and the legal bases
When providing services to you, we may use your personal data for the following purposes and on the following lawful bases:
Purpose
Responding to correspondence from you.
Lawful Basis for Processing
It is in our legitimate interest to respond to enquiries made via our website, by email, through our social channels or any other means.
Purpose
Sending you information such as product information which may be of interest.
Lawful Basis for Processing
If you are an existing customer or have expressed an interest in our products or services, we will rely on legitimate interests to contact you for marketing purposes. You may object to the processing for this purpose by emailing privacy@brandtwentytwo.com. If we have captured your consent for the purposes of marketing, that consent may be withdrawn at any time by emailing privacy@brandtwentytwo.com.
Purpose
Maintenance of security and ensuring the health and safety of employees and on-site visitors.
Lawful Basis for Processing
We have a legitimate interest in maintaining secure, safe premises for employees and on-site visitors and to protect company property.
Purpose
Improving our websites and the overall website visitor and user experience.
Lawful Basis for Processing
It is our legitimate interest to allow analytics and search engine providers to help improve and optimise our websites.
Purpose
Improving our websites and the overall website visitor and user experience.
Lawful Basis for Processing
We use cookies on our websites with your consent.
Where personal data is processed because it is necessary for the performance of a contract to which you are a party, we will be unable to provide our services without the required information.
Sharing your data
It is unlikely that we will ever share your personal data outside the UK. If a business need arises and it becomes necessary for us to share your data outside the UK for the purposes of providing our services to you, we will only share it with organisations in countries which benefit from a UK Adequacy Regulation, or if not, by using the UK International Data Transfer Agreement, which contractually obliges the recipient to process and protect your personal data to the standard expected within the UK.
How long we keep your data
We will retain your personal data for as long as is necessary to provide you with our services and for a reasonable period thereafter to enable us to meet our contractual and legal obligations and to deal with complaints and claims.
At the end of the retention period, your personal data will be securely deleted or anonymised, for example by aggregation with other data, so that it can be used in a non-identifiable way for statistical analysis and business planning.
How we protect your data
We implement appropriate technical and organisational measures to protect data against unauthorised or unlawful processing and against accidental loss, destruction or damage.
In addition to the technical and organisational measures we have put in place, there are simple things you can do to in order to further protect your personal information, such as:
Never share One Time Passcodes (OTPs).
Never enter your details after clicking on a link in an email or text message.
Always send confidential information by encrypted email to reduce risk of interception.
If you’re logged into any online service do not leave your computer unattended.
Close down your internet browser once you’ve logged off.
Never download software or let anyone log on to your computer or devices remotely, during or after a cold call.
You can easily identify secure websites by looking at the address in the top of your browser which will begin https:// rather than http://.
Your data protection rights
There are certain, fundamental, rights that you have in respect of your personal data:
Rights
Right to be informed.
Description
Individuals have the right to be informed about the collection and use of their personal data.
Rights
Right of access.
Description
Individuals have the right to receive a copy of their personal data, and other supplementary information.
Rights
Right to rectification.
Description
Individuals have the right to have inaccurate personal data rectified or completed if it is incomplete.
Rights
Right to erasure (the ‘right to be forgotten’).
Description
Individuals have the right to request their personal information to be erased, in certain circumstances.
Rights
Right to restrict processing
Description
Individuals have the right to request the restriction or suppression of their personal data, in certain circumstances, in particular:
if your data is not accurate;
if your data has been used unlawfully but you do not want us to delete it;
if your data is no longer needed, but you want us to keep it for use in legal claims; or
if you have already asked us to stop using your data but you are waiting to receive confirmation from us as to whether we can comply with your request.
Rights
Right to data portability.
Description
Individuals have the right to obtain and reuse their personal data, in a machine-readable format, for their own purposes across different services, in certain circumstances.
Rights
Right to object.
Description
Individuals have the right to object to the processing of their personal data, in certain circumstances.
Where we are using your personal data because it is in our legitimate interests to do so, you can object to us using it this way.
Where we are using your personal data for direct marketing, including profiling for direct marketing purposes, you have an absolute right to ask us to stop doing so.
Rights
Rights with respect to automated decision-making and profiling.
Description
Individuals have the right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.
In addition to the above, an individual also has the following rights:
Rights
Right to withdraw consent (if applicable)
Description
Where we are using your personal data based on your consent, you can withdraw your consent at any time.
Rights
Right to lodge a complaint with a supervisory authority.
Description
You have the right to raise a complaint about how we handle your personal information with the Information Commissioner’s Office.
Exercising your data protection rights
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 for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances
Contact us
If you would like to exercise your statutory data protection rights, or if you have any concerns or questions about how we handle personal data, please contact us using the details below:
Brand 22 Ltd
5 St John’s Lane
London
EC1M 4BH
Our telephone number is +44 (0)20 3093 0611
Alternatively, you can email us at privacy@brandtwentytwo.com
Raising a complaint with the UK data protection supervisory authority
If you believe that you have exhausted all possible avenues of resolving your data protection concerns with us, you may lodge a complaint with the Information Commissioner’s Office.
The ICO Helpline and can answer your data protection enquiries on: 0303 123 1113.
You can also send your postal correspondence to:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Alternatively, you can contact them at https://ico.org.uk/make-a-complaint/.