PRIVACY POLICY

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1. Introduction  

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At 20Ten Creative Limited (“20Ten”, “we”, “our”, or “us”) we are committed to protecting your privacy and are strongly committed to being responsible custodians of the information you provide to us and the information we collect in the course of operating our business.

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This Privacy Notice explains how we may collect, use, share and protect information that we obtain about you directly or indirectly in accordance with applicable data privacy laws.

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For the purpose of this Privacy Notice and Applicable Data Protection Legislation (including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679) and the Data Protection Act 2018), the relevant data controller responsible for your data is 20Ten.  

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If you need or want to get in touch with us, we have provided general contact details in the "How to Contact Us" section of this Privacy Notice.  

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If you are dissatisfied with any aspect of our Privacy Notice or how we have handled your personal data, you may submit a complaint to the Information Commissioners Office, details of which can be found at https://ico.org.uk/global/contact-us.

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2. When this Privacy Notice applies

 

This Privacy Notice applies:  

• to your use of any of our services where we are performing a data controller function;

• where you apply to us for a job or work placement;

• to your supply of services to us where this involves any personal data; and/or

• to any personal information collected from third parties where we are the controller of such information.

 

This Privacy Notice additionally applies to our website and online services, including www.20ten.co.uk, and any other website, mobile app or other online service created or hosted by us from time to time on which this Privacy Notice appears (together, our "online services") through which we may collect certain details if, for example, you want to subscribe to any publications or newsletters that we may periodically issue.

 

Please note that our online services make use of cookies and similar technologies, as described in more detail in section 10 (Cookies Policy) below.

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3. Information we collect about you

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"Personal data" is any information that can be used to identify you or that we can link to you.

 

Where you use our services, we will collect personal data directly from you. We collect information that you voluntarily provide to us, including when you communicate with us via email or other channels; when you sign up for or request that we send you newsletters, alerts, or other materials; when you sign up for a webinar or event; and when you respond to our communications or requests for information.

 

The information you provide may include current and historical personal data including your name, contact details, title, identification, employment, positions held and enquiry/complaint details and information about the organisation with which you are affiliated. We may also collect personal data about your other dealings with us and our clients, including any contact we have with you in person, by telephone, email or online.

 

We may also collect personal data from third parties such as your employing organisation, regulatory authorities, recruitment agencies, credit reporting agencies, information or service providers, publicly available records, and the third parties described in section 6 (sharing your personal data with third parties) below. 

 

We may collect information from other sources, such as social media platforms that share information about how you interact with our social media content, and any information gathered through these channels will be governed by the privacy settings, policies, and/or procedures of the applicable social media platform, which we strongly encourage you to review. This Privacy Notice does not apply to, and 20Ten Creative is not responsible for, any third-party websites.

 

If you apply for a job or work placement with 20Ten then you may need to provide information about your education, employment, racial background and state of health. As part of your application, you will be asked to provide your express consent to our use of this information to assess your application and to allow us to carry out both recruitment analytics and any monitoring activities which may be required of us under applicable law as an employer. We may also carry out screening checks (including reference, background, directorship, financial probity, identity, eligibility to work, vocational suitability and criminal record checks) and consider you for other positions.

 

We may exchange your personal data with academic institutions, recruiters, screening check providers, health service providers, professional and trade associations, law enforcement agencies, recruitment analytics providers, referees and your current and previous employers. We may also gather additional information about you from publicly available resources such as LinkedIn or other social or professional media platforms and collate this with the information that you provide to us. Without your personal data, we may not be able to progress considering you for positions with us.

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4. Why we collect your Personal data

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We collect, use and disclose your personal data for a number of reasons, including:  

to provide you with 20Ten’s services that you or your employing organisation request;  

to maintain and develop our relationship with you;

to help us to improve our services, products or online services;

to ensure that we can provide support and respond to any queries and contact you if you request us to do so;  

to contact the winner of any competition which we control;  

to facilitate our internal business operations, including to fulfil our legal or regulatory requirements and to detect or prevent fraud or illegal activities;

to maintain and update our records including our database of contacts;

for research, planning, service development, security or risk management

to evaluate, recruit, and hire personnel; or  

for other reasons with your consent.  

  

We may not be able to do some or all of these things without your personal data.

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If at any time we intend to change the purpose for which we hold your personal data, for example to offer you with a complimentary service that we may provide in the future, we will give you prior information of that new purpose so you are aware of this.

  

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5. Legal basis for usage of your personal data  

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Where we intend to use your personal data, we rely on the following legal grounds:   

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Where using your data is in our legitimate interests: We are allowed to use your personal data where (a) it is non-detrimental to you, (b) within your reasonable expectations, and (c) necessary for our own or third party’s legitimate interests to do so, and those interests are not outweighed by any potential prejudice to you.  

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We believe that our use of your personal data is within a number of our legitimate interests, including but not limited to:  

• to facilitate our organisation and running of competitions;  

• to direct market and advertise 20Ten Creative products and services;  

• to the prevention of fraud and to help us establish, exercise and defend legal claims; 

• for our internal administrative purposes;

• the personalisation of the service(s) we provide to you;

• ensuring network and information security, including preventing unauthorised access to electronic communications networks and stopping damage to computer and electronic communication systems; and

• reporting possible criminal acts or threats to public security to a competent authority.  

 

Performance of a Contract: Where using your personal data is necessary for us to carry out our obligations under our contract with you and in accordance with our terms and conditions.

 

Compliance with a legal obligation: We may be required to process your personal information due to legal requirements including employment laws, tax laws and other regulatory provisions applicable to 20Ten.

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Consent: We are allowed to use your data where you have specifically consented in connection with certain services that we offer. Where we are reliant upon your consent, you may withdraw this at any time by contacting us, however, please note that we will no longer be able to provide you with the services that rely on having your consent.

 

We will seek your explicit consent, where we wish to use your name and image in our publicity materials. For example, we will ask for consent when featuring the winners of competitions in any advertising for future competitions. If we require your consent for anything in the future, we will provide you with sufficient information so that you can decide whether or not you wish to consent.  

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6. Sharing your personal data with third parties

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We may share your information with third-party service provides contracted with 20Ten where any of the following apply:

• You have consented to us sharing your personal data in this way.

• We deem it reasonably necessary to provide you with the services that you have required at any particular time.

• Such sharing is provided for under contract, including our terms and conditions for any particular service that we may provide to you.

• Such sharing is to law enforcement bodies or other government authority.

• We need to enforce or apply our terms and conditions to which you have agreed (or other terms that have been agreed to apply to our relationship with you or your employing organisation).

• It is necessary to protect the rights and interests, property, or safety of 20Ten, our clients or others.

• It is relevant in the circumstances to disclose the information to parties with whom we have co-promotional arrangements (such as jointly sponsored events, external venues, or caterers).

• Our agents or contractors who assist us in providing our services require such information, for example in fulfilling requests for information, receiving and sending communications, updating marketing lists, analysing data, providing support services or in other tasks from time to time. Our agents and contractors will only use your information to the extent necessary to perform their functions.

• We use third party service providers to provide services that involve data processing, for example archival, web-hosting, analytics providers in connection with the operation of our online services, event hosting, information technology providers, auditing, reference checking, professional advisory (including legal, accounting, financial and business consulting), mailing vendor, delivery, technology, website, research, banking, payment, client contact, data processing, insurance, forensic, litigation support, marketing and security services.

• If a 20Ten Creative entity merges with or is acquired by another business or company in the future, we may share your personal data with the new owners of the business or company. In addition, circumstances may arise where, whether for strategic or other business reasons, 20Ten Creative decides to sell, buy, merge or otherwise reorganise businesses in some countries. Such a transaction may involve the disclosure of your personal information to prospective or actual purchasers, or the receipt of it from sellers. It is 20Ten Creative’s practice to seek appropriate protection for personal information in these types of transactions.  

• We are under a legal, regulatory or professional obligation to do so (for example, in order to comply with a Court Order).

 

Any third parties that we may share your personal data with are obliged to keep your details securely, and to use them only to fulfil the service they provide us. When such third parties no longer need your personal data to fulfil this service, they will dispose of such details in line with our procedures unless they are themselves under a legal obligation to retain information (provided that this will be in accordance with Applicable Data Protection Legislation).

 

We also provide anonymous statistical information about users of our websites and related usage information to reputable third parties, including analytics and search engine providers.

We own the database rights in the information collected via our online services. We do not sell, rent, or otherwise share information that reasonably identifies you or your organisation with unaffiliated entities for their independent use except as expressly described in this Privacy Notice or with your express prior permission.

 

We may disclose your data to an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger, acquisition, restructuring or insolvency of any part of our business, provided that we inform any recipient that it must use your personal information only for the purposes disclosed in this Privacy Notice.

 

We may share information that does not reasonably identify you or your organisation as permitted by applicable law.

 

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7. How we safeguard your personal data  

 

We care about protecting your information. That is why we put in place appropriate measures that are designed to prevent unauthorised access to, and misuse of, your personal data. We are committed to taking all reasonable and appropriate steps to protect the personal data that we hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures, including encryption measures and disaster recovery plans.  

 

All employees, officers or contractors of 20Ten Creative and third-party providers with access to confidential information are subject to access controls and confidentiality obligations, and we require our third-party data storage providers to comply with appropriate information security industry standards.

 

Unfortunately, there is always risk involved in sending information through any channel over the internet. You send information over the internet entirely at your own risk. Although we take reasonable steps to ensure the security of your personal information and we will continually strive to protect your personal data, we cannot guarantee the security of your data transmitted over the internet and we do not warrant the security of any information, including personal data, which you transmit to us over the internet.  

 

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8. International transfers  

 

Where you are submitting personal data from within the UK or European Economic Area (“EEA”), such information may be transferred to countries outside the EEA. By way of example, this may happen if one or more of our third-party service providers with whom we share personal data in accordance with section 5 (Sharing your personal data with third parties) are located, or have their servers located, outside your country or the country from which the data were provided.

 

If we transfer your information outside the EEA in this way, we will take steps to ensure that your privacy rights continue to be protected.

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9. How long we store your personal data  

 

We retain the information we collect for no longer than is reasonably necessary to fulfil the purposes that such data was originally collected in accordance with our internal data retention polices or to comply with our legal and regulatory obligations.

 

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10. Cookies Policy

 

Our website and services delivered online use cookies and other similar technologies, for example, to distinguish you from other users when you browse our website(s) or use our online services and to allow us to improve our online services.

 

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently to improve the user experience, as well as to provide certain information to the owners of the site.

 

We may, for example, collect information about the type of device you use to access our online services, the operating system and version, your IP address, your general geographic location as indicated by your IP address, your browser type, the content you view and features you access on our online services, the web pages you view immediately before and after you access our online services, whether and how you interact with content available on our online services, and the search terms you enter on our online services.

 

20Ten’s website sets cookies which remain on your computer for differing times. Some expire at the end of each session, and some remain for longer so that when you return to our website, you will have a better user experience.

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Which cookies we use

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Detailed below are the cookies we use and why and how long they last.

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__utma

2 years from set/update

Used to distinguish users and sessions. The cookie is created when the javascript library executes and no existing __utma cookies exists. The cookie is updated every time data is sent to Google Analytics.

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__utmt

10 minutes

Used to throttle request rate.

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__utmb

30 mins from set/update

Used to determine new sessions/visits. The cookie is created when the javascript library executes and no existing __utmb cookies exists. The cookie is updated every time data is sent to Google Analytics.

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__utmc

End of browser session

Not used in ga.js. Set for interoperability with urchin.js. Historically, this cookie operated in conjunction with the __utmb cookie to determine whether the user was in a new session/visit.

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__utmz

6 months from set/update

Stores the traffic source or campaign that explains how the user reached your site. The cookie is created when the javascript library executes and is updated every time data is sent to Google Analytics.

 

We collect standard internet log information and details of visitor behaviour patterns by using Google Analytics cookies. We do this to compile reports and to help us find out things such as the number of visitors to the various parts of our website, so that this can be improved. This information does not identify visitors or collect any personal details. We do not make any attempt to find out the identities of those visiting our websites. We will not associate any data gathered in this way with any personal data from any source. For more information about Google Analytics cookies please see the link here.

 

To provide website visitors with more choice on how their data is collected by Google Analytics, Google have developed the Google Analytics Opt-out Browser Add-on. The add-on communicates with the Google Analytics JavaScript (ga.js) to indicate that information about the website visit should not be sent to Google Analytics. The Google Analytics Opt-out Browser Add-on does not prevent information from being sent to the website itself or to other web analytics services. For more information about Google Analytics Opt-out Brower Add-on please see the link here.

 

 

 

Control of cookies

 

Web browsers allow you to exercise some control of cookies through the browser settings. Most browsers enable you to block cookies or to block cookies from particular sites. Browsers can also help you to delete cookies when you close your browser. You should note however, that this may mean that any opt-outs or preferences you set on our website will be lost. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org which includes information on how to manage your settings for the major browser providers.

 

 

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11. Online Services – Links to third party sites, services and content

 

In addition to our online services, which we control directly, we also use and provide links to websites which are controlled by third parties, which may include:

• Twitter, LinkedIn and YouTube, where we have certain 20Ten accounts and profiles.

• Facebook, Instagram and where we have a social page.

 

If you use or follow a link to any of these third-party websites, please be aware that these websites have their own privacy policies and that we cannot accept any responsibility for their use of information about you.

 

Our online services may include integrated content or links to content provided by third parties (such as video materials). This Privacy Notice does not address the privacy, security, or other practices of the third parties that provide such content.

 

We engage third parties that support the operation of our online services, such as analytics providers. These third parties may use technologies to track your online activities over time and across different websites and online platforms. Please see section 10 (Cookies Policy) above for more information.

 

 

 

12. Your Rights

 

Under Applicable Data Protection Legislation, we have a duty of care to ensure that your personal data is accurate and up to date. Therefore, please contact us to update or correct your information if this changes or if you believe that any information that we have collected about you is inaccurate.

 

You have various rights in relation to the data which we hold about you. We have set these out below. You can request:

• access to the personal data we hold about you

• corrections or updates to your details;

• the erasure of your personal data;

• the portability of personal data that you have provided to us in a structured, commonly used and machine-readable format.

 

You also have the right to object to, or request the restriction of, our use of your personal data.

 

Where we have obtained your consent to process your personal data for certain activities, you may withdraw this consent at any time and we will cease to use your data for that purpose unless we consider that there is an alternative legal basis to justify our continued processing of your data for this purpose, in which case we will inform you of this condition.  

 

You may ask us for a copy of the information we hold about you at any time, and request us to modify, update or delete such information. We shall respond to your request within one month, but this period may be extended by two further months where necessary. We may request proof of identification to verify your request. If we provide you with access to the information, we hold about you, we will not charge you for this unless permitted by law. If you request further copies of this information from us, we may charge you a reasonable administrative cost. Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will always tell you the reasons for doing so.  

 

If you would like to exercise any of these rights or withdraw your consent to the processing of your personal data (where consent is our legal basis for processing your personal data), please contact us using the contact details set out at the end of this Privacy Notice. Please note that we may keep a record of your communications to help us resolve any issues which you raise.  

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13. Status of this Statement

 

Your provision of personal data to us or use of our online services constitutes your acceptance of the terms of this Privacy Notice.

 

As technologies and information governance practices develop, and data privacy laws (and surrounding guidance) evolve, we may need to revise this Privacy Notice. You should therefore review this page regularly to ensure that you are aware of any changes to its terms.

 

We will post any Privacy Notice changes on this page and, if the changes are significant or may materially impact upon your rights, we will provide a more prominent notice or contact you by other means (including, for certain services, email notification of Privacy Notice changes).

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14. How to contact us

 

If you have any queries about this Privacy Notice, including your rights in relation to your personal information, or if you wish to contact us with any general queries or concerns, please contact us via any of the following means:

 

Contact address:

FOURTH FLOOR

OLD STREET WORKS

197 CITY ROAD

LONDON

EC1V 1JN

 

Email: enquiries@20ten.co.uk

 

The Data Privacy Officer for 20Ten is Luke Fisher.

 

 

Date of last update: 29 June 2021  

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TERMS AND CONDITIONS

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20ten Creative Limited (20ten) retains all the copyright and other intellectual property rights contained within this document. All concepts, advice, and ideas remain the property of 20ten.

 

The contents of this document are of a confidential nature and are submitted to you on the understanding that they are to be considered by you in the strictest confidence and that no use shall be made of the advice, concepts and ideas including communication to a third party without written express prior consent from a director of 20ten and the agreement of fees and charges. Until such time as that consent has been given, any prospective or existing client shall not purchase title to any or all of the ideas, advice and concepts submitted by 20ten as part of any project that excludes 20ten as the prime supplier of these services. 

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