PRIVACY POLICY
Introduction
Welcome to We are Human’s (Registered as Human Centred Research Ltd) privacy policy.
We are Human processes all personal data collected in accordance with the UK General Data Protection Regulation (UK GDPR), tailored by the Data Protection Act 2018.
This privacy policy tells you what to expect when We are Human collects personal information.
The policy is structured into the following sections:
- Important information and who we are
- The data we collect about you
- How is your personal data collected?
- How we use your personal data?
- Disclosures of your personal data
- International transfers
- Data security
- Data retention
- Your legal rights
- Glossary
1. Important information and who we are
Purpose:
This privacy policy aims to give you information on how We are Human (referred to as we, us or our in this privacy policy), collects and processes your personal data when you email us; visit our website; use our services; apply for a job with us; are one of our suppliers; contact us via social media; take part in research on behalf of our client and subscribe to our marketing information
It is important that you read this privacy policy together with any other information you may be provided relating specifically to research studies you may choose to participant in, such that you are fully informed of how the data collected will be used.
Our site is not intended for children, and we do not knowingly collect data relating to children.
What is Personal Data?
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 has been removed (anonymous data).
Data Controller:
We are Human is the Data Controller for the personal information we collect, such as our employee information and business contact information. We are also the Data Controller where we decide which research participants to select and the methodology to be employed. When our client decides which research participants to select and the methodology to be employed, the client will be the Data Controller and We are Human will be the Processor. Where you take part in our research and We are Human are not the Data Controller, we will clearly inform you who the Data Controller for the Research is.
Information Commissioner’s Office:
We are registered with the ICO, and we are responsible for protecting this information in accordance with this policy.
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.
Contact details
If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:
Full name of legal entity: Human Centred Research Ltd
Email address: [email protected]
Postal address: The Yard, 1A Walter Street, Southville, Bristol, BS1 3WS
2. The data we collect about you
We may collect, use, store and transfer different kinds of personal data about you including:
Identity Data
Includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender. In relation to research that we undertake on behalf of our clients, this may also include photographs and video footage.
Contact Data
Includes billing address, delivery 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 and other details of services you have purchased from us.
Technical Data
Includes internet protocol (IP) address, your login data, 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 site.
Profile Data
Includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses. If you participate in any consumer research we undertake on behalf of our clients, details relevant to the research topic will be collected, including but not limited to details about your occupation, interests, socio-economic group, purchasing habits, usage and attitudes towards specific product categories, lifestyle, living arrangements, etc.
Usage Data
Includes information about how you use our site and services.
Marketing and Communications Data
Includes your preferences in receiving marketing from us and our third parties, and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. 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 policy.
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), unless you participate in any consumer research we undertake on behalf of our clients, in which case we may gather special categories of data about you as part of that research if it is relevant to the topic we are researching.
We do not collect any information about criminal convictions and offences. However, if you apply for a job with us, this information may be required to enable us to assess your job application and complete our recruitment process, and we will tell you at the relevant time if this is the case.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions
You may give us your Identity, Contact, Financial and Profile Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- email us;
- visit our website
- use our services
- apply for a job with us
- are one of our suppliers
- contact us via social media
- take part in research studies
- subscribe to our marketing information
Automated technologies or interactions
As you interact with our site, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.
Third parties or publicly available sources
We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
- analytics providers such as Google based outside the EU;
- advertising networks such as Google AdWords based outside the EU; and
- search information providers such as internet search engines, which may be based inside or outside the EU, depending on which one is used.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Starling Bank or Tide bank based inside the EU.
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based in the UK.
- Identity, Contact, Financial and Special Category Data from a recruitment or employment agency if you apply for a job with us using the services of a third-party agency.
- Identity, Contact, Profile and Special Category Data from a market research recruitment agency if you are taking part in consumer research which is organised by a third-party agency.
4. How 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:
- Where we need to perform the contract, we are about to enter into or have entered into with you (for example, when you engage us to provide services or apply for a job with us).
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
See LAWFUL BASIS to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
Table 1 below outlines the various ways we plan to use your personal data, which of the legal bases we rely on to do so and what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
Table 1: Purposes for which we will use your personal data
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
| To register you as a new client or supplier | (a) Identity (b) Contact | Performance of a contract with you |
To process and deliver your requirement for services including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us | (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how clients use our services) |
| To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical | (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical | Necessary for our legitimate interests (to study how clients use our services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve and monitor our site, services, marketing, client relationships and experiences | (a) Technical (b) Usage | Necessary for our legitimate interests (to define types of clients for our services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about goods or services that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications | Necessary for our legitimate interests (to develop our services and grow our business) |
| To process and decide about your application for employment | (a) Identity (b) Contact (c) Financial (d) Special Category Data | (a) Necessary for our legitimate interests (to recruit staff for our business). (b) Because you have asked us to do so. |
| To ensure you meet the recruitment criteria for a research session and the specific topic to be discussed | (a) Identity (b) Contact (c) Profile (d) Special Category Data | (a) Necessary for our legitimate interests (to conduct consumer research to help our clients identify and develop new products and services). (b) Because you have agreed to share data during the consumer research recruitment process. |
| During research to gather insights into a particular subject or category and understand consumer needs and behaviour | (a) Identity (b) Profile (c) Special Category Data | (a) Necessary for our legitimate interests (to conduct consumer research to help our clients identify and develop new products and services). (b) Because you have given us consent to use personal data in this way (informed consent document). |
Marketing
We will provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
Third party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us because of your purchasing services from us, or other transactions.
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 our site may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.
Change of purpose:
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. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the Table 1 above.
- External Third Parties as set out in the Glossary.
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
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 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.
6. International transfers
Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use providers or work with clients based in the USA, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us via our Contact details if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. 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 any applicable regulator of a breach where we are legally required to do so.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
By law we must keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being clients for tax and accounting purposes.
In the case of recruitment data, we will keep your information for 12 months after you submit an application for employment to us (whether you do this yourself, or through a recruitment or other third party agency). If your application for employment is successful, we will retain your information throughout your period of employment with us and thereafter, as set out in our privacy policy for employees, workers and contractors (which we will provide to you when you join us).
In the case of research data, personal information obtained during research recruitment (Identity, Contact and Profile Data), will be kept until the final project deliverables have been delivered to the client organisation (unless you have opted in to be contacted about future research projects). Personal information obtained during fieldwork (specifically: audio, photographs or video) will be kept for seven years after the end of the project.
In some circumstances you can ask us to delete your data: see Your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
- Request access to your personal data
- Request correction of your personal data
- Request erasure of your personal data
- Object to processing of your personal data
- Request restriction of processing your personal data
- Request the transfer of your personal data
- Withdraw consent at any time consent
If you wish to exercise any of the rights set out above, please contact us via our Contact details.
No fee usually required
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 could refuse to comply with your request in these circumstances.
What we may need from you
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.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.
10. Glossary
LAWFUL BASIS
Legitimate Interest
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.
Performance of Contract
means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering such a contract.
Comply with a legal obligation
means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
THIRD PARTIES
External Third Parties
- Service providers and sub-contractors acting as processors or joint controllers who provide consultancy services, IT and system administration services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide professional advice and assistance such as banking, legal, insurance and accounting services.
- HM Revenue & Customs, the Information Commissioner’s Office, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
- Market research agencies who provide consumer recruitment, translation, moderation, interpretation services and viewing facilities, based anywhere in the world.
- Client organizations who have commissioned research. Personal data may be shared with the client organisation for the purpose of communicating the findings of the research project only.
Your Legal Rights
You have the right to:
Request access
to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction
of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure
of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing
of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing
of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful, but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer
of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time
where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our site.
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