Privacy Policy for Courageous Creatures
Last Updated: [Date]
1. Introduction Welcome to https://courageous-creatures.co.uk/ (“Site”), owned and operated by Brandspire Digital Limited. This privacy policy outlines how we collect, use, maintain, and disclose information collected from users (each, a “User”) of the Site. By using our Site, you agree to the collection and use of information in accordance with this policy.
2. Information Collection and Use We collect several different types of information for various purposes to provide and improve our service to you, including but not limited to:
- Personal Identification Information: We may collect personal identification information from Users in various ways, including when Users visit our site, register, place an order, fill out a form, or in connection with other activities, services, features, or resources we make available on our Site. Users may be asked for, as appropriate, name, email address, mailing address, phone number, and credit card information.
- Non-personal Identification Information: We may collect non-personal identification information about Users whenever they interact with our Site. This may include the browser name, the type of computer, and technical information about Users’ means of connection to our Site, such as the operating system and the Internet service providers utilised.
3. Web Browser Cookies Our Site may use “cookies” to enhance the User experience. Users’ web browsers place cookies on their hard drives for record-keeping purposes and sometimes to track information about them. Users may choose to set their web browser to refuse cookies, or to alert them when cookies are being sent. Please note that doing so may affect the functionality of the Site.
4. How We Use Collected Information Brandspire Digital Limited may collect and use Users’ personal information for the following purposes:
- To process payments
- To send periodic emails
- To personalise the user experience
- To improve our Site
- To run a promotion, contest, survey, or other Site feature
5. How We Protect Your Information We adopt appropriate data collection, storage, and processing practices and security measures to protect against unauthorised access, alteration, disclosure, or destruction of your personal information, username, password, transaction information, and data stored on our Site.
6. Sharing Your Personal Information We do not sell, trade, or rent Users’ personal identification information to others. We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates, and advertisers for the purposes outlined above.
Who we share your personal information with
We routinely share personal information with:
- [companies within the Brandspire Digital Limited group]
- third parties we use to help deliver our to you, eg payment service providers, warehouses and delivery companies;
- other third parties we use to help us run our business, eg marketing agencies or website hosts;
- third parties approved by you, eg social media sites you choose to link your account to or third party payment providers;
- [credit reference agencies;]
- [our insurers and brokers;]
- our bank[s];
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g. in relation to ISO[ or Investors in People] accreditation and the audit of our accounts.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
[We will not share your personal information with any other third party.]
Where your personal information is held
Information may be held at our offices and those of our [group companies,] third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of the EEA’.
How long your personal information will be kept
We will keep your personal information while you have an account with us or we are providing
to you. Thereafter, we will keep your personal information for as long as is necessary:- to respond to any questions, complaints or claims made by you or on your behalf;
- to show that we treated you fairly;
- to keep records required by law.
Retention of your personal information We will not retain your personal information for longer than necessary for the purposes set out in this policy below. Different retention periods apply for different types of personal information.
[When it is no longer necessary to retain your personal information, we will delete or anonymise it.]
Transferring your personal information out of the EEA
To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:
- [with our offices outside the EEA;]
- with your and our service providers located outside the EEA;
- if you are based outside the EEA;
- [where there is an international dimension to the services we are providing to you.]
These transfers are subject to special rules under European and UK data protection laws.
[Countries to which we may transfer personal information are within the assessment by the European Commission as providing an adequate level of protection for personal information.]
[Except for the countries listed above, these OR These] non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission. To obtain a copy of those clauses go to https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en.
If you would like further information please contact [us OR our Data Protection Officer (see ‘How to contact us’ below).
You have the following rights, which you can exercise free of charge:
| Access | The right to be provided with a copy of your personal information (the right of access) |
| Rectification | The right to require us to correct any mistakes in your personal information |
| To be forgotten | The right to require us to delete your personal information – in certain situations |
| Restriction of processing | The right to require us to restrict processing of your personal information – in certain circumstances, e.g. if you contest the accuracy of the data |
| Data portability | The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party – in certain situations |
| To object | The right to object: at any time to your personal information being processed for direct marketing (including profiling);in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests. |
| Not to be subject to automated individual decision-making | 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 |
Withdraw consent You can withdraw your consent although this does not impact the processing up to the point of withdrawal.
For further information on each of those rights, including the circumstances in which they apply, please contact us – see below ‘How to contact us’.
If you would like to exercise any of those rights, please:
- email, call or write to us OR our Data Protection Officer] – see below: ‘How to contact us’; and
- let us have enough information to identify you [(e.g. your full name, address and customer or matter reference number)];
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
- let us know what right you want to exercise and the information to which your request relates.]
Keeping your personal information secure
We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. [We continually test our systems and are ISO 27001 certified, which means we follow top industry standards for information security.]
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
[If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.]
We hope that [we OR our Data Protection Officer] can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at: First Contact Team, Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF, https://ico.org.uk/concerns or telephone: 0303 123 1113.
Changes to this privacy policy
This privacy notice was published on December 1, 2023 and last updated on the same day.
We may change this privacy notice from time to time – when we do we will inform you via this page.
Please contact us [and/or our Data Protection Officer] by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.
Our contact details are shown below:
| Our contact details | [Our Data Protection Officer’s contact details] |
| FAO Data Protection hello@brandspire.co.uk | Same as on the right. |
[If you would like this notice in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).]