Sharp End Partnership Ltd., Devonshire House, 60 Goswell Road, London, United Kingdom, EC1M 7AD (referred to as the ‘Owner’)
Owner contact email: [email protected]
This Policy applies to the data processing by the Owner’s website and other instances where the Owner is the data controller, including the data of its website users, other Owner services’ users, contractors, and employees. It does not apply to the situations where the Owner is the data processor.
Among the types of Personal Data that our Website collects, by itself or through third parties, there are: first name, last name, email address, Cookies and Usage Data.
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. Where such countries include one or more countries outside the EU/EEA, the Owner will rely on an adequacy decision, including EU-US Privacy Shield, standard clauses, or another safeguard acceptable by the EU General Data Protection Regulation (GDPR).
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation e.g. in relation to payroll information, or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Contacting the User and Analytics. Additional purposes may be contained in the legitimate interests mentioned in this policy.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
Google Analytics (Google Inc.)
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behaviour based on cookies to which you consent based on our pop-up when you first visit our website.
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data collected: Cookies and Usage Data.
Lucky Orange Web Analytics Service
This site uses the Lucky Orange analytics system to help improve usability and the customer experience. Lucky Orange may record mouse clicks, mouse movements and scrolling activity. Lucky Orange does not track this activity on any site that does not use the Lucky Orange system. You can choose to disable the Lucky Orange Service at http://www.luckyorange.com/disable.php.
Contact form (this Website)
By filling in the contact form with their Data, the User authorizes this Website to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
Personal Data collected: email address, first name and last name.
Mailing list or newsletter (this Website)
By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this Website. Your email address might also be added to this list as a result of signing up to this Website or after making a purchase.
You can always opt-out of receiving email information by sending us an email to [email protected]
Personal Data collected: email address, first name and last name, plus your query.
Users may exercise certain rights regarding their Data processed by the Owner by emailing us to [email protected]
In particular, Users have the right to do the following under EU General Data Protection Regulation (GDPR) or relevant UK legislation :
How to exercise these rights
Apart from contact email mentioned above, any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of the Owner’s Services or other activities.
Additional information about User’s Personal Data
System logs and maintenance
For operation and maintenance purposes, the Owner may collect files that record interaction with the Owner’s services (System logs) use other Personal Data (such as the IP Address) for this purpose.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person. As defined by GDPR.
Information collected automatically through the Owner’s services (or third-party services employed in the Owner’s services), which can include: the IP addresses or domain names of the computers utilized by the Users who use the Owner’s services, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.
The individual using the Owner’s services who, unless otherwise specified, coincides with the Data Subject. References to the User may mutatis mutandis apply to other data subjects whose data is processed by the Owner.
The natural person to whom the Personal Data refers.
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Small sets of data stored in the User’s device. The definition may also include similar purpose technologies such as pixels.