It’s the Flash Pack Ltd (“The Flash Pack”, “we”, ”us”, “our”) respects your privacy and is fully committed towards protecting the privacy of our clients, website visitors and participants in our content capture experiences.
Our business is to carry out photo/video (content capture) experiences on behalf of our clients. Our services include content capture, post production and social media sharing services ranging from short term to permanent installations.
If you are a participant in our content capture experiences, further details about how we process your data are available in this policy. This policy should be read together with the notices highlighting the uses we, and our clients wish to make of your personal data together with the ability to opt in or out of selected uses which may also be provided when we collect personal data from you as part of the content capture experience.
In the delivery of our services we also process personal data relating to our clients, and website users. Further information of how we process their personal data is also available here.
1. Who is responsible for the handling of your personal data?
2. Information we may collect about you
3. Why we process your personal data
4. Where the personal data comes from
5. Sharing your personal data
6. International transfers
7. Data security
8. How long do we keep your personal data?
9. Your rights
10. Our contact details
Our services are not intended for children and we do not knowingly collect data relating to children.
1. WHO IS RESPONSIBLE FOR THE HANDLING OF YOUR PERSONAL DATA?
Participants in our content capture experiences
When you participate in our content capture experiences you will be told who is responsible for the personal data you provided. This will clearly identify our client and whether (a.) use of your photo or video content is limited to sharing this content with you; or (b.) whether the content together with the personal data you have provided to us is passed on to our client to be processed in accordance with their privacy policies as part of their provision of the content capture experience to you. If you have consented to your content being used for promotional purposes on our website or social media channels, we may also include your content, together with other content from the installation in promotional case studies. The Flash Pack will be the controller in respect of any content featured on its website or social media channels.
a) Where your photo or video content is only shared with you:
We will be the data controller of personal data you provide when participating in the content capture experience. This means we will be responsible for safeguarding your personal data which will be processed in accordance with this policy. This policy only covers instances where we are a data controller.
b)Where your photo or video content, and personal data is shared with our client:
If you have consented to your content being used for promotional purposes, your content may also be included in case studies on The Flash Pack website and social media channels. The Flash Pack will be an independent controller in respect of any content featured on its website or social media channels, notwithstanding its general role as a data processor in the delivery of the content capture experience on the behalf of our clients.
Clients and website users
The Flash Pack is the controller of personal data you provide in connection with your interactions with us, or use of our services as a client or website user.
2. INFORMATION WE MAY COLLECT ABOUT YOU
We may collect, use, store and transfer different kinds of personal data about you. We have grouped together the categories of personal data we collect as follows:
a) Information you provide to us ► personal data you provide to us, such as when participating in our content capture experiences you will provide your photo or video content and your email address. If you are a client or potential client of ours, you may provide your name, business email address, and other contact details such as a telephone number and business address to us.
b) Our correspondence ► if you contact us, we will typically keep a record of that correspondence;
c) Your marketing preferences ► if you have consented to us sending you marketing communications about our services
d) Information about how you use our services ► such as information about the amount of time you use our website or products/services for. This may include the pages and screens you visit, and any options you select. We collect this information in order to provide feedback about the performance of our website and our services;
e) Website usage and device information ► if you use our website we will typically collect certain technical data including your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other details about the devices you use to access this website.
f) Information relating to our business relationship ► we will also collect information relevant to our business relationship with our clients, including details about payments made by or to you, or products and services you have bought from us.
3. WHY WE PROCESS YOUR PERSONAL DATA
We set out below the purposes for which we use the personal data that we collect about you, with the legal basis that we rely upon for its use.
The “legal bases” are set out in data protection laws: they allow companies to process personal data only when the processing is permitted by the specific “legal basis” set out in law. These grounds include:
• Consent: where you have consented to our use of your information.
• Contract performance: where your information is necessary to enter into or perform our contract with you.
• Legal obligation: where we need to use your information to comply with our legal obligations.
• Legitimate interests: where we use your information to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights.
• Legal claims: where your information is necessary for us to defend, prosecute or make a claim against you, us or a third party.
a) To provide photo and video content to participants ► As detailed in section 1 (Who is responsible for the handling of your personal data) above, where we are engaged by our clients to deliver photo or video content capture services to you, and that content is only shared with your email address then we are responsible for the processing of your personal data. In which case we process your personal data in order to make available and to deliver content capture experiences such as photobooths to you. Your content may also be included in our promotional case studies (see (c.) below) where you have provided consent to us for that use. Your name and email address will not be used for any additional purposes.
Use Justification: With your consent. When you choose to participate in the content capture experiences at our clients’ premises or at their events, you will be asked to confirm your consent to us processing your personal data. This is entirely voluntary.
b) To provide and manage products and services to our clients ► to administer our services to our clients, including to carry out our obligations arising from any agreements entered into with our clients, or to notify our clients about changes to our services.
Use justification: contract performance, legitimate interests (to enable us to perform our obligations and provide our services to our clients, or to notify our clients about changes to our service).
c) To create promotional case studies ► As detailed in section 1 (Who is responsible for the handling of your personal data) above, we may feature photo and video content from our installations on our website and social media pages.
Use justification: With your consent. When you choose to participate in the content capture experiences at our clients’ premises or at their events, you will be asked to confirm your consent to our use of your personal data in our promotional case studies. This is entirely voluntary.
d) To communicate with existing or prospective clients regarding products and services that may be of interest ► to provide existing or prospective clients with updates and offers, where they have chosen to receive these communications. Where required by law, we will ask for consent at the time we collect the data to conduct any of these types of marketing. You will always have the option to unsubscribe or opt-out of further communication in any electronic marketing communication sent to recipients.
Use justifications: legitimate interests (to keep existing and prospective corporate subscribers updated with news in relation to our products and services); consent (for individual recipients (including sole traders and partners) on the basis of their prior opt in consent to receive such communications.
e) To inform clients of changes about our services.
Use justifications: legitimate interests (to notify clients about changes to our services.)
f) To reorganise or make changes to our business► in the event that we: (i) are subject to negotiations for the sale of our business; (ii) are sold to a third party; or (iii) undergo a re-organisation, we may need to transfer some or all of your personal data to the relevant third party (or its advisors) as part of any due diligence process for the purpose of analysing any proposed sale or re-organisation. We may also need to transfer your personal data to that re-organised entity or third party after the sale or reorganisation for them to use for the same purposes as set out in this policy.
Use justifications: legitimate interests (in order to allow us to change our business).
g) In connection with legal or regulatory obligations ► We may process your personal data to comply with our regulatory requirements or communications with regulators which may include disclosing your personal data to third parties, the court service and/or regulators or law enforcement agencies in connection with enquiries, proceedings or investigations by such parties anywhere in the world or where compelled to do so.
Use justifications: legal obligations, legal claims, legitimate interests (to cooperate with law enforcement and regulatory authorities).
Where we rely upon consent for the processing of your personal data, you may withdraw your consent at any time. The withdrawal will not affect the lawfulness of the processing based on consent before the withdrawal.
We strive to provide our clients with choices regarding certain personal data uses, particularly around marketing and advertising. The Flash Pack will not send any marketing communications to you, unless we have received the individual’s express permission in advance.
The itstheflashpack.com website may, from time to time, offers its users e-mail subscriptions to fact sheets or newsletters. Any such communications will always follow an `opt-in` policy whereby they will not be sent to you unless you have given us explicit written permission in advance to email you concerning the specific subject you opted in for.
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 which is compatible with the purpose for which we originally collected it. 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.
4. WHERE THE PERSONAL DATA COMES FROM
Content capture participants
As you participate in our content capture experience, we will automatically collect your personal data and your video or photo content to facilitate our delivery of the content to you.
Clients will be required to share business contact details as part of our on-boarding process, this data shall remain within our possession for the duration of the contract.
As you interact with our website, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies.
We may share your personal data with the parties set out below for the purposes set out in X (Why we process your personal data):
5. SHARING YOUR PERSONAL DATA
Where the content capture experience is available simply to provide you with a content capture experience, then we will be responsible for the processing of your data and which will not be shared with our clients.
a) Third parties:
• Service providers (acting as processors) including:
i. our UK based provider of installation management and monitoring services; and
ii. our US based provider of email content delivery services.
• Our professional advisers, including lawyers, accountants, auditors, bankers, insurers, who provide legal, accountancy, audit, banking, insurance or consultancy, or other services to us;
• HM Revenue & Customs, regulators and other authorities who require us to report on processing activities in certain circumstances;
Where we are able to do so, we require all third parties to respect the security of your personal data and to treat it in accordance with the law. We only disclose the personal data each third party needs in order to provide the specified purposes, and we do not allow any of 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 the third parties with whom we work are based outside both the United Kingdom and the European Union, so their processing of your personal data will involve a transfer of this data outside the United Kingdom or the European Union. The countries to which your personal data may be transferred are set out in section 5 (Sharing your personal data).
When we transfer data, we take appropriate steps to ensure UK and EU data protection law is complied with. We will not transfer your personal data to any country (other than the United Kingdom) which is outside the European Union, except:
a) to a country which has been found by the European Commission to provide an adequate level of protection for personal data;
b) to an entity in the United States which is part of the EU-US Privacy Shield which requires it to provide similar protection to personal data shared between the European Union and the United States;
c) where we have ensured your personal data benefits from a similar degree of protection by using clauses approved by the European Commission which give personal data the same protection it has in the European Union.
Please contact us if you want further information on the specific mechanism we use when transferring your personal data out of the United Kingdom and the European Union.
7. DATA SECURITY
To prevent unauthorised access, maintain data accuracy and ensure the correct use of information, we have put in place appropriate physical, electronic and managerial procedures designed to safeguard and secure the information we collect.
8. HOW LONG DO WE KEEP YOUR PERSONAL DATA?
Where we have collected your personal data as part of a content capture experience, we will only retain this data for 6 months.
9. YOUR RIGHTS
You have rights (with some exceptions and restrictions) to:
• object to our processing of your personal data, including profiling. You can object, on grounds relating to your particular situation, at any time. In which case, we shall stop processing the data that your objection relates to, unless we can show compelling legitimate grounds to continue that processing;
• access your personal data. If you make this kind of request and we hold personal data about you, we are required to provide you with information on it, including a description and copy of the personal data and why we are processing it;
• request that we provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format;
• request erasure of your personal data in certain circumstances;
• request correction or updating of the personal data that we hold about you and that is inaccurate;
• request the restriction of our processing of your personal data in some situations. If you request this, we can continue to store your personal data but are restricted from processing it while the restriction is in place;
• complain to your local data protection authority about our collection or use of your personal data. For example, in the UK, the local data protection authority is the UK Information Commissioner’s Office.
If you choose to exercise the rights described above, we may ask you to provide additional information so that we can satisfy ourselves as to your identity before we take further action.
If you would like to exercise any of these rights in relation to any information that we hold about you, please contact us. Our contact details can be found in section 10 of this Notice. We will consider and respond to your request in accordance with the relevant law.
10. OUR CONTACT DETAILS
Its the Flash Pack Ltd
Studio B01 Parkhall
40 Martell Road
London, SE21 8EN
CHANGES TO THIS NOTICE