Introduction
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.
Content with Purpose Limited (“we”, “us” or “our” in this privacy policy”) is the data controller and is responsible for certain personal data about you that we collect and use as a consequence of providing our services to the Association that you represent, or where we work with the Company that you represent or we collaborate with you directly as a Contributor to feature in our content, or where you use or browse our website as a User (capitalised terms are defined in the Key Terms table below).
We keep our privacy policy under regular review. This version was last updated on 31st May 2023.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
Key Terms
It would be helpful to start by explaining some key terms and references used in this policy:
| Association | The association or member-body with whom we partner to provide our production, Content and/or digital marketing services (and who is not a Company). |
| Company | Third party who pays us to provide our production, Content and/or digital marketing services. |
| Content | Digital content created by us. |
| Contributor | Individual featuring in our Content. |
| Data protection contact | Emilia Smith, General Counsel:emilia@contentwithpurpose.co.uk |
| Data subject | The individual who the personal data relates to, for the purposes of this policy can be representatives of an Association, a Company, Contributors or Users. |
| Personal data | Any information relating to an identified or identifiable individual |
| User | Individual user or browser of our website https://contentwithpurpose.co.uk/ |
| We, us, our | Content with Purpose Limited Whose registered address is: 11 Okeford Drive, Tring, HP23 4EQ. |
| You, your | Data subject who this policy applies to |
Personal data we collect about you
We may collect a variety of information about you depending on what the status of our relationship with you is. We have summarised the different kinds of personal data collected for each of the categories of Data Subject that this policy applies to:
- Representatives of Associations and prospects:
- Identity Data: includes full name and job title, details of relevant Association/organisation.
- Contact Data: includes business email address and telephone number and online presence.
- Profile Data: feedback, your contact history and your preferences in receiving promotional and informational communications from us.
- Financial Data: includes bank account information.
- Representatives of Companies and prospects:
- Identity Data: includes full name and job title, details of relevant Company.
- Contact Data: includes business email address and telephone number and online presence.
- Profile Data: feedback, your contact history and your preferences in receiving promotional and informational communications from us.
- Financial Data: includes bank account information.
- Contributors:
- Identity Data: includes full name and job title, details of employing organisation.
- Contact Data: includes email address and telephone number, online presence.
- Contributor Data: includes photos, video, recorded interviews, areas of expertise, biographies.
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). Nor do we collect any information about criminal convictions and offences.
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below. If you do not provide personal data we ask for, it may delay or prevent us from providing services to your organisation or engaging you or your organisation to provide services to us.
How your personal data is collected
We collect some of this personal data directly from you in person, by telephone, email and/or via our website. However, we may also collect information:
- from publicly accessible sources, eg Companies House, LinkedIn and other publicly accessible websites;
- from cookies on our website—for more information on our use of cookies, please see our Cookie Policy
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a lawful basis eg:
- for our legitimate interests or those of a third party.
- to comply with our legal and regulatory obligations; or
- for the performance of a contract with you or to take steps at your request before entering into a contract. or
A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.
The table below explains what we use your personal data for and why.
| What we use your personal data for | Lawful basis | Type of data |
|---|---|---|
| Providing services to the Association that you represent | For our legitimate interest, i.e. to carry out our services | Identity Contact Profile Financial |
| Providing services to the Company that you represent | For our legitimate interest, i.e. to provide our services | Identity Contact Profile Financial |
| Featuring you as a Contributor | To perform our contract with you or to take steps at your request before entering into a contract; For our legitimate interest, i.e. to provide our services | Identity Contact Contributor |
| Carrying out marketing of our services to the Association or Company that you represent | For our legitimate interest, i.e. to develop and grow our business | Identity Contact Profile |
| Preventing and detecting fraud against you or us | For our legitimate interest, ie to minimise fraud that could be damaging for you and/or us | Identity Contact Financial |
| To enforce legal rights or defend or undertake legal proceedings, or to provide information required relating to audits, enquiries or investigations by regulatory bodies. | To comply with our legal and regulatory obligations; For our legitimate interests, ie to protect our business, interests and rights | Identity Contact Profile Financial |
| Operational reasons, such as improving efficiency, training quality control and security of our website. | For our legitimate interests , ie to be as efficient as we can so we can deliver the best service to you at the best price | Identity Contact Technical Usage |
| Statistical analysis to help us manage our business | For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price | Technical Usage |
Marketing
We have a legitimate interest in using your personal data for marketing purposes (see table above). This means we do not usually need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by contacting us at info@contentwithpurpose.co.uk.
We will always treat your personal data with the utmost respect and never sell it to other organisations for marketing purposes.
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 this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.
Who we share your personal data with
We routinely share personal data with:
- third parties we use to help deliver our services, eg payment service providers and delivery companies;
- other third parties we use to help us run our business, eg marketing agencies or website hosts and IT and systems administrators;
- in some instances we will share Contributor’s Data with the relevant Association (when working with an Association) or the relevant Company (where the Content has been commissioned by that Company), so that they can endorse and approve the production of the specific Content;
- our bank.
We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.
We or the third parties mentioned above occasionally also share personal data with:
- our external auditors, eg in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations;
- our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;
- law enforcement agencies, courts, tribunals and regulatory bodies such as HMRC, to comply with our legal and regulatory obligations;
- other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.
Where your personal data is held
Personal data may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above.
Some of these third parties may be based outside the UK. For more information, including on how we safeguard your personal data when this happens, see below.
How long your personal data will be kept
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.
Please contact us if you want further information about how long we will retain your personal data.
Transferring your personal data out of the UK
It is sometimes necessary for us to transfer your personal data to countries outside the UK. In those cases we will comply with applicable UK laws designed to ensure the privacy of your personal data.
Whenever we transfer your personal data out of the UK, 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; or
- Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
Your rights
You have the following rights, which you can exercise free of charge:
| Access | The right to be provided with a copy of your personal data |
| Rectification | The right to require us to correct any mistakes in your personal data |
| Erasure (also known as the right to be forgotten) | The right to require us to delete your personal data—in certain situations |
| Restriction of processing | The right to require us to restrict processing of your personal data in certain circumstances, eg if you contest the accuracy of the data |
| Data portability | The right to receive the personal data 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 data being processed for direct marketing (including profiling);—in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims |
| 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 |
| The right to withdraw consents | If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any timeWithdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn |
For more information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below) or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights.
How to contact us if you would like to exercise any of those rights, please:
- Email: info@contentwithpurpose.co.uk;
- provide enough information to identify yourself and any additional identity information we may reasonably request from you; and
- let us know what right you want to exercise and the information to which your request relates.
How to complain
Please contact us if you have any queries or concerns about our use of your personal data. We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with the Information Commissioner, who may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.