Privacy Policy
CONTENTS
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Introduction
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How We use personal data
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How we collect your personal data
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Who we share your personal data with
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International transfers of personal data
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Retaining and deleting personal data
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Your legal rights
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Amendments to this Policy
1. Introduction
We are committed to safeguarding the privacy and accuracy of the personal data of Our website visitors, service users and email recipients.
This policy applies where We are acting as a Data Controller with respect to the personal data of Our website visitors, service users, email recipients and personal data collected from public sources; in other words, where We determine the purposes and means of the processing of that personal data.
In this policy, “We”, “Us” and “Our” refer to Loft Films ltd of 12 Gt James, London WC1N 3DH – Registered in England & Wales, Company Number 8412347, ICO number ZB206233.
Reference to a Data Subject means a natural person whose personal data is processed by a Data Controller or a Data Processor, in other words, You.
2. How We use Your personal data
You can find out more about personal data from the Information Commissioners Office.
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Usage Data
We may process data about Your use of Our website and services (“Usage Data“). The Usage Data may include Your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of Your service use. The source of the Usage Data is Google Analytics as well as Our analytics tracking system. This Usage Data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is Our legitimate interests, namely monitoring and improving Our website and services, and tailoring any communication with You.
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Account Data
We may process Your Account Data (“Account Data“). The Account Data may include Your name and email address. The source of the Account Data is You or Your employer. The Account Data may be processed for the purposes of providing Our services, ensuring the security of Our website and services, maintaining back-ups of Our databases and communicating with You. The legal basis for this processing is the performance of a contract between You and Us and/or taking steps, at Your request, to enter into such a contract.
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Service Data
We may process Your personal data that are provided in the course of the use of Our services (“Service Data“). The Service Data may include name, email address and telephone number. The source of the Service Data is You or Your employer. The Service Data may be processed for the purposes of providing Our services and communicating with You. The legal basis for this processing is the performance of a contract between You and Us and/or taking steps, at Your request, to enter into such a contract.
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Enquiry Data
We may process information contained in any enquiry You submit to Us regarding goods and/or services (“Enquiry Data“). The Enquiry Data may be processed for the purposes of Us offering, marketing and selling relevant goods and/or services to You. The legal basis for this processing is consent which may be withdrawn by You at any time by contacting Us.
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Notification Data
We may process information that You provide to Us for the purpose of subscribing to Our email notifications and/or newsletters (“Notification Data“). The Notification Data may be processed for the purposes of sending You the relevant notifications and/or newsletters. The legal basis for this processing is consent which may be withdrawn by You at any time by contacting Us.
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Correspondence Data
We may process information contained in or relating to any communication that You send to Us (“Correspondence Data“). The Correspondence Data may include Your name, email address and the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The Correspondence Data may be processed for the purposes of communicating with You and record-keeping. The legal basis for this processing is Our legitimate interests, namely the proper administration of Our website and business and communications with users.
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Public Data
We may process information found on public social networking profiles (“Public Data“). This data may include name and job title. Public Data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to Your employer. The legal basis for this processing is Our legitimate interests, namely proper administration of Our business.
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Legal Claims Data
We may process any of Your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. (“Legal Claims Data”) The legal basis for this processing is Our legitimate interests, namely the protection and assertion of Our legal rights, Your legal rights and the legal rights of others.
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Professional Use Data
We may process any of Your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. (“Professional Use Data”). The legal basis for processing Legal Claims Data is Our legitimate interests, namely the proper protection of Our business against risks.
We may also process any of Your personal data where such processing is necessary for compliance with a legal obligation to which We are subject, or in order to protect Your vital interests or the vital interests of another natural person.
Please do not supply any other person’s personal data to Us unless We prompt You to do so.
3. How we collect your personal data
We use different methods to collect data from and about you including:
Directly
You may give us your [IDENTITY, CONTACT AND FINANCIAL DATA] by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
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Apply for our products or services;
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Subscribe to our service or publications;
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Request marketing to be sent to you.
Indirectly
With regard to each of your visits to our website www.loft-films.com we may automatically collect the following information We may use special technologies to passively collect information while you are visiting www.loft-films.com (that is, you do not actively provide this information). These technologies allow us to collect certain kinds of non-personally identifiable information, including your Internet domain name, the type of web browser you use, the operating system you use, the date and time of your visit to www.loft-films.com, the specific pages you visit, and the address of the web site you visited prior to entering www.loft-films.com. We do not link this passively collected, non-personally identifiable information with personally identifiable information you have actively provided elsewhere on this site. We reserve the right to share with third parties, including our business partners and advertisers, the anonymous aggregated information that we have passively collected via this site.
The primary means of passive information collection at our site are:
Cookies
This site uses cookies, which are small text files that store non-personally identifiable information about you, either temporarily in connection with your Internet Protocol (IP) address (known as a temporary or session cookie, and deleted once you close your browser window) or more permanently on the hard drive of your computer (known as a permanent or persistent cookie). This site uses session cookies so that you do not have to fill in the same information from page to page within www.loft-films.com. If you elect not to receive cookies, you may be able to view some, but not all, of the content on this site.
Internet Protocol (IP) Addresses
This site uses Internet protocol (IP) addresses. IP addresses are unique identifiers automatically assigned to each computer when logging onto the Internet. IP addresses allow us to collect much of the same information we collect through cookies, including browser type, what pages you visit, and how long you stay on the site. In general, IP addresses allow us to identify problems with our servers, prepare aggregate demographic information and other information regarding the use of this site, and improve the functions of this site.
Other sources. We may receive information from other sources about you. We work closely with third parties, including for example, business partners, subcontractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies, and may receive information about you from them.
4. Who we share your personal data with
We may have to share your personal data with the parties set out below for the purposes set out in section 3 above.
Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
Internal Third Parties - subcontractors and other freelance workers for the performance of any contract we enter into with them or you.
External Third Parties, Service Software as a Service Providers based with the EU who provide IT AND SYSTEM ADMINISTRATION SERVICES.
Professional advisers including lawyers, bankers, auditors and insurers who provide CONSULTANCY, BANKING, LEGAL, INSURANCE AND ACCOUNTING SERVICES.
HM Revenue & Customs, regulators and other authorities [WHO REQUIRE REPORTING OF PROCESSING ACTIVITIES IN CERTAIN CIRCUMSTANCES].
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 notice.
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.
5. International transfers of Your personal data
Your personal data may be transferred to countries outside the European Economic Area (“EEA”).
We have Partners and Collaborators with offices and facilities in several countries, both in and outside the EEA. Transfers to such countries will be protected by appropriate safeguards agreed with our partners.
You acknowledge that personal data that You submit for publication through Our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
Our Website contains links to external Websites run by other organisations. This privacy policy applies only to our Websites, not those external Websites that we link to, who will have their own privacy policies. We are not responsible for these external Websites and their privacy policies and practices. In addition, if you linked to our Website from an external site, we cannot be responsible for the privacy policies and practices of the owners and operators of that external Website and recommend that you check the privacy policy of that external site.
6. Retaining and deleting personal data
Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
Notwithstanding the other provisions of this Section, We may retain Your personal data where such retention is necessary for compliance with a legal obligation to which We are subject, or in order to protect Your vital interests or the vital interests of another natural person.
7. your legal rights
Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data:
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The right to request a copy of the personal data which we hold about you;
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The right to request that we correct any personal data if it is found to be inaccurate or out of date;
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The right to request your personal data is erased where it is no longer necessary to retain such data;
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The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data;
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The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), where applicable i.e. where our processing is based on consent or is necessary for the performance of our contract with you or where we process your data by automated means);
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The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
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The right to object to our processing of personal data, where applicable i.e. where processing is based on our legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct marketing or processing for the purposes of scientific/historical research and statistics).
If you wish to exercise any of the rights set out above, please contact the Data Protection Officer in the following ways:
Email - accounts@loft-films.com
Phone - +44 (0) 208 123 6731
Letter - 12 Gt James St, London WC1N 3 DH
8. Amendments to this policy
We may update this policy from time to time by publishing a new version on Our website.
You should check this page occasionally to ensure You are happy with any changes to this policy.
Our carefully selected partners and service providers may process personal information about you on our behalf as described below:
Digital Marketing Service Providers
We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information. Our appointed data processors include:
(i) Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: http://sopro.io. Sopro are registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at: dpo@sopro.io.
This policy was last updated on 01st January 2023