Bolt Digital (the “Company”, “We”, “Us” or “Our”) is committed to protecting and respecting Your privacy. This Privacy Notice is provided for Our prospective, existing and former customers (“You”, “Your”).
This Privacy Notice together with Our Cookie Notice published on Our Website tells You about how We process Your personal data, including Our collection, usage and sharing of Your personal data, and including in relation to Your use of Our websites at www.natashacourtenaysmith.com AND www.stevebolton.com AND www.boltdigital.media all of which are owned and hosted by Bolt Digital.
We will only process Your personal data in accordance with the Notices (and any other information We give to You about how We process Your personal data), and in accordance with the Data Protection Legislation.
In this Privacy Notice the terms “personal data”, “Data Controller”, “Data Processor” each have a special meaning that is set by legislation (the “Data Protection Legislation”). The Data Protection Legislation is: from the date it comes into force in the United Kingdom, the EU General Data Protection Regulation (2016/679) and, until such date, the Data Protection Act 1998.
Your Data Controller
The Company is a Data Controller in relation to Your personal data.
Our address is Unit 7, The Tay Building, 2A Wrentham Ave, London NW10 3HA. The Company may be contacted by email at email@example.com
Information We collect about You
We obtain Your personal data from the following sources:
- Directly from You
You will know what personal data We obtain from You, because You (or someone who You trust, and who You have authorised Us to deal with, such as a member of Your family) provide it to Us. Examples of how We obtain personal data from You include: when You make an enquiry (such as submitting an enquiry form to us), when You give Us information via email, during a telephone conversation with Us, during face-to-face discussions with Us, information You provide via Our Website, via social networking messages, or if You report something to Us such as a problem with Our Website, or when You send a completed order form to Us.
- From marketing sources
We love to receive new customers as a result of recommendations from Our existing customers, and We also actively seek new customers via marketing. We obtain Contact Details about prospective new customers, and enquiries from prospective and existing customers, from:
- Your responses to Our online marketing or direct marketing to You, whether You respond by electronic mail, telephone, post, social media or other means;
- Your interactions with Our online advertising and advertisements placed by Our digital media and marketing service provider(s).
- From Our other service providers
We receive personal data about You from the following third parties who provide services to Us.
- our bank or providers who process payments from You, to confirm the outcome of payment transactions;
- data supplied by third party suppliers who may refer on enquiries to us.
To help Us decide what marketing to provide to You, we obtain information from some social media providers, and particularly Facebook, about group(s) that You belong to within that social network. The information We receive is about the group(s) that You belong to, not specifically about You, and it gives Us statistics about gender, marital status, age, occupation and the interests of the group(s).
For the purposes of online advertising, some service and social media providers, and particularly Google and Facebook, do not provide Us with personal data about You, but they do use what they know about You in order to present Our advertising to You online after You have visited Our Website.
Your choices about what We collect
When you provide information via the Website, the online instructions will identify some fields as being mandatory. You will not be able to submit the information via the Website, or We will be unable to deal with Your request or enquiry, unless you complete the mandatory fields with true and accurate information.
To stay in touch with you before and after You place an order with Us, as a minimum We need the Contact Details for contacting You by Your preferred method(s) of contact (if You tell us Your preference(s)).
If You prefer for Us to use less personal data, You can choose to make less available to Us.
- How to withhold personal data: You can control all of Our sources of Your personal data. You can:
- provide less personal data than We request;
- use our Website to tell Us to stop contacting You with Our marketing;
- not respond to Our marketing and communications (and You also have rights to stop Our direct marketing to You: see below);
- change Your settings and connections in the social networks that you use; and/or
- change Your internet browser settings to prohibit cookies.
- Impact of withholding personal data: Withholding Your personal data from Us will mean the updates, offers and communications (via advertisements, direct marketing or messages) You receive from Us are not personalised or relevant to You, or (if you withhold the Contact Details, or tell Us not to contact You) that You do not receive them at all.
If You make an enquiry or place an order with Us, withholding Your personal data may mean that Our response to Your enquiry is not personalised or fully suitable for You.
For as long as We have access to Your personal data, We will use it for the following purposes, unless otherwise required as a result of You exercising Your data protection rights. We may use Your personal data for any of the following purposes, whether We obtained it directly from You (or someone You trust), or another source:
|To provide You with Our products and/or services in accordance with Our contract with You, once You have placed an order.||Processing by Us, and by Our Data Processors, will be necessary for Us to perform the contract with You or to take steps (at Your request) before We enter into the contract with You.|
|To process Your payment for Our products and/or services.||Our legitimate interest in obtaining payment before and after performing Our contract with You.|
|To provide You with information that You request from Us, or respond to Your enquiries made directly to Us.||Our legitimate interest in responding to Your requests and enquiries, e.g. by email, telephone, post or social networks.|
|To prepare, and send You, solicited or unsolicited direct marketing (unless You ask Us to stop), consisting of online advertising directed to You via our service providers or of direct correspondence with You, and containing relevant information about products and/or services that We provide.
Also to select or de-select You for each of Our direct marketing initiatives.
|If You are an existing customer: Our legitimate interest in staying in touch with You to discuss potential repeat business.
If You are a prospective customer: Our legitimate interest in sending You direct marketing to seek business from You, unless You ask Us to stop (in which case We will stop).
We may send notifications by email. You can stop these notifications at any time by contacting firstname.lastname@example.org
|To profile You via social media channels, using information about social media group(s) that You belong to.||Our legitimate interest in ensuring We are able to focus our marketing and advertising more effectively provided that You can ask Us to stop profiling You at any time (in which case We will stop).|
|To provide Us with information about how You use the Website, so we and our service providers can review the information and ensure that the Website is presented in the most effective manner for You and for Your devices, and that it is an effective sales and communication tool.||Our legitimate interest in providing products, services, choices, operations and Websites that meet the requirements of Our existing and prospective customers.
|For Us to take legal or administrative action, including to collect debts, resolve disputes with You, and deal with regulators.||Our legitimate interest in enforcing Our contract with You and in resolving any disputes with You, in dealing with regulators and as necessary for Us to establish, exercise or defend legal claims.|
|To contact You by email.||For prospective customers: Normally We will ask for Your consent and will not contact You by email if You have specifically withheld or withdrawn Your consent to this.
For existing customers: It is lawful for Us to contact You by email provided that We give You an easy method to unsubscribe. You can stop Us contacting You by email at any time by contacting email@example.com
How long We retain Your personal data
We will hold Your personal data until, in accordance with Your rights, We find Your Contact Details are not current, or We are notified that You are deceased, or You or a regulator ask Us to stop processing and erase Your personal data after Our contract with You has expired.
Disclosure of Your personal data
For as long as We have access to Your personal data, We may share any of it with any of the following to the extent that they need to have access to Your personal data in order to perform their role:
- Any employee within Our organisation.
- Our IT service providers who provide, maintain, improve, manage, optimise or fix the IT facilities that We use or rely on in Our business, including computing devices, computer networks, connectivity, telecommunications, software and Our Website.
- Our online service providers, who provide networking opportunities, information about networking groups, marketing and advertising placement services for Us, including providers of search engines, analytics services, behavioural marketing services, advertisement placement services, social media and online software applications.
- Our professional service providers, such as accountants, auditors, legal advisers and insurance brokers.
- Any third party company or companies in the event that We go through a business transition, such as a merger, being acquired by another person or company, or selling a portion of Our assets.
We reserve the right to disclose Your personal data to other third parties if We have lawful grounds to do so, or are under a legal obligation to disclose or share it with them, or in order to establish, exercise or defend Our legal rights, or to protect the rights, property, or safety of the Company or Our employees or subcontractors.
Our transfer of Your personal data abroad
Our paper records and our internal IT systems on which We store Your personal data are all within the European Economic Area (the “EEA”).
We or our service providers who process Your personal data for us may, however, use external IT services that are accessed from the UK and established outside the EEA. In particular, services that are established in the United States of America will be used. The European Commission decides, for the purposes of Data Protection Legislation, whether or not states outside the EEA have “adequate” safeguards for personal data. In the case of the United States, it is not currently considered to provide adequate safeguards, although its Government operates Privacy Shield and members of that scheme are considered to have “adequate” safeguards. Our service providers use Mailchimp (which participates in the EU-US Privacy Shield) and Leadpages (which does not participate). We will not transfer Your personal data into Leadpages without Your prior consent.
When We use social networks, Our use (as well as Yours) is subject to each social network provider’s terms and conditions and policies, which may state that the provider will store Your personal data outside of the EEA. Please refer to each provider and their terms and conditions and policies.
Under the Data Protection Legislation:
- You have the right to access personal data that We hold about You. Your right of access can be exercised in accordance with the Data Protection Legislation. You can submit a data access request at any time. In order to do this, please contact Us at firstname.lastname@example.org
- If You become aware of any inaccuracies in Your personal data which We process on Your behalf, You have a right to ask Us to rectify the inaccuracies.
- To the extent that (a) We no longer need to use Your personal data (e.g. You no longer wish to receive marketing from Us) for purposes described in Our Notices, or (b) We rely on Your consent and You have withdrawn it, or (c) You object to Our legitimate interests for using Your personal data and no exception applies to permit Us to keep using it, or (d) it is established that We did not have the lawful right to process Your personal data, or (e) the law requires Us to erase Your personal data, You may ask Us to erase Your personal data. If We erase Your personal data, Your ability to order Our products and/or use Our services will be affected, as described above.
- You have the right to ask Us not to process Your personal data for marketing purposes (including profiling). You may unsubscribe at any time by emailing Us directly at email@example.com
- You have the right to object to Our processing of Your personal data to the extent that (a) We use the personal data on grounds of Our legitimate interests and no exception applies to permit Us to keep using it, or (b) We use it for direct marketing purposes, or (c) We use it for scientific or historical research purposes or statistical purposes and no exception applies to permit Us to keep using it.
- You have the right to ask Us to restrict Our processing of Your personal data to the extent that (a) You have questioned the accuracy of the personal data and We are still checking its accuracy, (b) it is established that We did not have the lawful right to process the personal data, (c) We no longer need to use Your personal data for the purposes We collected or used it for but You need it to be preserved for the purposes of legal claims, or (d) You have exercised Your right to object to Our use of Your personal data and no exception applies to permit Us to keep using it.
- If We rely on Your consent for processing Your personal data, You can withdraw Your consent at any time.
- You have the right to complain to the Information Commissioner (http://www.ico.gov.uk/) if You have any concerns in respect of the handling of Your personal data by the Company.
If You would like to exercise any of the above rights, including to withdraw Your consent (where Our processing of Your personal information relies on Your consent), please contact Us at firstname.lastname@example.org
Our protection of Your personal information
We have taken reasonable steps to put in place appropriate security measures to protect Your personal data when it is processed by Us or on Our behalf.
We do not accept any responsibility for the policies of third party Data Controllers, such as providers of search engines and social networks. Your use of such third parties, their websites and services is at Your own risk. Please check the third parties’ Privacy Notices before You submit any personal data to them.
Changes to Privacy Notice
We reserve the right to make changes to this Privacy Notice from time to time. If this Privacy Notice changes in any way, We will place an updated version on Our Website. Regularly reviewing Our Website ensures that You are always aware of what information We collect, how We use it and under what circumstances, if any, We will share it with other parties.
If You do not agree to the changes that We make from time to time, please tell Us via email@example.com. If material changes are made to this Privacy Notice, We will notify You by placing a prominent notice on the Website.