Privacy policy.
Contents
Introduction
Together is committed to safeguarding the private information entrusted to us by our clients and visitors. This privacy notice will inform you as to how we look after your personal data, and tell you about your privacy rights and how the law protects you. We will never sell or trade your personal or financial information.
Together cares about your privacy. If you have any queries regarding this Privacy Policy, please let us know at hello@together.agency.
Purpose
This privacy notice aims to give you information on how Together collects and processes your personal data through your use of this website and in the course of its business, including any data you may provide through this website when you sign up for updates from us.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Controller
Together Holdings Ltd. is the controller and responsible for your personal data.
Contact details
Together Holdings Ltd. is a limited company whose registered office is at 22 Elthiron Road, London SW6 4BN, UK. The registered company number is 11342654.
Our contact email address for privacy matters: hello@together.agency
Postal address: Together, 22 Elthiron Road, London SW6 4BN, UK
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance at hello@together.agency
Sites Covered
This privacy statement applies to the information collected vxia this web site. It does not apply to any linked sites. To learn about the privacy policies of any linked sites, please refer to the privacy statements on those sites.
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 notice of every website you visit.
The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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 notice.
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.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. 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:
- subscribe to our service or publications;
- request marketing to be sent to you;
- give us some feedback; or
- provide us with services.
- Automated technologies or interactions. As you interact with our website, we may 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. Please see our cookie policy below for further details.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties:
- analytics providers such as Google based outside the EU; and
- search information providers.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
- Identity and Contact Data from data brokers or aggregators.
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
Security
We are committed to providing a safe and secure online environment. To that end, we maintain physical, electronic and procedural safeguards to protect information, which comply with all applicable laws. We require independent contractors and other third parties who work with us to adhere to strict privacy standards through their contracts with us.
Information Usage
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing hello@together.agency.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we may use your personal data, and which of the legal bases we would rely on to do so. We have also identified what our legitimate interests would be where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please email hello@together.agency. If you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the list below.
Purpose/Activity: To register you as a new supplier or client of a Together Holdings Ltd.
Type of data: Identity, Contact
Lawful basis for processing including basis of legitimate interest:
- Performance of a contract with you
Purpose/Activity:To process and deliver any services (or our receipt of services), manage payments, fees and charges, collect and recover money owed to us
Type of data: Identity, Contact, Financial, Transaction, Marketing and Communications
Lawful basis for processing including basis of legitimate interest:
- Performance of a contract with you
- Necessary for our legitimate interests (to recover debts due to us)
Purpose/Activity: To manage our relationship with you which will include:Notifying you about changes to our terms or privacy policy, Asking you to leave a review or take a survey
Type of data: Identity, Contact, Marketing and Communications
Lawful basis for processing including basis of legitimate interest:
- Performance of a contract with you
- Necessary to comply with a legal obligation
- Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
Purpose/Activity: To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Type of data: Identity, Contact, Technical
Lawful basis for processing including basis of legitimate interest:
- Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
- Necessary to comply with a legal obligation
Purpose/Activity: To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
Type of data: Identity, Contact, Usage, Marketing and Communications, Technical
Lawful basis for processing including basis of legitimate interest:
- Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
Purpose/Activity: To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Type of data: Technical, Usage
Lawful basis for processing including basis of legitimate interest:
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
Purpose/Activity: To make suggestions and recommendations to you about services that may be of interest to you
Type of data: Identity, Contact, Technical, Usage
Purpose/Activity:
- Necessary for our legitimate interests (to develop our products/services and grow our business)
Marketing
We use Mailchimp to manage our direct marketing. When you subscribe through our website for our newsletter, you are agreeing to receive our newsletter.
Opting out
If you wish to opt out, you will be able to ask us or third parties (if applicable) to stop sending you marketing messages at any time by contacting us at hello@together.agency, or through the unsubscribe link provided on all emails.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of our receipt of services or other transaction.
Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- Internal Third Parties as set out in the Glossary.
- External Third Parties as set out in the Glossary.
- 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.
International transfers
We may share your personal data within Together Holdings Ltd. This may involve transferring your data outside the European Economic Area (EEA). We have therefore entered into a specific intra-group contract approved by the European Commission which gives these transfers of personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries (Link).
Many of our external third party services providers are also based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA to these third parties, 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 by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries (Link).
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries (Link).
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield (Link).
Please emailing hello@together.agency. if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements.
In some circumstances you can ask us to delete your data: see [Right to Erasure] below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Rights
The right to object to processing
You have the right to object to certain types of processing, including processing for direct marketing (i.e. if you no longer want to be contacted with potential opportunities).
The right to be informed
You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Policy.
The right of access
You have the right to obtain access to your information (if we’re processing it), and certain other information (similar to that provided in this Privacy Policy).
This is so you’re aware and can check that we’re using your information in accordance with data protection law.
The right to rectification
You are entitled to have your information corrected if it’s inaccurate or incomplete.
The right to erasure
This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
The right to restrict processing
You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.
The right to data portability
You have rights to obtain and reuse your personal information for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability.
The right to lodge a complaint
You have the right to lodge a complaint about the way we handle or process your personal information with your national data protection regulator.
The right to withdraw consent
If you have given your consent to anything we do with your personal information, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal information with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal information for marketing purposes.
If you wish to exercise any of the rights set out above, please email hello@together.agency.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Information Updates
You may request access, amend or remove any of their personal information at any time by emailing compliance@together.agency.
We usually act on requests, and provide information free of charge, but may charge a reasonable free to cover our administrative costs of providing information for:
- Baseless or excessive/repeated requests
- Further copies of the same information
Alternatively, we may be entitled to refuse to act on the request.
Please consider your request responsibly before submitting it. We’ll respond as soon as we can. Generally this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we’ll come back to you and let you know.
Website Links
Together does not take responsibility for collection of personal information via other websites for which a link is provided on this website. You should refer to the privacy statements for those websites.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated in November 2022.
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.
Contacting Us
If you have any queries regarding this Privacy Policy, the practices of this site, or your dealings with this Web site, please contact us at: hello@together.agency.