1. Who we are?
2. What data do we collect
We may at times ask you to voluntarily provide us with Personal Data. For example, when you want us to provide you with information or services. In addition, we may collect information about how you use our website, social media, marketing channels and from the devices you use to access the website. This may be collected on the basis of our legitimate interests (as set out for fully below).
We may gather following information about you when you use or access Ada such as but not limited to:
- Email address
- Telephone number
- IP address (a unique identifier for your computer or other device)
- Mobile device ID
- Marketing preferences
- Data collected from the website is linked to cookies which we receive and process.
3. What about Sensitive Personal Data?
We do not collect Sensitive Personal Data (including, for example, information on race or ethnic origin, political or religious beliefs, trade union membership, physical or mental health, criminal record or other sensitive issues) except to the extent that any such information may be appropriate as part of Talon’s recruitment processes as an equal opportunities’ employer.
4. What if you believe the Personal Data we collect is inaccurate?
To the extent that any Sensitive Personal Data is collected, we will be collected this either on the basis of specific consent or where necessary for assessing your working capacity or otherwise because we have to by law. Talon will only disclose Sensitive Personal Data to trusted third parties where such disclosure is with your specific consent. We also have additional security measures in place to protect Sensitive Personal Data and its confidentiality. If you have reason to believe that any Personal Data that we have about you is out of date or inaccurate, please contact us using the contact details below, so that we can arrange for this to be amended.
5.. Why do we collect Personal Data?
We collect and process Personal Data generally, for the provision of our services or for the purposes of our legitimate business interests which we have set out below. We balance our legitimate interests against the impact on you and we ensure that our processing of your Personal Data does not unreasonably intrude on your privacy:
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We also may use the information we obtain about you in other ways for which we provide specific notice at the time of collection.
6. What Personal Data collected by Third Parties?
7. Your rights
Under the Data Protection Laws, you have a number of important rights in respect of Personal Data such as:
- Ask for a copy of Personal Data we hold about you, and details how we are processing your Personal Data;
- Object to our processing of your Personal Data, including profiling. If you raise an objection to this, we will stop processing the data, unless we can show compelling legitimate grounds to continue processing;
- Ask if we are processing your Personal Data by automated means and on the basis of your consent (see “How do we use it?”, above), and ask us to provide you your Personal Data in a structured, commonly used and machine-readable format. You can also ask us to provide your Personal Data directly to a third party in this format, and, if technically feasible, we will do so; and
- Ask to have Personal Data we have collected from you or maintain about you to be deleted in certain circumstances, for example, where we no longer have the right to process information, but this will not apply where the data is required for legal purposes, or for legitimate business purposes (such as research or statistical purposes);
- Request the restriction of our processing of your Personal Data in some situations, for example where the processing is unlawful and you oppose the erasure of Personal Data and request restriction instead, or where you contest the accuracy of the Personal Data.
You also have the right to make a complaint to the supervisory authority if you are not happy with how we’ve handled your Personal Data. In the UK, the supervisory authority is the Information Commissioner’s Office (http://www.ico.org.uk).
If you wish to exercise any of your rights in relation to Personal Data, please contact us on email@example.com. To the extent you are entitled to engage the above rights, your request will be dealt with promptly and generally within one month from when we receive your request and free of charge, except in extenuating circumstances (for example in the case of excessively large requests). If such extenuating circumstances means we are unable to comply with your request within one month, we will tell you as soon as possible about this delay.
8. Can I opt out or ask to have my Personal Data moved or erased?
You can at any time let us know that you wish to opt out to us using of your Personal Data, where we process your Personal Data based on your consent. If you do withdraw consent, that will not affect the lawfulness of what we have done with your Personal Data before you withdrew consent;
You may also seek portability of your Personal Data, where we process your personal data on the basis of consent and automated processing is carried out. Example: “If end users do not want client name to identify their mobile device, they can: (a) delete the Customer app or adjust the in-app settings of the Customer app if the app makes that option available(this will limit data collection from this app alone); or (b) opt-out of sharing your mobile advertiser ID by limiting ad tracking on the device.
9. How do we store Personal Data
Talon holds Personal Data in a combination of electronic and hard copy files, and may also store Personal Data with a third-party data storage provider. We take reasonable steps, including the use of secure storage, to ensure that the personal data we hold is protected from misuse, loss, unauthorised access, modification or disclosure. Where we store Personal Data with a third-party data storage provider, we require them to keep it secure and only use, or make it available to us, for the purpose for which it was provided.
10. Retention of Personal Data
The period for which we may retain Personal Data will depend on the purposes for which the information was collected, but we will not keep the Personal Data for longer than is necessary for the purposes for which it was provided, unless we are required by law or we have other legitimate interests (for example regulatory compliance) which requires us to keep it longer. Where we process your Personal Data for the contractual provision of our services, we will hold your Personal Data for 7 years following the completion of the contract for services with you.
Where we process your Personal Data on the basis of our legitimate interests, we will hold your Personal Data for 3 years following our last contact with you.
11. How do we protect Personal Data
Personal Data is kept confidential, secure and up to date, through a range of physical, technical, administrative and operational safeguards that are designed to prevent loss, disclosure and unauthorised access (by both employees and third parties). We also take reasonable steps to ensure that third parties that we deal with, have similar safeguards to ensure that any Personal Data is protected.
Talon uses a third-party service to help maintain the security and performance of the Talon website. As part of this service, the third party processes the IP addresses of visitors to the site, but these IP addresses are not tied to any other form of identification. This monitoring protects the website from malicious attacks.
Notwithstanding the security measures taken, and although we will do our best to protect personal data, complete security cannot be guaranteed. For example, the transmission of information via the internet is not completely secure. Therefore any sharing of Data by you needs to be at your own risk.
12. Transfer of Personal Data
Personal Data may be transferred to other group companies and trusted third parties outside the UK, but the Lead Supervisory Authority in respect of cross border transfers to and from Talon will be the Information Commissioner’s Office (ICO) in the United Kingdom.
13. What Personal Data do we share
In addition, Talon may disclose information to third parties in certain other limited circumstances, as follows:
if we are required to do so by law or legal process,
to law enforcement authorities or other government officials based on a lawful disclosure request, or
if we believe disclosure is necessary in connection with an investigation of suspected or actual fraudulent or illegal activity.
In the event that Talon sells or buys any business or assets, we reserve the right to disclose Personal Data to the prospective buyer or seller of such business or assets, subject to their being appropriate confidentiality provisions in place.
14. Our responsibility for website links
15. Protection of Children
Our services, platforms and websites, including Ada, are designed for a general audience, but it is not our intention to attract children under 13 to our website, platform, social media, or other marketing channels, and we do not knowingly collect or process Personal Data relating to any person under the age of 13. We would discourage children under the age of 13 from using our website social media or other marketing channels, or from providing any Personal Data to the company. If a parent or guardian learns that a child has provided us with personal identifiable information, that child’s parents or guardian should contact us and send a request marked Privacy- Urgent” if they would like the information submitted by the child to be deleted from our database. We will use all reasonable efforts to delete such information from our database.
16. What to do if your information or choices change
If you wish to update your Personal Data, make changes to your preferences, no longer wish to receive information that you have requested or if you have any queries about how we use your Personal Data, please contact us on firstname.lastname@example.org . We will take action to make any changes requested as soon as we reasonably can.
18. Contact us
If you have any questions or comments in relation to this policy, or if you would like to update any information we may have about you or your preferences, please contact us by email on email@example.com or write to us at:
Privacy and Data Protection, Talon Outdoor Limited, Holden House (2nd Floor), 57 Rathbone Place, London, W1T 1JU
19. Applicable Law
19. Further information
If you require further information on privacy and data protection generally, please visit the ICO website which oversees data protection compliance in the UK: ico.org.uk
Last updated 17th June 2021.