Introduction: why do we have this policy?
Arrowmaker Communications is a B2B copywriting and content company. It does not target marketing to consumers, nor does it hold or process your personally identifiable data for that purpose.
However, Arrowmaker Communications does hold and process personally identifiable information arising from individual contact persons in the companies and sole trader organisations with which it does business, as well as in its suppliers.
The vast majority of this data is used to enable us to deliver the services you have requested from us (or we from you) and for payment of these services. Some of the information is also used to market further services to you.
We believe GDPR is a necessary step in protecting your (and our) personally identifiable information and we are very glad to support it. There is still significant uncertainty about some of the ramifications of the Regulation, particularly for smaller businesses, and our take on it may have to evolve over the coming months and years.
But we are determined to take whatever steps we reasonably can to treat your personal data with the respect it deserves now and in the future.
The policy: scope, purpose and applicability
This policy is applicable to the processing of customers’ personal data by Arrowmaker Communications (“our”, “us” or “we”). The purpose of this policy is to provide our current, former and potential customers (jointly referred to as “customers” or “suppliers” or “you”) with a general understanding of:
This policy will be updated when appropriate to reflect measures taken by Arrowmaker Communications in relation to your personal data.
Arrowmaker Communications is the Controller in relation to processing of your personal data for services offered to customers.
Arrowmaker Communications is also Controller for any processing of personal data in relation to legal and regulatory requirements.
Data processing: principles
We consider your privacy an essential part of the integrity of the services we offer. To safeguard your personal data whilst maximising the value of our services to you, we adhere to five general principles:
Principle 1: Freedom of choice
Your personal data belongs to you. It’s your choice whether or not to share your personal data with us.
Principle 2: Legitimate interest and other circumstances
We will only process your personal data in the pursuit of a legitimate interest, where there is risk to life or limb if we do not process it, or where ordered to process it (for example, as a legal requirement, or instruction by the forces or agents of the Law).
Principle 3: Proportionality
Arrowmaker Communications will only process our customers’ personal data if it is adequate, relevant and necessary in relation to the purpose for which it has been gathered or supplied.
Principle 4: Transparency and security
Arrowmaker Communications wants to be transparent about which personal data we process and for which purposes, and understands that it is critical that we protect that data. On request, Arrowmaker Communications will provide customers with further information regarding our processing and protection of your personal data.
Principle 5: Legal compliance
It is Arrowmaker Communications’ policy to comply with the applicable laws, rules and regulations governing privacy and data protection in the United Kingdom (our sole country of operation). Where necessary, we will adjust our processing of your personal data as described in this policy to ensure legal compliance.
Personal data that Arrowmaker Communications collects or receives about you will be used to:
Definitions of terms
Arrowmaker Communications makes use of the below-listed definitions in this policy:
You may provide us with information about you, for example through our website or by email, or by voice call. We may also obtain such data from third parties. Such data may include:
Although we do not typically collect or process sensitive personal data (as defined above or by any applicable law) we will carefully apply additional measures if and when collecting and processing such data, as required by applicable law.
Where reasonably practical or as required by applicable law, we will, in connection to collecting or registering your personal data, provide you with (i) specific information as to the purposes of the processing of your personal data, (ii) the identity of the Controller, (iii) the identities of any third parties to whom the data may be disclosed and (iv) other information which may be necessary to ensure that you are able to safeguard your rights.
Gaining your consent
Where reasonably practical or as required by applicable law, we will obtain your consent prior to collecting or using your personal data. The request for your consent will be clear and specific and provide you with a reasonable basis with which to make your decision. We will never take your consent for granted. Instead, we will make sure that you can consent in a clear and transparent manner.
Your consent is voluntary and may always be revoked, for example by terminating a particular service or contacting Arrowmaker Communications at the address indicated in the “Information and access” section below. If you do not give your consent, it may not be possible to use services or parts of services.
International transfer and sharing of data
Arrowmaker Communications will not transfer your personal data to recipients in countries outside of the European Economic Area or share your data with them unless you give us express written permission to do so, in which you also indicate that you have understood that no liability can be accepted by Arrowmaker Communications for the standard of data processing and protection, and how it is or is not enforced by law, in the countries concerned.
Use of data
For most processing acts, you are able to terminate our use of your personal data by either using built-in unsubscribe links or buttons, or by contacting Arrowmaker Communications at the address indicated in the “Information and access” section below or as otherwise instructed by us.
However, termination of the use of your personal data does not cover processing that we must perform in order to comply with our legal obligations.
Retention of your data
We will only retain your personal data for as long as it is necessary to fulfil the purposes outlined in this policy or for legitimate purposes of which you have otherwise been informed.
This means that when you have consented to our processing of your personal data, we will retain the data for as long as the customer relationship lasts or can reasonably be said to be ongoing, until you withdraw your consent.
If you have revoked your consent, we may nevertheless retain certain personal data for the period required in order for us to meet our legal obligations and defend ourselves in legal (including financial) disputes. If we have not received your consent for processing, the personal data will only be retained to the extent we are permitted to do so by law.
Data quality and correction
When we process your personal data, we make reasonable efforts to ensure that it is correct and up to date. We will delete or correct personal data that is incorrect or incomplete, once you have brought any such faults to our attention. For more information regarding your right to ensure the accuracy of your personal data held by us, please see the “Information and access” section below.
Information and access
As stated in the “Notice” section above, we may provide you with specific information concerning our processing of your personal data when collecting or registering such data.
You have the right to request (i) a copy of the personal data that we store about you, (ii) that we correct or remove personal data that you think is inaccurate, and (iii) to have your personal data deleted. In addition, you have the right to object to our processing of your personal data as well as to receive your personal data, which you have provided to us, in a structured, commonly used and machine-readable format and to have these transmitted to another Controller.
Requests should be sent to the legal entity stipulated in the end of this document. Your requests will be dealt with in a prompt and proper manner. For more information on your rights please contact us using the details at the end of this document.
Arrowmaker Communications has taken, and continues to take, technical and organisational measures in order to protect your personal data against accidental or unlawful destruction, accidental loss or alteration, unauthorised disclosure or access and any other unlawful forms of processing.
Disclosures to third parties
Arrowmaker Communications may share your personal data:
Arrowmaker Communications, being the Controller of your personal data will, as a general rule, only disclose your personal data to a third party if it has received your consent to do so (see above). However, if permitted by law we may share your personal data without your consent, unless we consider your consent necessary in the individual case or your consent is required by law, in the following situations:
Data processing on our behalf
We restrict processing access to your personal data by others on our behalf to third party applications such as (but not limited to) mailing, invoicing / accounting and document storage / document management software, which are required by us in order to deliver and manage services to you that you have requested from us.
We will not sell or trade your personal data with third parties unless we have your consent to do so. We will not share your personal data with third parties for their marketing purposes, unless we have received your consent for such disclosures. If you have provided such consent, but wish to stop receiving marketing materials from a third party, please contact that third party directly.
We may provide you with information regarding new products, services, events or similar marketing activities. If you wish to unsubscribe from a particular e-mail newsletter or similar communication, or change previously submitted preferences, please follow the instructions, links and buttons in the relevant communication.
Websites and cookies
In general, you can visit Arrowmaker Communications’ website without telling us who you are or revealing any information about yourself. However, to be able to provide you with certain services or offerings, we often need to record certain items of personal data such as your name and email address.
We may also collect (by means of cookies) anonymous information on how you have used our websites prior to such recording. This information will be helpful to us in order to improve our websites or marketing, and, in turn, the customer experience you receive from us.
Protection of children
Our services are not intended for use by children. We do not knowingly solicit or collect any personal data about children nor do we market our products or services to them.
If a child has provided us with personal data, a parent or guardian of that child may contact us to have the information deleted from our records. If you believe that we might unknowingly have any information collected from, or personally identifying, a child, please contact us. We will take steps to delete the information as soon as possible, where jurisdiction permits.
If you are of the opinion that we are processing your personal data in violation of data protection laws and regulations you have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office (ICO).
However, if you suspect there has been an error or a contravention of any of the processes outlined in this document, we would advise you to contact us first (see contact information below), as we are in the best position to rectify the problem most rapidly and ensure it causes you and others no further issues.
Data protection representative and contact details
You can contact the Arrowmaker Communications data protection representative via the following contact details:
E-mail address: firstname.lastname@example.org
Postal address: Arrowmaker Communications, Attn. Data Protection Representative, 61 Bridge Street, Kington, HR5 3DJ
To exercise your rights – e.g. to obtain information or access to personal data which we process – or to suggest how we could improve the information on these pages – please use the contact details above.
Thanks for reading.
Your Arrowmaker Communications Team