Aspect Ltd (incorporated in England and Wales under company number 3445712) is based at Unit 7, Hampstead West, 224 Iverson Road, London, NW6 2HL. We are a global events and communications agency, specialising in audio video, production, creative design, message and content development, audience engagement and interaction, presenter scripts and presenter support, logistics and event management, venue sourcing, leadership coaching, video and animation, technical, environment design, rehearsal management, digital expertise.
Aspect operates conscientiously within the requirements of the General Data Protection Regulations 2018 and other electronic marketing legislation. We work within the principles of fair data processing, namely:
- Using information in a way that people would reasonably expect.
- Thinking about the impact of our processing.
- Being transparent and ensuring that people know how we will use their information.
This statement (together with our Terms and Conditions), which will be updated at regular intervals, sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us, as data controller and a data processor.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
1. What This Privacy Statement Covers
This statement covers how we treat any personal information that we collect and receive either from our website or as part of our broader operating processes.
We do not sell or pass on any personal information about our clients or prospects and we only use any information shared with us for running and improving our services and in that capacity operate as a data controller and, in the extent that we process the data, as a data processor.
This statement tells you what information we collect, the steps we take to protect and secure it, how we use and share information, and finally, how you can contact us with questions or concerns.
2. Information We Collect
(a) Personal Information. We collect personal information (e.g., name, email address, phone number, etc.) when you:
- Send us an enquiry through our website.
- Email us.
- Work with us as a customer, supplier or employee.
(b) Other User Information. When you access and use our services, we may collect additional contextual information about your company as well as your design and aesthetics preferences. We do not link this additional data to any other information we collect about you and do not undertake any profiling activity.
(c) Billing Information. If you contract us for event services, we will require your billing information in order to process the transaction. Billing information includes your name, address, bank details and other information necessary to process the transaction.
3. Information Use, Legal Basis, Sharing, Disclosure, and Retention
(a) Use and Legal Basis.
Sales and Service Delivery. Aspect uses personal data for developing and issuing sales proposals and for providing its products and services – and justifies this under the legal basis of “Contract”.
Marketing Emails. Aspect uses personal data to update existing clients and prospective B2B clients with information about our services. We justify this through a “Legitimate Interests” assessment and offer opt-out functionality for those no longer wishing to hear from us in this way.
CCTV and Security. We operate CCTV at our premises – as justified through a “Legitimate Interests” assessment.
Administrative and Legal. We process small amounts of employee and subcontractor data under the legal basis of “Contract” and, if in the Vital Interests of the data subject, or with specific consent, or to comply with Employment or Health and Safety or another Legal requirement will hold special category data such as medical history or driving convictions.
(b) Sharing. Aspect does not share, sell, rent or trade personal information with any third parties for marketing or promotional purposes.
We do share small quantities of employee data for administrative and legal purposes.
Aspect also reserves the right to share data with relevant authorities if compelled to do so to comply with legal obligations. We will use third party payment processors for card transactions to pay for goods and services but these third parties are authorized to use the data only as necessary to provide these services to us and are prohibited from using your personal information for promotional purposes.
(c) Disclosure. Aspect may disclose personal information under the following circumstances:
- In certain situations, we may disclose personal data in response to lawful requests by public authorities, including but not limited to national security or law enforcement requests. We may also disclose your personal information as required by law, such as to respond to court orders, or similar legal processes, to establish or exercise our legal rights or, defend against legal claims, or if in our judgment in such circumstances disclosure is required or appropriate.
(d) Retention. We will retain existing customer information for as long as a customer account is active with us or as needed to provide our services – and where required to comply with our legal obligations, resolve disputes, and enforce our agreements. We will retain all prospective customer data ongoing until any such time that we receive a request to opt-out.
4. Confidentiality and Security
We use physical, electronic, and procedural safeguards to protect personal information. Our IT arrangements aspire to “Data Protection by Design” and should be able to detect a significant data breach. Where such a breach could result in discrimination, damage to reputation, financial loss, loss of confidentiality or any other significant economic or social disadvantage we will notify the ICO. Where a breach is likely to result in a high risk to the rights and freedoms of individual data subjects, we will also notify those concerned directly and at the earliest practical opportunity. We shall then fully investigate a data breach and implement corrective action to prevent recurrence.
By using our services or providing personal information to us, you are consenting to Aspect communicating with you electronically regarding security, privacy, and administrative issues related to your use of our services. We may post a notice on our website if a security breach occurs. In these circumstances, we may also send an email to you at the email address you have provided.
Data transmissions over the Internet are not 100% secure. Consequently, we cannot guarantee or warrant the security of any information you transmit to us and you do so at your own risk. Once we receive your transmission, we use reasonable efforts to ensure security on our systems.
5. Right to Be Informed
We strive to ensure that all those engaging with us are informed of our arrangements for processing personal data through this Privacy Statement which is linked to from our email signatures and website home page.
6. Right of Access
We will respond to data requests within 1 month and will only charge for requests that are manifestly unfounded or excessive. If we have grounds to refuse a request we will inform the data subject and make them aware of their right to complain to the ICO or to seek civil action – again within 1 month of receiving the request.
7. Right to Rectification
For personal data obtained directly from a data subject under the legal basis of consent – and obtained indirectly from a data subject under the legal basis of legitimate interest – we will correct any inaccuracies in a data subject’s personal data upon receipt of a request. For personal data held under the legal basis of “Contract” or “Vital Interests” or “Legal Obligations” we will endeavour to correct the data upon request but may not be able to do so if changing the data may conflict with our legal obligations or be disadvantageous in a future legal action. In cases where we cannot rectify the data for these reasons we shall inform the data subject and make them aware of their right to complain to the ICO or to seek civil action.
8. Right to Erase
For personal data obtained directly from a data subject under the legal basis of consent – and obtained indirectly from a data subject under the legal basis of legitimate interest – we will erase a data subject’s personal data upon receipt of a request / opt-out notification. For personal data held under the legal basis of “Contract” or “Vital Interests” or “Legal Obligations” we will endeavour to erase data upon request but will not be able to do so if holding the data is necessary to fulfil our legal obligations or may be necessary as evidence in a future legal action involving us. In cases where we cannot erase the data for these reasons we shall inform the data subject and make them aware of their right to complain to the ICO or to seek civil action.
9. Right to Restrict Processing
For personal data obtained directly from a data subject under the legal basis of consent – and obtained indirectly from a data subject under the legal basis of legitimate interest – we will restrict the processing of a data subject’s personal data upon receipt of a request / opt-out notification. For personal data held under the legal basis of “Contract” or “Vital Interests” or “Legal Obligations” we will endeavour to facilitate the requested restriction upon request, but will not be able to do so if restricting the processing of the data prevents us from fulfilling our legal obligations, or the current processing of the data may be necessary as evidence in a future legal action involving us. In cases where we cannot restrict the processing of the data for these reasons we shall inform the data subject and make them aware of their right to complain to the ICO or to seek civil action.
10. Right to Data Portability
For personal data obtained directly from a data subject under the legal basis of consent – we shall provide, upon receiving a request, the data that we hold in a standard, widely accessible format.
11. Right to Object
For personal data obtained directly from a data subject under the legal basis of consent – and obtained indirectly from a data subject under the legal basis of legitimate interest – we will cease to process a data subject’s personal data upon receipt of a request/opt-out notification.
12. Changes to this Privacy Statement
Aspect reserves the right to revise, modify, or update this statement at any time. We will notify you via email about material changes in the way we treat personal data or by placing a prominent notice on this website.
13. Contacting Aspect
If you have a privacy concerns regarding Aspect, or this statement, you may contact us via firstname.lastname@example.org