register for focus group discussions or consumer research surveys (we will refer to each of these as a “Research Event”);
attend a Research Event;
answer questions in relation to a Research Event;
take part in any other consumer research events
give your consent for us to add your contact details to our database of contacts who may be invited to attend further Research Events or be involved in other consumer research events in the future (we call this our “research panel”); or
enter into a prize draw competition,
in each case which we organise (either for ourselves or on behalf of another person (other people are known as “third parties”),
We do not knowingly collect data relating to children under the age of 16.
Nerds is the controller and responsible for your personal data.
Email address: email@example.com
Postal address: 20-22 Wenlock Road, London, N1 7GU
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.
It is important that the personal data we hold about you is accurate and up to date. Please keep us informed if your personal data changes during your relationship with us.
2. THE DATA WE COLLECT ABOUT YOU
“Personal data” means any information about an individual (known as a “data subject”) from which that person can be directly or indirectly identified. It does not include data where the identity has been permanently 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 including first name, maiden name, last name, username or similar identifier, marital status, title, age, date of birth and gender, location data, and photographs and videos.
- Contact Data include postal address, email address and telephone numbers.
- Profile Data includes your username and password, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Special Category Data including personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. We only collect and process this type of personal data with your explicit consent.
We do not 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 register you to take part in a Research Event or any prize draw competition we may be running). In this case, we may have to cancel our contract with you but we will let you know this at the time.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
You may give us your personal information by filling in online forms or by corresponding with us by phone, email or otherwise. This includes personal data you provide when you:
request marketing to be sent to you;
register to take part in a Research Event;
enter a competition, promotion or survey;
give us consent for us to add you to our research panel; or
give us feedback or contact us for any other reason.
Third parties or publicly available sources.
We will receive personal data about you from various third parties and public sources as set out below:
Contact Data from the third parties we organise Research Events or panel discussions for; and
Identity Data from publicly available sources such as Google and social media platforms, which may be based outside the United Kingdom.
4. HOW WE USE YOUR PERSONAL DATA
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 you have given your consent for us to use your personal data. You can withdraw your consent at any time.
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 perform the contract we are about to enter into or have entered into with you.
Where we need to comply with a legal obligation.
Each of these is known as a “lawful basis” on which we can process your personal data.
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 plan to use your personal data, and which of the lawful bases we rely on in each case. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful basis, depending on the specific purpose for which we are using your personal data. Please contact us if you need details about the specific lawful basis we are relying on to process your personal data where more than one lawful basis has been set out in the table below.
Purpose / Activity
Type of personal data
Lawful basis for processing including basis of legitimate interest
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(c) receiving your registration to take part in a Research Event
(d) asking you to attend a Research Event
(e) holding your details in our database of people willing to take part in panel groups
(f) asking you to take part in a panel group
(g) receiving your entry for a prize draw competition we are running
(d) Marketing and Communications
You have given us your consent where (c), (d), (e) and (f) apply.
Necessary for our legitimate interests (to keep our records updated and to study how you found our process)
To enable you to partake in a Research Events, any other consumer research we organise, whether for ourselves or our third party client(s), or a prize draw competition we are running, and subsequent follow up communication, and for us and our third party client(s) to make use of the written and oral comments your provide.
(e) Marketing and Communications
(a) You have given your consent for us to process your personal data for this purpose
(b) Performance of a contract with you
To measure and understand the effectiveness of the work we do with you
(e) Marketing and Communications
You have given us your consent to send direct marketing to you.
Necessary for our legitimate interests (to develop our services them, to grow our business and to inform our marketing strategy)
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
If, for any reason, you wish to object to the processing of your personal data (as outlined in the table above), or if you would like to withdraw your consent to us processing your personal data for any reason, please send an email to: firstname.lastname@example.org stating your full name, with the words OPT OUT, or, in the case of marketing communications we have sent to you, please click on the opt-out link or follow the opt-out instructions provided.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it (we will call this the “original purpose”), unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you would like an explanation of how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below for the purposes set out in the table above.
Third parties who we appoint to provide services to us. For example, where we appoint a third party to run our website or software we use.
Our professional advisers including lawyers, bankers, auditors and insurers.
HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
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.
6. INTERNATIONAL TRANSFERS
We do not transfer your personal data outside the United Kingdom.
7. 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. We also limit our employees’, agents’, contractors’ and other relevant third parties’ access to your data, to those who have a business need to know. Where these third parties process your personal data on our behalf, they will only do so 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.
8. HOW LONG WILL WE USE YOUR PERSONAL DATA FOR?
We will only keep your personal data for as long as reasonably need it to fulfil the purposes we collected it for. We may keep your personal data for a longer period if you make a complaint or if we reasonably believe there is a prospect that we may be involved in a dispute with you that goes to court.
To determine the appropriate period for us to keep your personal data, we consider the amount, nature and sensitivity of the personal data we hold, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data, whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection law in relation to your personal data, including the right to: Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. There may be certain reasons why we are unable to provide the information you request and we will let you know if that’s the case.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate personal data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with the law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons and we will let you know if that’s the case.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this basis, as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. You can ask us to suspend the processing of your personal data in the following scenarios:
if you want us to establish the accuracy of the personal data’s.
where our use of the personal data is unlawful but you do not want us to erase it.
where you need us to keep the personal data even, if we no longer need it, as you need it to establish, exercise or defend legal claims.
you have objected to our use of your personal data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. Where you exercise this right, we will send you or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use, or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing of your personal data that we carried out before you withdrew your consent. If you withdraw your consent, we may not be able to provide certain products or services to you or perform a contract we have entered into with you. We will let you know if this is the case at the time you withdraw your consent.
If you would like to exercise any of the rights set out above, please contact us at email@example.com.
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 listed above). However, we may either charge a reasonable fee or refuse to comply with your request if your request is clearly unfounded, repetitive or excessive.
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) exists. 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 could 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 on our progress.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law to do so). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities, by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract between you and Nerds, or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.