Colorific Solutions Ltd t/a CSL Digital (“CSL Digital”, “we”, “us”, or “our”) is strongly committed to protecting personal data. This privacy statement describes why and how we collect and use personal data and provides information about individuals’ rights. It applies to personal data provided to us, both by our business customers themselves or by others. We may use personal data provided to us for any of the purposes described in this privacy statement or as otherwise stated at the point of collection.
Personal data is any information relating to an identified or identifiable living person. CSL Digital processes personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose may differ.
When collecting and using personal data, our policy is to be transparent about why and how we process personal data. To find out more about our specific processing activities, please go to the relevant sections of this statement.
Collection of personal data – Business Customers
CSL Digital processes personal data about contacts (existing and potential CSL Digital business customers and/or individuals associated with them) using a customer relationship management system (the “CSL CRM”).
The collection of personal data about contacts and the addition of that personal data to the CSL Digital CRM is initiated by a CSL Digital user and will include name, employer name, contact title, phone, email and other business contact details. In addition, the CSL Digital CRM may collect data from CSL Digital email (sender name, recipient name, date and time) and calendar (organiser name, participant name, date and time of event) systems concerning interactions between CSL Digital users and contacts or third parties.
Use of personal data – business customers
Personal data relating to business contacts may be visible to and used by CSL Digital users to learn more about an account, client or opportunity they have an interest in, and may be used for the following purposes:
- Administering, managing and developing our businesses and services
- Providing information about us and our range of services
- Making contact information available to CSL Digital users
- Identifying business customers/contacts with similar needs
- Describing the nature of a contact’s relationship with CSL Digital
- Performing analytics, including producing metrics for CSL Digital leadership, such as on trends, relationship maps, sales intelligence and progress against account business goals
In addition, the CSL Digital CRM uses an algorithm to evaluate the strength of interactions between a CSL Digital user and a contact. This ranking is primarily based on interaction frequency, duration, recency and response time.
CSL Digital does not sell or otherwise release personal data contained in the CSL Digital CRM to third parties for the purpose of allowing them to market their products and services without consent from individuals to do so.
Personal data will be retained on the CSL Digital CRM for as long as it is necessary for the purposes set out above (e.g. for as long as we have, or need to keep a record of, a relationship with a business contact).
Collection of personal data – Suppliers
We collect and process personal data about our suppliers (including subcontractors and individuals associated with our suppliers and subcontractors) in order to manage the relationship, contract, to receive services from our suppliers and, where relevant, to provide professional services to our clients.
Use of personal data – Suppliers
We use personal data for the following purposes:
- Receiving services
We process personal data in relation to our suppliers and their staff as necessary to receive the services. For example, where a supplier is providing us with facilities management or other outsourced services, we will process personal data about those individuals that are providing services to us.
- Providing goods or services to our business customers
Where a supplier is helping us to deliver goods or services to our business customers, we process personal data about the individuals involved in providing the goods or services in order to administer and manage our relationship with the supplier and the relevant individuals and to provide such services to our business customers (for example, where our supplier is providing people to work with us as part of a CSL Digital team providing goods or services to our business customers).
- Administering, managing and developing our businesses and services
We process personal data in order to run our business, including:
– managing our relationship with suppliers;
– developing our business and the goods and services we provide to our business customers
– maintaining and using IT systems;
– hosting or facilitating the hosting of events; and
– administering and managing our website and systems and applications.
- Security, quality and risk management activities
We have security measures in place to protect our and our business customers’ information (including personal data), which involve detecting, investigating and resolving security threats. Personal data may be processed as part of the security monitoring that we undertake; for example, automated scans to identify harmful emails. We have policies and procedures in place to monitor the quality of our services and manage risks in relation to our suppliers. We collect and hold personal data as part of our supplier contracting procedures. We monitor the services provided for quality purposes, which may involve processing personal data.
- Providing information about us and our range of services
Unless we are asked not to, we use business contact details to provide information that we think will be of interest about us and our services. For example, industry updates and insights, other services that may be relevant and invites to events.
We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation).
Personal data may be held for longer periods where extended retention periods are required by law or regulation and in order to establish, exercise or defend our legal rights.
Visitors to our offices and showrooms
We have security measures in place at our offices, including CCTV and building access controls.
There are signs in our office showing that CCTV is in operation. The images captured are securely stored and only accessed on a need to know basis (e.g. to look into an incident). CCTV recordings are typically automatically overwritten after a short period of time unless an issue is identified that requires investigation (such as a theft).
We require visitors to our offices to sign in at reception and keep a record of visitors for a short period of time. Our visitor records are securely stored and only accessible on a need to know basis (e.g. to look into an incident).
Visitors to our websites
Collection of personal data
Visitors are also able to send an email to us through the website. Their messages will contain the user’s screen name and email address, as well as any additional information the user may wish to include in the message.
We ask that you do not provide any potentially sensitive information to us when using our website; if you choose to provide sensitive information to us for any reason, the act of doing so constitutes your explicit consent for us to collect and use that information in the ways described in this privacy statement or as described at the point where you choose to disclose this information.
Further Cookie information:
- A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
- Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
- Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
- We use both session and persistent cookies on our website.
The names of the cookies that we use on our website, and the purposes for which they are used, are set out below:
- Most browsers allow you to refuse to accept cookies; for example:
(a) in Internet Explorer (version 11) you can block cookies using the cookie handling override settings available by clicking “Tools”, “Internet Options”, “Privacy” and then “Advanced”;
(b) in Firefox (version 44) you can block all cookies by clicking “Tools”, “Options”, “Privacy”, selecting “Use custom settings for history” from the drop-down menu, and unticking “Accept cookies from sites”; and
(c) in Chrome (version 48), you can block all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Content settings”, and then selecting “Block sites from setting any data” under the “Cookies” heading.
- Blocking all cookies will have a negative impact upon the usability of many websites.
- If you block cookies, you will not be able to use all the features on our website.
- You can delete cookies already stored on your computer; for example:
(a) in Internet Explorer (version 11), you must manually delete cookie files (you can find instructions for doing so at http://windows.microsoft.com/en-gb/internet-explorer/delete-manage-cookies#ie=ie-11);
(b) in Firefox (version 44), you can delete cookies by clicking “Tools”, “Options” and “Privacy”, then selecting “Use custom settings for history” from the drop-down menu, clicking “Show Cookies”, and then clicking “Remove All Cookies”; and
(c) in Chrome (version 48), you can delete all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Clear browsing data”, and then selecting “Cookies and other site and plug-in data” before clicking “Clear browsing data”.
- Deleting cookies will have a negative impact on the usability of many websites.
Use of personal data – websites
When a visitor provides personal data to us, we will use it for the purposes for which it was provided to us as stated at point of collection (or as obvious from the context of the collection). Typically, personal data is collected to:
- register for certain areas of the site;
- subscribe to updates;
- enquire for further information;
- distribute requested reference materials;
- submit curriculum vitae;
- monitor and enforce compliance with our terms and conditions for use of our website;
- administer and manage our website, including confirming and authenticating identity and preventing unauthorised access to restricted areas, premium content or other services limited to registered users; and
- aggregate data for website analytics and improvements.
Unless we are asked not to, we may also use your data to contact you with information about CSL Digital’s business, services and events, and other information which may be of interest to you. Should visitors subsequently choose to unsubscribe from mailing lists or any registrations, we will provide instructions on the appropriate webpage, in our communication to the individual, or the individual may contact us by email to firstname.lastname@example.org.
Our websites do not collect or compile personal data for the dissemination or sale to outside parties for business to business or consumer marketing purposes or host mailings on behalf of third parties. If there is an instance where such information may be shared with a party that is not CSL Digital, the visitor will be asked for their consent beforehand.
Personal data collected via our websites will be retained by us for as long as it is necessary (e.g. for as long as we have a relationship with the relevant individual).
We take the security of all the data we hold very seriously. We have a framework of policies, procedures and training in place covering data protection, confidentiality and security and regularly review the appropriateness of the measures we have in place to keep the data we hold secure.
When and how we share personal data and locations of processing
We will only share personal data with others when we are legally permitted to do so. When we share data with others, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality and security standards.
We do operate in a global marketplace and we may use third parties located in other countries to help us run our business. As a result, personal data may be transferred outside the countries where we and our business customers are located. This includes to countries outside the European Union (“EU”) and to countries that do not have laws that provide specific protection for personal data. We have taken steps to ensure all personal data is provided with adequate protection and that all transfers of personal data outside the EU are done lawfully. Where we transfer personal data outside of the EU to a country not determined by the European Commission as providing an adequate level of protection for personal data, the transfers will be under an agreement which covers the EU requirements for the transfer of personal data outside the EU, such as the European Commission approved standard contractual clauses. The European Commission approved standard contractual clauses are available here.
Personal data held by us may be transferred to:
Third party organisations that provide applications/functionality, data processing or IT services to us
We use third parties to support us in providing our services and to help provide, run and manage our internal IT systems. For example, providers of information technology, cloud-based software as service providers, identity management, website hosting and management, data analysis, data back-up, security and storage services. The servers powering and facilitating that cloud infrastructure are situated in secure data centres around the world, and personal data may be stored in any one of them.
- Third party organisations that otherwise assist us in providing goods, services or information
- Auditors and other professional advisers
- Law enforcement or other government and regulatory agencies or to other third parties as required by, and in accordance with, applicable law or regulation
Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.
Changes to this privacy statement
We recognise that transparency is an ongoing responsibility, so we will keep this privacy statement under regular review.
This privacy statement was last updated on Friday 27th April 2018.
Data controller and contact information
The data controller is Colorific Solutions Ltd t/a CSL Digital, Unit 6, Globe Business Park, First Avenue, Marlow, Buckinghamshire, SL7 1YA
If you have any questions about this privacy statement or how and why we process personal data, please contact us at:
Data Protection Officer
Colorific Solutions Ltd t/a CSL Digital
Unit 6, Globe Business Park, First Avenue,
Phone: 01268 560 890
Individuals’ rights and how to exercise them
Individuals have certain rights over their personal data and data controllers are responsible for fulfilling these rights. Where we decide how and why personal data is processed, we are a data controller and include further information about the rights that individuals have and how to exercise them below.
Access to personal data
You have a right of access to personal data held by us as a data controller. This right may be exercised by emailing us at email@example.com. We may charge for a request for access in accordance with applicable law. We will aim to respond to any requests for information promptly, and in any event within the legally required time limits (currently 40 days).
Amendment of personal data
To update personal data submitted to us, you may email us at firstname.lastname@example.org or, where appropriate, contact us via the relevant website registration page or by amending the personal details held on relevant applications with which you registered.
When practically possible, once we are informed that any personal data processed by us is no longer accurate, we will make corrections (where appropriate) based on your updated information.
Withdrawal of consent
Where we process personal data based on consent, individuals have a right to withdraw consent at any time. We do not generally process personal data based on consent (as we can usually rely on another legal basis). To withdraw consent to our processing of your personal data, please email us at email@example.com or, to stop receiving an email from a CSL Digital marketing list, please click on the UNSUBSCRIBE LINK in the relevant email received from us.
Other data subject rights
This privacy statement is intended to provide information about what personal data we collect about you and how it is used. As well as rights of access and amendment referred to above, individuals may have other rights in relation to the personal data we hold, such as a right to erasure/deletion, to restrict or object to our processing of personal data and the right to data portability. Some of these rights will only be available from 25 May 2018.
If you wish to exercise any of these rights, please send an email to firstname.lastname@example.org.
We hope that you won’t ever need to, but if you do want to complain about our use of personal data, please send an email with the details of your complaint to email@example.com. We will look into and respond to any complaints we receive.
You also have the right to lodge a complaint with the Information Commissioner’s Office (“ICO”) (the UK data protection regulator). For further information on your rights and how to complain to the ICO, please refer to the ICO website.