PRIVACY POLICY

https://www.10before.com/ (“our website”) is operated by 10Before Creative Services Ltd, a private limited company, incorporated and registered in England with company number 13480331, whose registered office is at 39 Egmont Street, Salford, Greater Manchester, United Kingdom, M6 7FJ, trading as 10Before (“we”, “us”, “our”).

“Personal Data” or “Personal Information” means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (“Anonymous Data”). 10Before respects your privacy and is committed to protecting your Personal Data. This policy explains how we look after your Personal Data when you visit our website and informs you about your privacy rights.

BY CONTINUING TO BROWSE OUR WEBSITE, YOU ARE AGREEING TO OUR PRIVACY POLICY

CONTENTS

Introduction
Controller
The Data we Collect about you
How Your Personal Data is Collected
Third Party Links
Purposes for which we will use your Personal Data
Change of Purpose
Disclosures of your Personal Data
Marketing and Promotional Offers from us
Our use of Cookies
Data Security
Data Retention
Your Legal Rights
Requesting access to your Personal Data

INTRODUCTION
1. It is important that you read this Privacy Policy, together with any other privacy policy or fair processing policy that 10Before may provide on specific occasions when collecting or processing Personal Data about you, so that you are fully aware of how and why we are using your data.
2. This Privacy Policy supplements other notices and policies and is not intended to override them.
3. We keep our Privacy Policy under regular review. This version was last updated on 28 July 2021.

CONTROLLER
1. 10Before is the controller and is responsible for your Personal Data.
2. We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy or our privacy practices, including any requests to exercise your legal rights, please contact the DPO using the details set out below:
  1. The DPO: Tony Hutchinson.
  2. Email address: tony@10before.com.
  3. Postal address: 39 Egmont Street, Salford, Greater Manchester, United Kingdom, M6 7FJ.
3. It is important that the Personal Data we hold about you is accurate and current. Please keep 10Before informed if your personal information changes during your relationship with us.
4. 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). Our ICO registration number is ZB174244. We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

THE DATA WE COLLECT ABOUT YOU
1. 10Before may process your Personal Data without your knowledge or consent where this is required or permitted by law.
2. We may collect, use, store, and transfer different kinds of Personal Data about you which we have grouped together as follows:
  1. “Identity Data” includes first name, maiden name, last name, or similar identifier, marital status, title, date of birth, and gender.
  2. “Contact Data” includes billing address, delivery address, email address, and telephone numbers.
  3. “Financial Data” includes bank account and payment card details.
  4. “Transaction Data” includes details about payments to and from you, and other details of [products][or][services] you have purchased from us.
  5. “Technical Data” includes internet protocol address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website.
  6. “Profile Data” includes purchases, and orders made by you, and your interests, preferences. The majority of this comes from feedback via our contact form.
  7. “Usage Data” includes information about how you use our website, products, and services.
  8. “Marketing and Communications Data” includes your preferences in receiving Marketing from 10Before and our third parties, and your communication preferences.
  9. We also collect, use, and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data could be derived from your Personal Data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data, which will be used in accordance with this Privacy Policy.
3. We do not collect, use, store, or transfer the following kinds of Personal Data about you:
  1. We do not collect any “Special Categories of Personal Data” about you. This includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health, and genetic and biometric data. Nor do we collect any information about criminal convictions and offences.
  2. Our website is not intended for children and we do not knowingly collect data relating to children.

HOW YOUR PERSONAL DATA IS COLLECTED
1. 10Before use different methods to collect data from and about you:
  1. You may give us your Identity, Contact, and Financial Data through direct interactions. For example, by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes Personal Data you provide when you:
    1. Apply for our products or services.
    2. Create an account on our website.
    3. Subscribe to our service or publications.
    4. Request Marketing to be sent to you.
    5. Enter a competition, promotion, or survey.
    6. Give us feedback or contact us.
  2. We may collect Personal Data through automated technologies and interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions, and patterns. This Personal Data is collected by using cookies, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
  3. We will receive Personal Data about you from various third parties and public sources, as set out below:
    1. Analytics providers (such as Google) based outside the EU.
    2. Identity Data and Contact Data from publicly available sources (such as Companies House and the Electoral Register).

THIRD PARTY LINKS
1. Our website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you.
2. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

PURPOSES FOR WHICH WILL USE YOUR PERSONAL DATA
1. 10Before will only use your Personal Data when the law allows us to. Most commonly we will use your Personal Data in the following circumstances:
  1. Where we need to perform a contract we are about to enter into or have entered into with you, or to take steps at your request before entering into such a contract (“Performance of a Contract”).
  2. Where it is necessary for the interest of our business or those of a third party in conducting and managing our business, to enable us to give you the best service or product and the best and most secure experience (“Legitimate Interests”), and your interests and fundamental rights do not override those interests. We always consider your rights and balance any potential impact on you (both positive and negative) before we process your Personal Data for 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. You can contact us to obtain further information about how we assess our Legitimate Interests against any potential impact on you in respect of specific activities.
  3. Where it is necessary for compliance with a legal obligation that we are subject to (“Comply with a Legal Obligation”).
2. 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, and as a result, 10Before may be unable to provide you with a product or service. In this case, we may have to cancel any product or service you have with us, but we will notify you if this is the case at the time.
3. We may use your Identity, Contact, Technical, Usage, and Profile Data to form a view on what we think you may want or need or what may be of interest to you. This is how we decide which products, services, and offers may be relevant for you (“Marketing”).
4. The remainder of this clause sets out a description of all the ways 10Before plan to use your Personal Data and which of the legal bases we rely on to do so. We have also identified what our Legitimate Interests are where appropriate. Please note that we may process your Personal Data for more than 1 lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Data, where more than 1 ground has been set out below.
5. We will use your identity data and contact data to register you as a new customer. Our lawful basis for processing this data is the performance of a contract with you.
6. We will use your (a) Identity Data, (b) Contact Data, (c) Financial Data, (d) Transaction Data, and (e) Marketing and Communications Data to process and deliver your order, including managing payments, fees, and charges and collecting and recovering money owed to us. Our lawful basis for processing this data is (1) the performance of a contract with you, and (2) necessary for our Legitimate Interests (to recover debts due to us).
7. We will use your (a) Identity Data, (b) Contact Data, (c) Profile Data, and (d) Marketing and Communications Data to manage our relationship with you, which will include notifying you about changes to our terms or website policies and asking you to leave a review or take a survey. Our lawful basis for doing this is (1) performance of a contract with you, (2) that this is necessary to comply with a Legal Obligation, and (3) that this is necessary for our Legitimate Interests (to keep our records updated and to study how customers use our products or services).
8. We use your (a) Identity Data, (b) Contact Data, (c) Profile Data, (d) Usage Data, and (e) Marketing and Communications Data to enable you to partake in a prize draw, competition, or complete a survey. Our lawful basis for doing this is (1) performance of a contract with you, and (2) that this is necessary for our Legitimate Interests (to study how customers use our products or services, to develop them, and grow our business.
9. We use your (a) Identity Data, (b) Contact Data, (c) Technical Data to administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data. Our lawful basis for doing this is (1) that it is necessary for our Legitimate Interests (for running our business, provision of administration and IT services, network security, to prevent fraud, and in the context of a business reorganisation, or group restructuring exercise), and (2) that it is necessary to comply with a Legal Obligation.
10. We use your (a) Identity Data, (b) Contact Data, (c) Profile Data, (d) Usage Data, (e) Marketing and Communications Data, and (f) Technical Data to deliver relevant website content and advertisements to you, and measure or understand the effectiveness of the advertising we serve to you. Our lawful basis for doing this is that it is necessary for our Legitimate Interests (to study how customers use our products or services, to develop them, to grow our business, and to inform our Marketing strategy).
11. We use (a) Technical Data, and (b) Usage Data to use data analytics to improve our website, products or services, Marketing, customer relationships, and experiences. Our lawful basis for doing so is that it is necessary for our Legitimate Interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business, and to inform our Marketing strategy).
12. We use your (a) Identity Data, (b) Contact Data, (c) Technical Data, (d) Usage Data, (e) Profile Data, (f) Marketing and Communications Data to make suggestions and recommendations to you, about goods or services that may be of interest to you. Our lawful basis for doing so is that this is necessary for our Legitimate Interests (to develop our products or services and grow our business).

CHANGE OF PURPOSE
1. 10Before will only use your Personal Data for the purposes for which it was collected, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to know how the processing for the new purpose is compatible with the original purpose, please contact our DPO.
2. If we need to use your Personal Data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.

DISCLOSURES OF YOUR PERSONAL DATA
1. For the purposes set out in clause 6, 10Before may share your Personal Data with third parties, including and without limitation:
  1. Internal third parties, such as consultants who may, from time to time, assist us in completing work for you acting as joint controllers or processors and who are based both inside and outside of the EU and provide services to us not dissimilar to those we provide to you.
  2. External third parties, including, but not limited to:
    1. Professional advisers acting as processors or joint controllers, including (without limitation) lawyers, bankers, auditors, and insurers, based in the United Kingdom and who provide services including (but not limited to) consultancy, banking, legal, insurance, and accounting services.
    2. Regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances, such as (for illustration) HM Revenue & Customs.
  3. Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business then the new owners may use your Personal Data in the same way as set out in this Privacy Policy.
2. 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.
3. We do not transfer your Personal Data outside the European Economic Area.

MARKETING AND PROMOTIONAL OFFERS
1. 10Before strive to provide you with choices regarding certain Personal Data uses, particularly around Marketing and advertising. Generally, we do not rely on consent as a legal basis for processing your Personal Data, although we will get your express opt-in consent before sharing your Personal Data with a third party for Marketing purposes, and before sending third party direct Marketing communications to you via email or text message.
2. You have the right to withdraw consent to Marketing at any time by emailing tony@10before.com.
3. You will receive Marketing communications from 10Before if you have requested information from us or purchased services from us and you have not opted out of receiving that Marketing.
4. You can ask us, or third parties, to stop sending you Marketing messages at any time by emailing tony@10before.com.
5. Where you opt-out of receiving these Marketing messages, this will not apply to Personal Data provided to us as a result of a product or service purchase, warranty registration, product or service experience, or other transactions.

OUR USE OF COOKIES
1. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly.
2. For more information about the cookies we use, please see our Cookies Policy.

DATA SECURITY
1. 10Before have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, altered, disclosed, or used or accessed in an unauthorised way.
2. In addition, we limit access to your Personal Data to those employees, agents, contractors, and other third parties who have a business need-to-know. They will only process your Personal Data on our instructions and are subject to a duty of confidentiality.
3. We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of any breach where we are legally required to do so.

DATA RETENTION
1. 10Before will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements.
2. We may retain your Personal Data for a longer period in the event of a complaint, or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
3. To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data; the potential risk of harm from unauthorised use or disclosure of your Personal Data; the purposes for which we process your Personal Data and whether we can achieve those purposes through other means; and the applicable legal, regulatory, tax, accounting, or other requirements.
4. By law, we must keep basic information about our customers (including Contact, Identity, Financial, and Transaction Data) for tax purposes, for 6 years after they cease being customers.
5. In some circumstances, you can ask us to delete your data. See clause 13 for further information in relation to your legal rights.
6. In some circumstances, we will anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes. In which case, we may use this information indefinitely without further notice to you.

YOUR LEGAL RIGHTS
1. Under certain circumstances, you have rights under data protection laws in relation to your Personal Data, specifically:
  1. You have 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.
  2. You have the right to request correction of your Personal Data. This enables you to have corrected any incomplete or inaccurate data we hold about you, though we may need to verify the accuracy of the new data you provide to us.
  3. You have the right to request erasure of your Personal Data. This enables you to ask us to delete or remove any 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, where we may have processed your information unlawfully, or where we are required to erase your Personal Data to comply with local law. Please note that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you at the time of your request.
  4. You have the right to 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 ground 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.
  5. You have the right to request restriction of processing your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios:
    1. If you want us to establish the data’s accuracy.
    2. Where our use of the data is unlawful, but you do not want us to erase it.
    3. Where you need us to hold the data, even if we no longer require it, as you need it to establish, exercise, or defend legal claims.
    4. You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
  6. You have the right to request transfer of your Personal Data to you or a third party. We will provide to you or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Please note, 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.
  7. You have the right to withdraw consent where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case, at the time you withdraw your consent
2. If you wish to exercise any of the rights set out above, please contact our DPO.

REQUESTING ACCESS TO YOUR PERSONAL DATA
1. You will not have to pay a fee to access your Personal Data or to exercise any of the other rights. However, 10Before may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
2. 10Before 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. 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.
3. We try to respond to all legitimate requests as soon as possible. However, it could take us longer if your request is particularly complex or you have made several requests. In this case, we will notify you and try to keep you updated.

BY CONTINUING TO BROWSE OUR WEBSITE, YOU ARE AGREEING TO OUR PRIVACY POLICY

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