Privacy Policy

PRIVACY NOTICE – CHAMELEON SOCIAL
 
INTRODUCTION  
 
Welcome to our privacy notice.
 
We respect your privacy and are committed to protecting your personal data. This privacy notice will
inform you as to how we look after your personal data when you visit our website (regardless of where
you visit it from) and tell you about your privacy rights and how the law protects you. 
  
1.  IMPORTANT INFORMATION AND WHO WE ARE  
 
PURPOSE OF THIS PRIVACY NOTICE  
 
This privacy notice aims to give you information on how we collect and process your personal data
through your use of this website, including any data you may provide through this website when you
sign up to our newsletter or take part in a competition.
 
This website is not intended for children and we do not knowingly collect data relating to children.
 
It is important that you read this privacy notice together with any other privacy notice or fair
processing notice we may provide on specific occasions when we are collecting or processing personal
data about you so that you are fully aware of how and why we are using your data. This privacy notice
supplements the other notices and is not intended to override them.
 
CONTROLLER  
 
Laura Simpson is the controller and responsible for your personal data (collectively referred to as “we”,
“us” or “our” in this privacy notice).
  
Laura Simpson is  responsible for overseeing questions in relation to this privacy notice, including any requests to exercise your legal rights, please contact Laura at hello@chameleonsocial.co.uk 
 
CONTACT DETAILS  
 
Our contact details are set out in table 1 below:

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.
 
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES  
 
This version was last updated in September 2019.
  
It is important that the personal data we hold about you is accurate and current. Please keep us
informed if your personal data changes during your relationship with us.
 
THIRD-PARTY LINKS  
 
This 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. 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 notice of every website you visit.
 
2.  THE DATA WE COLLECT ABOUT YOU  
 
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).
 
We may collect, use, store and transfer different kinds of personal data about you which we have
grouped together in table 2 below:

 

We also collect, use and share Aggregated Data such as statistical or demographic data for any
purpose. Aggregated Data may be derived from your personal data but is not considered personal data
in law as this data does 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 notice.
 
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, information about your health and genetic and biometric data). Nor do we 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 provide you with goods or services). In this case, we
may have to cancel a product or service you have with us but we will notify you if this is the case at the
time.
 
3.  HOW IS YOUR PERSONAL DATA COLLECTED?  
 
We use different methods to collect data from and about you, as set out in table 3 below:
 

 
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 consented for us to do so.
• Where we need to perform the contract we are about to enter into or have entered into with you.
• 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 comply with a legal or regulatory obligation.
See table 4 below to find out more about the types of lawful basis that we will rely on to process your
personal data. 


PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA  
 
We have set out below in table 4 a description of all the ways we 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.
 
Note that we may process your personal data for more than one lawful ground depending on the
specific purpose for which we are using your data. Please contact us via email at
hello@chameleonsocial.co.uk
or via the Get In Touch page on our website if you need details about the specific legal ground we are
relying on to process your personal data where more than one ground has been set out in table 4
below:

 

MARKETING  
 
We strive to provide you with choices regarding certain personal data uses, particularly around
marketing and advertising.
 
PROMOTIONAL OFFERS FROM US  
 
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 (we call this marketing).
 
You will receive marketing communications from us if you have requested information from us or
purchased goods or services from us or if you provided us with your details when you entered a
competition or registered for a promotion and, in each case, you have not opted out of receiving that
marketing.
 
THIRD-PARTY MARKETING  
We will get your express opt-in consent before we share your personal data with any company for
marketing purposes.
 
OPTING OUT  
 
You can ask us or third parties to stop sending you marketing messages at any time by:
 by following the opt-out links on any marketing message sent to you; or
 by contacting us via email at hello@chameleonsocial.co.uk or via the Get In Touch page on our
website at any time.
 
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/service purchase, warranty registration, product/service
experience or other transactions.
 
COOKIES  
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 this website may
become inaccessible or not function properly. For more information about the cookies we use, please
see our Cookie Policy.


CHANGE OF PURPOSE  
 

We will only use your personal data for the purposes for which we collected it, 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 get an explanation as to how the processing for the new purpose is compatible
with the original purpose, please contact us via email at hello@chameleonsocial.co.uk or via the Get In
Touch page on our website.
 
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 have to share your personal data with the parties set out in table 5 below for the purposes set
out in the table in paragraph 4 above.

We may also share your personal data with 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 notice.
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  
  
Some of our external third parties are based outside the European Economic Area (EEA) so their
processing of your personal data will involve a transfer of data outside the EEA.
 
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is
afforded to it by ensuring at least one of the following safeguards is implemented:

 
• We will only transfer your personal data to countries that have been deemed to provide an
adequate level of protection for personal data by the European Commission. For further details,
see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the European
Commission which give personal data the same protection it has in Europe. For further details, see
European Commission: Model contracts for the transfer of personal data to third countries.
• Where we use providers based in the US, we may transfer data to them if they are part of the
Privacy Shield which requires them to provide similar protection to personal data shared between
the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us via email at hello@chameleonsocial.co.uk or via the Get In Touch page on our
website if you want further information on the specific mechanism used by us when transferring your
personal data out of the EEA.
 
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. 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 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.  DATA RETENTION  
 
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?  
 
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for,
including for the purposes of satisfying any legal, accounting, or reporting requirements.
 
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 requirements.
 
By law we have to keep basic information about our customers (including Contact, Identity and
Transaction Data) for six (6) years after they cease being customers for tax purposes.
 
In some circumstances you can ask us to delete your data: see Request erasure below for further
information.
 
In some circumstances we may 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.
 
9.  YOUR LEGAL RIGHTS  
 
Under certain circumstances, you have rights under data protection laws in relation to your personal
data. Please see below to find out more about these rights:
 
• 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.
• Request correction of your personal data that we hold about you. This enables you to have any
incomplete or inaccurate 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 local law. Note, however, that
we may not always be able to comply with your request of erasure for specific legal reasons which
will be notified to you, if applicable, at the time of your request.
• 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.
• 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: (a) if you want us to establish the
data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c)
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; or (d) you have objected to our use of your data but we need to
verify whether we have overriding legitimate grounds to use it.
• Request transfer of your personal data to you or to 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. 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
• Right to 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 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.
If you wish to exercise any of the rights set out above, please contact us via email at
hello@chameleonsocial.co.uk or via the Get In Touch page on our website.
 
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).
However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.
Alternatively, we may refuse to comply with your request in these circumstances.
 
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). 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 may 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.

 

Nottingham, UK

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