We are company number 10497682 registered in England and Wales. Our registered office is at 14 Homefield Park, Bodmin, United Kingdom, PL31 1DJ.
For the purpose of the General Data Protection Regulations (the GDPR), the Data Controller is Figure Fairy Ltd. Our nominated representative for the purpose of the Act and your point of contact for any enquiries or communications about this policy is Rachael Prideaux our Data Protection Officer. We have tried to make the Policy as easy to understand as possible, but please do contact us if you have any queries.
Your privacy is important to us
Collection of personal information
Personal information is anything which identifies you personally whether directly (e.g. your name, phone number, email address, postal address) or indirectly (e.g. information about your use of our services).
How we may collect your personal data
We obtain personal data about you, for example:
- when you request a proposal from us in respect of the services we provide;
- when you engage us to provide our services and also during the provision of those services;
- from third parties and / or publicly available resources (for example, from your employer or from Companies House);
- when you complete any of the forms on our website, e.g. contact forms, application forms, enquiry forms, testimonial forms, newsletter or any other subscription forms, etc.;
- when you use Facebook Messenger or Live Chat on our website;
- when you post any information on our website;
- when you email us, phone us, or contact us in any other way, including via social media.
In addition, we collect the information you give us about changes / updates to your personal information, contact preferences, etc, and when you report a problem with our website. The personally identifiable information could include, but is not restricted to: name, email address, telephone number, postal address, photos for promotional purposes, financial.
Information we collect / hold about you
The information we hold about you may include the following:
- your personal details (such as your name and / or address);
- details of contact we have had with you in relation to the provision, or the proposed provision, of our services;
- details of any services you have received from us;
- our correspondence and communications with you;
- information about any complaints and enquiries you make to us;
- information from research, surveys, and marketing activities;
- Information we receive from other sources, such as publicly available information, information provided by your employer or our clients or social media.
When you visit our website, we may automatically collect certain information. We use Google Analytics on our website.
This is information about your computer hardware and software, such as:
- your IP address, your login information, browser type, browser version, domain names, access times and time zone settings, browser plug-in types and versions, operating system and platform; referring website addresses.
Information about your visit to our website, such as:
- weblogs, length of visit, pages viewed, time on pages, flow through the website, the products or services you viewed or searched for, page response times, download errors, actions taken on the website (calls, links, downloads etc), page interaction information etc.
How we use your personal information
We may process your personal data for purposes necessary for the performance of our contract with you or your employer or our clients and to comply with our legal obligations.
We may process your personal data for the purposes necessary for the performance of our contract with our clients. This may include processing your personal data where you are an employee, subcontractor, supplier or customer of our client.
We may process your personal data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This includes processing for marketing, business development, statistical and management purposes.
We may process your personal data for certain additional purposes with your consent, and in these limited circumstances where your consent is required for the processing of your personal data then you have the right to withdraw your consent to processing for such specific purposes.
Please 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 data.
Situations in which we will use your personal data
We may use your personal data in order to:
- carry out our obligations arising from any agreements entered into between you and us (which will most usually be for the provision of our services);
- carry out our obligations arising from any agreements entered into between our clients and us (which will most usually be for the provision of our services) where you may be a subcontractor, supplier or customer of our client;
- provide you with information related to our services and our events and activities that you request from us or which we feel may interest you, provided you have consented to be contacted for such purposes;
- seek your thoughts and opinions on the services we provide;
- notify you about any changes to our services; and
- provide general statistics regarding the use of our website, in order to improve it in the future – legal basis: legitimate interests.
We will only ever use the information you have provided for the purpose it has been collected for. For example, if you provide us with your email address for a service enquiry, we will not add your email address to a newsletter database for email marketing, without your consent.
In some circumstances we may anonymise or pseudonymise the personal data so that it can no longer be associated with you, in which case we may use it without further notice to you.
If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered into with you. Alternatively, we may be unable to comply with our legal or regulatory obligations.
We may also process your personal data without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.
If you are an existing client, we use your information to provide you with information on relevant services, products and offers, given your consent. You have the right to ask us to stop contacting you for marketing purposes at any time. We do not sell, rent or lease our customer lists to third parties.
Data storage and retention
We will only retain your personal data for as long as is necessary to fulfill the purposes for which it is collected.
When assessing what retention period is appropriate for your personal data, we take into consideration:
- the requirements of our business and the services provided;
- any statutory or legal obligations;
- the purposes for which we originally collected the personal data;
- the lawful grounds on which we based our processing;
- the types of personal data we have collected;
- the amount and categories of your personal data; and
- whether the purpose of the processing could reasonably be fulfilled by other means.
If you send us an email or complete a form on our website, the information will be stored in our email system. If you enter information onto our website, such as registration / user information, comments / posts, this information will be stored in our WordPress database. If you subscribe to a newsletter on our website, this information will be held in Mailchimp, email marketing software. You may withdraw consent at any point, and we will remove your data. Any website transactional data will be stored in WordPress.
We retain your data for only as long as we need it to provide our products and services to you, and to fulfil any regulatory obligations. When your personal data is no longer required, we will delete it from our systems.
Change of purpose
Where we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal data where that reason is compatible with the original purpose.
Should it be necessary to use your personal data for a new purpose, we will notify you and communicate the legal basis which allows us to do so before starting any new processing.
Why might you share my personal data with third parties?
We will share your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so.
Which third-party service providers process my personal data?
“Third parties” includes third-party service providers. The following activities are carried out by third-party service providers: IT and cloud services, professional advisory services, administration services and marketing.
All of our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.
What about other third parties?
We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or to otherwise comply with the law.
We have put in place commercially reasonable and 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 data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Our website is protected by an SSL certificate. When installed on a web server, an SSL certificate activates the padlock and the https protocol and allows secure connections from a web server to a browser. (Typically, SSL is used to secure credit card transactions, data transfer and logins.)
We also have security plugins installed on our website carrying out regular monitoring and providing protection e.g. from unauthorised login attempts.
Transferring personal data outside the European Economic Area (EEA)
We use Xero Cloud Accounting Software, which holds our clients’ personal information on servers located in the United States of America (the U.S.)
Xero use top tier, third party data hosting providers’ (Rackspace, AWS, and Microsoft Azure) to host their services on servers located in the U.S. This means that your personal information will be transferred to the U.S.
Xero have in place transfer mechanisms with all their third-party data hosting providers that satisfy the requirements relating to their transfer of data from the European Union to the U.S.
By engaging with Figure Fairy Ltd, you consent to your personal information being hosted on servers located in the U.S. While your personal information will be stored on servers located in the U.S., it will remain within Xero’s effective control at all times. Each data hosting provider’s role is limited to providing a hosting and storage service to Xero, who have taken steps to ensure that their data hosting providers do not have access to, and use the necessary level of protection for, your personal information. They do not control and are not permitted to access or use your personal information, except for the limited purpose of storing the information.
If you do not want your personal information to be transferred to a server located in the U.S., you should not engage with Figure Fairy Ltd.
Your rights regarding your personal data
Under certain circumstances, by law you have the right to:
- Request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully.
- Request correction of the personal data that we hold about you.
- 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 exercised your right to object to processing (see below).
- 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible.
If you want to exercise any of the above rights, please email our data protection point of contact firstname.lastname@example.org.
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 for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose (for example, in relation to direct marketing that you have indicated you would like to receive from us), you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email our data protection point of contact email@example.com.
Once we have received notification that you have withdrawn your consent, we will no longer process your personal information (personal data) for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us, using the contact details below.
Links to other websites
If you have any questions regarding this notice or if you would like to speak to us about the manner in which we process your personal data, please email our Data Protection Point of Contact Mrs Rachael Prideaux at firstname.lastname@example.org.
You also have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, at any time. The ICO’s contact details are as follows:
Information Commissioner’s Office
Telephone – 0303 123 1113 (local rate) or 01625 545 745
Website – https://ico.org.uk/concerns
Published: May 2018