Anne du Boucheron, Inc. (d/b/a A Creative Partner) respects your privacy and is committed to protecting your personal data. We only ask for personal information when we truly need it to provide a service to you. We collect it by fair and lawful means, with your knowledge and consent. We also let you know why we’re collecting it and how it will be used.

THE PURPOSE OF THIS PRIVACY POLICY

This privacy notice aims to give you information on how we collect and process your personal data through your use of our site, including any data you may provide through our site when you sign up to our newsletter, purchase a service or register an account with us. Our site is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this Privacy Policy 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. Except as set out in this Privacy Policy, we don’t share any personally identifying information publicly or with third-parties, except when required to by law.

WE MAY COLLECT THE FOLLOWING INFORMATION:

• Your name, company and job title
• Contact information including your email address, postal address and telephone number
• Demographic information such as postcode, and interests
• Any photos that you submit for agency consideration or archival purposeslegally required to do so.

WE COLLECT THIS DATA FROM YOU ON AT LEAST ONE OF THE FOLLOWING LEGAL BASES:

• That you have provided your consent for us to do so or have signed up to our newsletter.
• That we need to in order to fulfill our contractual obligations to you or to take steps to enter into a contract with you (which includes the provision of quotations or estimates as a result of a request from you).
• That we have a legitimate interest in doing so for our own commercial marketing activities where our use of your data is appropriate, has a minimal impact on your privacy and is an activity that you might reasonably expect us to be engaged in.

HOW IS THIS PERSONAL DATA COLLECTED?

• Direct interactions with you via email, telephone, our website or post including if you sign up for our newsletters, give us feedback or otherwise.
• Automated technologies or interactions. As you interact with our website, it may automatically collect information - including but not limited to Internet browser, operating system, device and application identifiers, IP address and geo-location information, access times and dates, referring and exit pages and URLs, clickstream data, search terms, pages viewed, time spent on pages, bounce rate and login frequency. We collect this personal data by using cookies, and other similar technologies.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL INFORMATION:

We set out above a description of the ways we plan to use your data (such as for the performance of a contract, to send you marketing information with your consent, respond to queries). We also identified the lawful bases on which rely in doing so.

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 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.

YOUR RIGHTS AND CONTROLLING YOUR PERSONAL INFORMATION:

You have the right to withdraw consent to marketing at any time by unsubscribing from our newsletters. You can also choose to restrict the collection or use of your personal information by contacting us.

• Right to withdraw consent, data retention and the right to be forgotten - If you have previously agreed to us using your personal information for direct-marketing purposes, you may change your status at any time by emailing us on hello@acreativepartner.co. We will comply with your request within one month of receiving it. Please note, there may be certain circumstances such as a legal obligation we may have, that mean the right to be forgotten cannot be implemented. We will inform you of this should you contact us on this basis.
• Right to object to processing of your data – You have a right to object to us using your data for marketing under the basis of ‘legitimate interests.’ If you wish to do so, please email us on hello@acreativepartner.co. We will consider your request and whether your legitimate interests outweigh ours and respond promptly.

We will only retain your personal information for the minimum time that is necessary. For some purposes such as our business accounting obligations, this length of time will be determined by legislation. We will keep this under review and adapt it as necessary.

If the processing of personal data about you is subject to European Union data protection law, you have certain rights with respect to that data:

• You can request access to, and rectification or erasure of, personal data;
• If any automated processing or personal data is based on your consent or a contract with you, you have a right to transfer or receive a copy of your personal data in a usable and portable format;
• If the processing of personal data is based on your consent, you can withdraw consent at any time for future processing;
• For resident of France, you can send us specific instructions regarding the use of your data after your death.

Your continued use of our website will be regarded as acceptance of our practices around privacy and personal information. If you have any questions about how we handle user data and personal information, feel free to email us on hello@acreativepartner.co.

DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out above:

• Internal third parties such as our employees or officers within A Creative Partner;
• External third parties including specialist IT support, suppliers and sub-contractors for the performance of this site, our applications and any contract we enter into with them or you including our professional advisers, IT support provider, Mail Chimp and other third party partners for marketing and promotional purposes for our own internal business purposes;
• 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.

INTERNATIONAL TRANSFERS

We share your personal data within A Creative Partner. This will involve transferring your data outside the European Economic Area (EEA). Many countries to which we may transfer your personal data outside of the EEA do not have an adequate level of protection for personal data approved by the European Commission. However, within A Creative Partner and where we use certain service providers or partners, 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 or another mechanism such as Privacy Shield. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

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.

SECURITY

We are committed to ensuring that your information is secure. In order to prevent unauthorized access or disclosure we have put in place appropriate physical, electronic and managerial procedures to safeguard and secure the information we collect online. 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.

A Creative Partner reserves the right to change this policy including by updating this page, as it sees fit. We encourage you to check this page regularly to ensure your understanding and continued acceptance with our policy.