Privacy Policy
This Privacy Policy sets out the data processing practices carried out on any information we collect from visitors to our website, people who use our services, job applicants, contacts held for and on behalf of our clients and any person who contacts 23red either electronically or by traditional means.
Regardless of whose data 23red might hold, please be assured that it is treated with the same level of care and security as our own company data.
If you have any requests concerning your personal information or any queries with regard to these practices please contact our Data Protection Co-Ordinator at dataprotectionofficer@23red.com. Please note that all data thus captured will be used and held in accordance with the requirements of the UK General Data Protection Regulation (GDPR).
Visitors to our websites
Generally, when someone visits www.23red.com, it is done without having to provide any personal data about themselves. We do use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website.
This purpose is justified by our legitimate interest to make sure that your experience when visiting our webpage and interacting with us is optimal.
Contacts held for and on behalf of our clients
There may be times where we are required to hold personal data for and/or on behalf of our clients.
Where our clients are the Data Controller, and we are acting on their behalf, 23red will always follow the data principles and instructions provided by our clients to process data on their behalf. If you would like more information on this, please email dataprotectionofficer@23red.com and we can either direct you to our Client’s data privacy policy or we will liaise with our clients. The processing of data for this purpose is under a contractual basis for processing.
Where 23red might be the Data Controller, we will always seek your consent in advance of gathering, storing or processing data. In such instances, consent will be obtained via a consent form which will provide details about how your information will be used, stored, shared (if applicable) and how to withdraw consent. Consent can also be withdrawn by emailing dataprotectionofficer@23red.com). Generally your data will be retained for only as long as our campaign requires, but this will be advised on the consent form.
People who attend our events
We routinely host events, whether virtual or at our offices and you will be asked at the point of registration whether you would like to hear from us on our future marketing activities.
Where you opt in to these communications and have provided express consent, your details will remain on our secure marketing database for three (3) years from the last point of contact we make with you. If you would like to be removed from these database, then please email newbusiness@23red.com.
People who contact us via social media
If you send us a private or direct message via social media we will store your message and social media handle for one (1) year. Your information will not be shared with any other organisation.
Should we engage with you in response to your message, your information will be managed as appropriate depending on the nature of the continued communications. These purposes are justified by our legitimate interest to be able to respond to your message.
People who email us
We collect information from visitors to this website via a direct email link on our Connect webpage. We collect your details when you email us with an enquiry. We will only process these collected details for the purpose of dealing with your enquiries and requests. Emails will only be stored for 6 months, unless otherwise responded to for recruitment or business relationship purposes. These purposes are justified by our legitimate interest to be able to respond to your enquiry.
Our email traffic is monitored and protected through Mimecast. We monitor any emails sent to us which are received through Mimecast, including file attachments, for viruses and malicious software. Please be aware that you have a responsibility to ensure that any email you send it within the bounds of the law. Mimecast’s GPDR policy can be found here.
Job Applicants
23red is the Data Controller for the information you provide during the process unless otherwise stated.
All the information you provide during the process will only be used for the purpose of processing your application, or to fulfil legal or regulatory requirements if necessary. Our recruitment process is managed via Team Tailor, a third party platform whose Privacy Policy can be found at www.career.teamtailor.com/privacy-policy
Should you apply for a job or send your CV in and are unsuccessful in gaining employment with us, we will keep your application, CV and interview notes for a period of 7 months (unless we explicitly request to keep on file for future opportunities). These purposes are justified by our legitimate interest to be able to consider your job application.
Legitimate Interests
We have a number of lawful reasons that mean we can use (or 'process') your personal information. One lawful reason is something called 'legitimate interests'. Broadly speaking Legitimate Interests means we can process your personal information if:
We have a genuine and legitimate reason, and
We are not harming any of your rights and interests.
Such reasons may include for instance:
Where we have a shared business interest, including our partnership marketing work
To identify and prevent fraud
To enhance the security of our network and information systems
Whenever we process data for these purposes, we will ensure that we always keep your Personal Data rights in high regard and take account of these rights. You have the right to object to this processing if you wish, and please contact dataprotectionofficer@23red.com if you wish to do so. Please bear in mind that if you object, this may affect our ability to carry out tasks above for your benefit.
Your rights
Under UK GDPR, you hold several rights to the personal data we hold on you, including:
· to request that your personal data be rectified or deleted,
· to object to the processing or your personal data or to request restriction thereof; and
· to ask for to see what personal data we hold on you, and to receive it in a structured and standard format.
To obtain a copy of the personal information we hold about you, you can either:
· email at dataprotectionofficer@23red.com
· please write to us at: Data Compliance, 23red, Victoria House, 1 Leonard Circus, London, EC2A 4DQ
Disclosures
We rely on third-party suppliers and partners with which we may share your personal data for the purposes indicated above. Wherever we rely on such third parties, we make sure that they provide an adequate level of protection to the personal data they process on our behalf.
We will not share your data with third parties unless we are obliged to disclose personal data by law, legal process, litigation and/or requests from public of governmental authorities. We may also disclosure your personal data if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate.
Data Security
We use various technological and procedural security measures in order to protect the personal data we collect, use of transfer from loss, misuse, alteration or destruction. However, you should be aware that, due to the open and unsecured character of the Internet, 23red cannot be responsible for the security of transmissions of the personal data over the internet.
Other websites
Our website may contain links to other websites that are outside our control and are not covered by this Privacy Policy. 23red does not make any representations or warranties with respect to such third-party websites. If you access other sites using the links provided, the operators of these sites may collect information from you that will be used by them in accordance with their privacy policy, which may differ from ours and you should inform yourself of the privacy policies of such third-party websites.
Amendments
Please note that this privacy policy is subject to change from time to time. It was last updated in February 2024.