This statement sets out the privacy and data protection policies of Team Commando Spirit. All references to ‘our’, ‘us’ or ‘we’ within this policy are deemed to refer to Team Commando Spirit.
The Team Commando Spirit is a data controller. This means that we are responsible for deciding how we hold and use personal information about our Data Subjects. As an organisation registered and operating in the European Union, we are obligated to comply with the General Data Protection Regulation ((EU) 2016/679) (GDPR). These obligations extend to all individuals for which we hold personal data, including those based outside of the EU.
Data Protection Principles
We will comply with data protection law and principles, which means that your data will be:
- Used lawfully, fairly and in a transparent way
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes
- Relevant to the purposes we have told you about and limited only to those purposes
- Accurate and kept up to date
- Kept only as long as necessary for the purposes we have told you about
- Kept securely
The Personal Information We May Hold 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). There are “special categories” of more sensitive personal data which require a higher level of protection. In the course of activities covered by this privacy statement, we may collect, store, and use the following categories of personal information about you.
Your basic contact details, including:
- Your name
- Phone number
- Postal address
- Information about your company
- Job title
Records of your activity with Team Commando Spirit:
- Customer support queries and correspondence
- Any consent for further marketing communications and preferences
- Cookies to collect and store information relating to your usage of our website and web applications
How We May Collect Your Personal Information
Team Commando Spirit may collect information about you in the following ways:
- When you subscribe to our email marketing and/or provide your marketing preferences
- When you contact us via phone or email
- During general use of our website and web applications, via cookies
- Research or other data validation activities to ensure that the personal information we hold is correct and up to date – this may add to and augment the personal information originally provided
How We May Use Your Personal Information
Team Commando Spirit will use your personal information to provide services to you. You can request that we suspend our use of your personal data for these purposes at any time, although we may need to consider the rights and freedoms of other data subjects and our own obligations.
We will seek your explicit (opt-in) consent to be contacted by Team Commando Spirit, covering:
- Direct marketing communications about Team Commando Spirit and its services that may be of interest to you or your business
- Using your quotes, likeness or otherwise for case studies produced for Public Relations purposes
- Sharing your personal data with third parties beyond those specified in the section Third-Party Service Providers Processing Your Personal Information – you may withdraw this consent at any time
How We Will Store Your Personal Information
Team Commando Spirit takes the security of personal data extremely seriously, and has obligations under GDPR to provide appropriate protections for all the personal data it holds.Where necessary, and in common with other websites, we use SSL (Secure Sockets Layer) encryption to ensure that information provided to us is not visible to anybody else when in transit between your computer and our servers. You can tell when SSL is in use by the presence of a small “padlock” symbol in the status bar of your web browser.
Third-Party Service Providers Processing Your Personal Information
Team Commando Spirit uses several third-party service providers for activities including data hosting, storage and processing. All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
The third-party service providers that will process your personal data will likely include the following:
- MailChimp (where you have subscribed to our email marketing)
- Google LLC (email and shared document provider, website analytics)
- Social and other channels such as but not limited to Facebook, Instagram, LinkedIn, Google Adwords (online advertising)
We will have appropriate data sharing agreements with all third-party service providers. Any data processing services that are located in the US will be certified under the Privacy Shield agreement (https://www.privacyshield.gov/).
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We will only retain your personal information 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. Generally we will keep your personal data for up to ten years after your most recent activity with us (invoices). After this period, your personal data will be removed from our systems and files.
Rights of Access, Correction, Erasure and Restriction
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information 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. 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 information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact Team Commando Spirit in writing using the details in the section
Contacting Us Regarding Your Personal Information
You will not have to pay a fee to access your personal information (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.
Contacting Us Regarding Your Personal Information
If you have any questions about this privacy notice, or how we handle your personal information, please contact our Project Lead, Christine Madden, via email@example.com.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the supervisory authority for data protection issues in the UK, or your local supervisory authority if you are located in another European Union member state.