Creative Sensemaking Limited
Privacy Notice



We are committed to respecting your privacy. This notice explains how we comply with the law on data protection. References to we, our or us in this privacy notice are to Creative Sensemaking Limited (“sensemaking”) - a registered company.
For the purposes of data protection, we are the controller of any of your personal information.
We have not appointed a Data Protection Officer to oversee our compliance with data protection laws as we not required to do so, but our Data Protection Compliance Manager has overall responsibility for data protection compliance in our organisation. Contact details are set out in the "Contacting us" section at the end of this privacy notice.

1.         Personal Information we may collect from you


In the course of our business, we shall collect and process personal information about you, such as information regarding your:


We shall collect and process your personal data to the extent that it is required to fulfil our operational and contractual needs.

We shall only process your personal information for advertising and marketing of our services and/or our partners and affiliates based on your explicit consent. You are entitled to opt out of these services at any time by contacting us by email.


2.         Where we collect your information


We typically collect personal information when you apply to become a member of the Sensemaking Partner Network, when you purchase any services or products we offer, when you register to attend a sensemaking event, when you make a query and/or complaint or when you correspond with us by phone, e-mail or in some other way.


3.         Uses made of the information


The table below describes the main purposes for which we process your personal information, the categories of your information involved and our lawful basis for being able to do this.

Purpose

Personal information used

Lawful basis

To arrange and manage any contracts for the provision of any services or products

Contact details, transaction and payment information.

Records of your interactions with us.

This is necessary to enable us to properly administer and perform any contract for the provision of any services and products you have purchased from us.

To send you information which is included within your membership benefits package.

Contact and membership details.

This is necessary to enable us to properly manage and administer your membership contract with us.

To send you other marketing information we think you might find useful or which you have requested from us, including our newsletters, information about membership, events, products and training courses.

Contact details and marketing preferences.

Where you have given us your explicit consent to do so.

To answer your queries or complaints

Contact details and records of your interactions with us.

We have a legitimate interest to provide complaint handling services to you in case there are any issues with your membership.

The security of our IT systems

Your usage of our IT systems and online portals.

We have a legitimate interest to ensure that our IT systems are secure.

Retention of records

All the personal information we collect.

We have a legitimate interest in retaining records whilst they may be required in relation to complaints or claims.
We need to retain records in order to properly administer and manage your membership and in some cases we may have legal or regulatory obligations to retain records.

For the purposes of promoting sensemaking, our events and membership packages.

Images in video and/or photographic form.

Where you have given us your explicit consent to do so.

To administer your attendance at any courses or programmes you sign up to

All contact and membership details.

Transaction and payment data.

This is necessary to enable us to register you on to and properly manage and administer your attendance on the course and/or programme.

                
For some of your personal information you will have a legal, contractual or other requirement or obligation for you to provide us with your personal information.  If you do not provide us with the requested personal information we may not be able to admit you as a member or we may not be able to properly perform our contract with you or comply with legal obligations and we may have to terminate your membership.  For other personal information you may not be under an obligation to provide it to us, but if you do not provide it then we may not be able to properly perform our contract with you.


Where you have given us your consent to use your personal information in a particular manner, you have the right to withdraw this consent at any time, which you may do by contacting us as described in the "Contacting us" section below.


Please note however that the withdrawal of your consent will not affect any use of the data made before you withdrew your consent and we may still be entitled to hold and process the relevant personal information to the extent that we are entitled to do so on bases other than your consent.  Withdrawing consent may also have the same effects as not providing the information in the first place, for example we may no longer be able to provide certain member benefits to you.

4.         Direct Marketing


From time to time, we may contact you by email, post or SMS with information about products and services we believe you may be interested in.
We will only send marketing messages to you in accordance with the marketing preferences you set. You can then let us know at any time that you do not wish to receive marketing messages by emailing us at dave@sensemaking.co.uk. You can also unsubscribe from our marketing by clicking on the unsubscribe link in the marketing messages we send to you.


5.         Disclosure of your personal information


We share personal information with the following parties:


We use cloud providers to store and manage your personal data including Microsoft, Dropbox, Squarespace, Mail Chimp

.


6.         Transferring your personal information internationally


The personal information we collect is held on cloud services and may be transferred to and stored in countries outside of the UK and the European Union. Some of these jurisdictions require different levels of protection in respect of personal information and, in certain instances, the laws in those countries may be less protective than the jurisdiction you are typically resident in. We will take all reasonable steps to ensure that your personal information is only used in accordance with this privacy notice and applicable data protection laws and is respected and kept secure and where a third part processes your data on our behalf we will put in place appropriate safeguards as required under data protection laws.


7.         How long do we keep personal information for?


The duration for which we retain your personal information will differ depending on the type of information and the reason why we collected it from you. However, in some cases personal information may be retained on a long-term basis: for example, personal information that we need to retain for legal purposes will normally be retained in accordance with usual commercial practice and regulatory requirements.  Generally, where there is no legal requirement we retain all physical and electronic records for a period of 6 years after your last contact with us or the end of your membership.


It is important to ensure that the personal information we hold about you is accurate and up-to-date, and you should let us know if anything changes, for example if you change your phone number or email address by contacting us using the details set out in the "Contacting us" section below.


8.         Your rights in relation to personal information


You have the following rights in relation to your personal information:

You should note that some of these rights, for example the right to require us to transfer your data to another service provider or the right to object to automated decision making, may not apply as they have specific requirements and exemptions which apply to them and they may not apply to personal information recorded and stored by us.  For example, we do not use automated decision making in relation to your personal data.  However, some have no conditions attached, so your right to withdraw consent or object to processing for direct marketing are absolute rights.

Whilst this privacy notice sets out a general summary of your legal rights in respect of personal information, this is a very complex area of law. More information about your legal rights can be found on the Information Commissioner’s website at
https://ico.org.uk/for-the-public/


To exercise any of the above rights, or if you have any questions relating to your rights, please contact us by using the details set out in the "Contacting us" section below.


If you are unhappy with the way we are using your personal information you can also complain to the UK Information Commissioner’s Office or your local data protection regulator. We are here to help and encourage you to contact us to resolve your complaint first.



9.       Changes to this notice


We may update this privacy notice from time to time. When we change this notice in a material way, we will update the version date at the bottom of this page. For significant changes to this notice we will try to give you reasonable notice unless we are prevented from doing so. Where required by law we will seek your consent to changes in the way we use your personal information.

 
10.           Contacting us


To contact us about changes in your personal information, or in the event of any query, or complaint in connection with the information we hold about you, please contact us by email at
dave@sensmaking.co.uk