Privacy policy.

Last updated: 26 May 2022


Create Flow Limited (“we”, “us”) are committed to data security and the fair and transparent processing of personal data. We take safeguarding online privacy seriously.  

This Policy (together with our Terms of Service and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the whole of this policy carefully to understand our views and practices regarding personal data and how we will treat it, alongside your rights in respect of our use. It also contains information on how to contact us and how to contact supervisory authorities in the event that you would like to report a concern about the way in which we process your personal data.

From time to time, we may need to change our privacy statement because of changes in our organisation, legislation or in our attempts to serve your needs better. We will use reasonable efforts to publish any changes to our privacy statement. 

Create Flow is the trading name for Create Flow Limited, a company incorporated and registered in England and Wales with company number 1306845. Create Flow Limited is responsible for collecting, processing, storing and safe-keeping personal and other information as part of providing a service and carrying out our regular business activities. We manage personal information in accordance with the Data Protection Act 2018.

We are registered as a Data Controller with the Information Commissioner’s Office (the “ICO”) under registration number: CSN3959211

Any questions regarding our processing of personal data should be directed to us via email to info@wearecreateflow.com 


INFORMATION COLLECTED

The information we may collect about you could include, but is not limited to:

    1. Personal details

    2. Family details

    3. Lifestyle and social circumstances

    4. Financial details

    5. Physical or mental health details

    6. Racial or ethnic origin

We will collect information from you when:

    1. You sign up to our newsletter or mailing list

    2. You download an opt-in

    3. You purchase a product from our website

    4. You join a course or programme

    5. You contact us for information via our website or social media channels, by phone or email

    6. You post on our social media channels, website or blog

    7. You work with us in a commercial capacity

We may use the information collected to:

    1. Allow you to process a booking for a product or course

    2. Send you our newsletters or provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes

    3. Ensure that content from our site is presented to you in the most effective manner for you and your computer

    4. Allow you to participate in the service you have chosen to do so

    5. Notify you about changes to our service

We will not, without your permission, sell, publish or share any information you entrust to us that identifies you or any person. 


LEGAL BASIS FOR PROCESSING YOUR DATA

Under the General Data Protection Regulation (GDPR), the lawful bases we rely on for processing this information are:

    1. You have consented. You are able to remove your consent at any time. You can do this by contacting info@wearecreateflow.com

    2. We have a contractual obligation

    3. We have a legal obligation.

    4. We have a vital interest

    5. We need it to perform a public task

    6. We have a legitimate interest.

We collect data for the purposes set out above. Data is managed to ensure that it is either erased from our system when it is no longer required for the purpose for which it was collected, retained for legal reasons or minimised and retained. 

Any health data collected from you has special protection and is limited to that permissible by law. 

STORING YOUR PERSONAL DATA

The information you provide will be kept confidential. We have in place administrative, technical and physical measures designed to guard against and minimise the risk of loss, misuse or unauthorised processing or disclosure of the personal information that we hold. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

We do not store your information longer than we need to provide services to you, or to ensure we have appropriate and auditable records. We generally hold appropriate records for the duration of your engagement with Create Flow and for up to 2 years after. Where there is a contract between us, we will retain your personal data for the duration of the contract, and for a period of six years following its termination or expiry, to ensure we are able to comply with any contractual, legal, audit and other regulatory requirements, or any orders from competent courts or authorities.

All information stored by us is kept on our secure servers in the Cloud.  Once your data has been securely stored in the ‘Cloud’ it will be deleted from all personal computers and, where possible, paper documents shredded.  All personal computers are password protected and kept up to date with the virus protection software.  A back up of information stored in the Cloud is stored on an external hard drive for a maximum of two years and stored in lockable secure storage.  

On occasion to deliver our service or to meet a legal requirement it is necessary to store your personal data in paper form.  When this is required your data is stored in locked conditions. Once your data is no longer required to meet our service or legal obligations the paper storage of your data is shredded. Paper copies are kept for a maximum of two years post completion of a project or assignment.

We will store your personal data for the period that enables us to provide you with information, products or services that you request from us or for a longer period when required by law. 

Where you have consented to marketing communications, you may change your preferences or unsubscribe from marketing communications at any time by clicking the unsubscribe link in an email from us or by emailing info@wearecreateflow.com 

Unfortunately, the transmission of information via the internet and email is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website or via email; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. 

YOUR DATA PROTECTION RIGHTS

 Under data protection law, you have rights including:

Your right of access - You have the right to ask us for copies of your personal information

Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. 

Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances. 

Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances. 

Your right to object to processing - You have the the right to object to the processing of your personal information in certain circumstances.

Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you. If we are not sure of your identity, we may require you to provide further information in order for us to confirm who you are.

Please note that in some cases, asking us to stop using your personal data may restrict the products and services we are able to provide to you.

You can exercise your rights at any time by contacting us at info@wearecreateflow.com.


LINKS FROM OUR SITE

Our site contains links to and from other websites which are operated by individuals and companies over which we have no direct control. If you follow a link to any of these websites, please note that these websites have their own privacy and terms of use polices. We do not accept any responsibility or liability for these policies. We advise you to check the policies for third party sites before you submit any personal data to the website. 

MARKETING EMAILS

We will make it as easy as we can for you to opt out of unwanted processing, providing it does not restrict our ability to provide you with the primary service you have requested. 

Please note if you wish to unsubscribe from any marketing emails that you have signed up for, you can do so by emailing info@wearecreateflow.com  or clicking the unsubscribe link on the marketing email that was sent to you via Mailchimp. It may take 24 hours for this to become effective and your contact details will be deleted within 30 days.

WEBSITE ANALYTICS & TARGETED MARKETING

We use website analytics to provide the best user experience and service to you and to evaluate and improve our site. We utilise a third party data analytics service provider, Google Analytics which works with SquareSpace to improve our visibility and to monitor website browser behaviour and navigation across our site.

These third-party data analytics service providers collect this information on our behalf in accordance with our instructions and in line with their own privacy policies. Our service providers may collect the following data about the way you use our site, which will almost always be anonymised and aggregated before reporting back to us:

  • Number of visitors to our site

  • Pages visited whilst using the site and time spent per page

  • Page interaction information, such as scrolling, clicks and browsing methods

  • Source location and details about where users go when they leave the site

  • Page response times and any download errors

Other technical information relating to end user device, such as IP address or browser plug-in
From time to time we may use the information collected about you to present you with targeted advertisements using platforms such as Facebook, Twitter, Google and/or Instagram.

 

CHANGES TO THIS POLICY & FUTURE PROCESSING 

We do not intend to process your personal information except for the reasons stated within this privacy notice. If this changes, this privacy notice will be amended and placed on our website at https://www.wearecreateflow.com/privacypolicy and, where appropriate, notified to you by email. However, we advise you to check this page regularly to keep up to date with any necessary changes.

 

COMPLAINTS

If you have any concerns about our use of your personal information, or you are not satisfied with how we have collected, stored and used your data, you can make a complaint to our Data Controller via email so we can try to rectify the situation. Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to info@wearecreateflow.com 

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:          

Information Commissioner’s Office

Wycliffe House, Water Lane

Wilmslow, Cheshire,

SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk 


POLICY DETAILS

We continually review our privacy practices and may change this policy from time to time. When it does an amended privacy notice will be placed on our website at https://www.wearecreateflow.com/privacypolicy 

Our privacy notice was first published on 22 January 2021 and last updated on 24 July 2024.