Creative Edinburgh is committed to ensuring and protecting the privacy of your personal data. This Privacy Policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Please read this Privacy Policy carefully and contact us at info@creative-edinburgh.com if you require more information. This policy may be updated at any time, and should be read in conjunction with our Terms & Conditions.

This policy was last updated on 12 January 2023.

Important information about who we are

This privacy policy aims to give you information on how Creative Edinburgh Ltd, a company limited by guarantee (company registration number SC245233) and having its registered office at Codebase Edinburgh, Studio 106, 37a Castle Terrace, Edinburgh, Scotland, EH1 2EL collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, register for an event or become a member.

Controller

Creative Edinburgh Ltd is the controller and responsible for your personal data (collectively referred to as “Controller”, "we", "us" or "our" in this privacy policy).

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us in the following ways:

Email address: info@creative-edinburgh.com

Postal address: Creative Edinburgh, CodeBase Edinburgh, Argyle House, 3 Lady Lawson Street, Edinburgh, EH3 9DR.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Using our website

This website is not intended for children and we do not knowingly collect data relating to children.

When you use our website, we collect usage data, which may include information about which device you’re using (eg, laptop or mobile phone); which pages you have visited; the referral website; your geographic location; and your search criteria.

Our website uses cookies. By accepting the use of cookies on our site, you are consenting to information being stored on your browser. Read our Cookie Policy for more information.

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 policy of every website you visit.

The data we collect 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).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact, Profile and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• apply to become a Creative Edinburgh member (for more information on this see below);
• register to attend an event (for more information on this see below);
• create an account on our website;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us feedback or contact us.

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.

Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below.

Becoming a Creative Edinburgh member

When you sign up for a Creative Edinburgh membership (including Core, Student, Plus, Premium and Business/Professional memberships), we will collect some personal information from you, including but not limited to, your name, email address, payment details, postal address, sector area and date of birth.

This information is stored on our ‘Join It’ membership platform and our ‘Airtable’ back up membership database. Your name, sector area, any links that you have provided to social media or contact information and brief description of your work will display in our members library on our website.

By becoming a Creative Edinburgh member and agreeing to our Terms and Conditions and Privacy Policy, you are giving us permission to contact you via email. We will only contact you with Creative Edinburgh news and updates, which may include details on events, opportunities, jobs, calls to participate courses and feedback.

Attending Creative Edinburgh events

To attend our events, we will collect an email address and a name from you. There is often photography and filming at Creative Edinburgh events. When that is the case, your invite will ask you to give us permission to be photographed and filmed. If you do not give us this permission, we cannot guarantee you will be able to attend the event.

We may also upload event photography and videos to our social media channels via Twitter, Facebook, Instagram, Linkedin, YouTube and Vimeo.

If your likeness is captured, it may be used for marketing purposes solely related to Creative Edinburgh.

For more information or to request that we delete an image of yourself, please contact info@creative-edinburgh.com.

Applying for the Creative Edinburgh mentoring scheme

When you sign up to be a Creative Edinburgh mentor and mentee, we collect some personal information from you, including but not limited to, your name, email address, payment details, postal address, sector area and date of birth.

By becoming a Creative Edinburgh mentor or mentee and agreeing to our Terms and Conditions and Privacy Policy, you are giving us permission to contact you via email. We will only contact you with information regarding mentoring unless you have agreed to receive marketing communications from us.

Nominating for the Creative Edinburgh Awards

When you submit a nomination for the Creative Edinburgh awards, we collect some personal information from you, including but not limited to, your name, email address, payment details, postal address, sector area and date of birth.

By submitting a nomination for a Creative Edinburgh Award and agreeing to our Terms and Conditions and Privacy Policy, you are giving us permission to contact you via email. We will only contact you with information regarding the Creative Edinburgh Awards unless you have agreed to receive marketing communications from us.

Applying for the Creative Informatics Connected Innovators, Resident Entrepreneurs, or similar programme

When you apply to be a Connected Innovator, Resident Entrepreneur, or to a similar programme we run with our partners Creative Informatics we collect some personal information from you in order to deliver the service, including but not limited to your name; email address; payment details; postal address; and date of birth. The application form is created and administered by Creative Informatics, we receive the data when reviewing the application forms. 

By applying to a Creative Informatics programme and agreeing to our Terms and Conditions and Privacy Policy, you are giving us permission to contact you via email. We will only contact you with information regarding Connected Innovators and professional development or your programme unless you have agreed to receive marketing communications from us.

Applying for a fund we administer on behalf of another organisation

When you apply for a fund or scheme that we administer, we will collect your application data.

By applying for the fund or scheme you are agreeing to our Terms and Conditions and Privacy Policy, and you are giving us permission to contact you via email. We will only contact you with information regarding the fund or scheme unless you have agreed to receive marketing communications from us.

Applying for scheme run by our partners CodeBase 

We work with CodeBase on schemes such as Creative Bridge, occasionally where necessary we will receive information from them to enable us to deliver our aspect of the programme. If we do need to collect some personal information from you in order to deliver the service this can include, but is not limited, to your name, email address, payment details, postal address and date of birth. 

By applying for the scheme you are agreeing to our Terms and Conditions and Privacy Policy, and you are giving us permission to contact you via email. We will only contact you with information regarding the scheme unless you have agreed to receive marketing communications from us.

By enquiring to Creative Edinburgh by email or social media

When you enquire at Creative Edinburgh via email, social media or other form of communication we may have access to your name and contact information via the method you enquired by. In responding to your enquiry, we may recommend events, programmes or opportunities that may be of interest to you. We will not contact you with regards any other information unless explicitly requested or if you sign up to be a Creative Edinburgh member.  

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.

Please see below to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Lawful basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Purposes for which we will use your personal data

We have set out below, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.

1.

Purpose/Activity

To register you as a new member or customer

Type of data

(a) Identity

(b) Contact

Lawful basis for processing including basis of legitimate interest

Performance of a contract with you

2.

Purpose/Activity

To process and deliver your order including:

Type of data

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

Lawful basis for processing including basis of legitimate interest

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

3.

Purpose/Activity

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

Type of data

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

Lawful basis for processing including basis of legitimate interest

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

4.

Purpose/Activity

To enable you to partake in a prize draw, competition or complete a survey

Type of data

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

Lawful basis for processing including basis of legitimate interest

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

5.

Purpose/Activity

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Type of data

(a) Identity

(b) Contact

(c) Technical

Lawful basis for processing including basis of legitimate interest

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

6.

Purpose/Activity

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

Type of data

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Lawful basis for processing including basis of legitimate interest

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

7.

Purpose/Activity

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

Type of data

(a) Technical

(b) Usage

Lawful basis for processing including basis of legitimate interest

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

8.

Purpose/Activity

To make suggestions and recommendations to you about goods or services that may be of interest to you

Type of data

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

Lawful basis for processing including basis of legitimate interest

Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing and promotional offers

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or have opted in to receiving marketing.

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

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

We will never share your data for anything other than its intended use

We will only share your data with any other organisations in the UK or internationally for the use cases outlined above. We will never share your data or use it for anything other than its intended purpose. We will never share your information with any third party organisation in the UK or internationally, unless you have given us explicit permission to do so. For the use cases above, for example, submitting an application to a fund we administer on behalf of another body, in agreeing to our terms and conditions and submitting an application constitutes explicit permission.

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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.

Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see below for further information on this.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

You have the right to:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
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• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you/
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.