Unboxed Consulting Limited trading as Unboxed (“we” or “us”) takes the privacy of your information very seriously. Our Privacy Notice is designed to tell you, the user, about our practices regarding the collection, use and disclosure of personal information which may be provided to us via our website or collected through other means such as an online form, email, or telephone communication.
This notice applies to information provided by our users. In this notice “you” refers to any individual whose personal data we hold or process (other than our staff).
In this notice references to the “Site” are references to any website, app or other means by which you provide personal data to us or access our services.
This notice is governed by the EU General Data Protection Regulation (the “GDPR”).
Basis on which we process personal data
Personal data we hold about you will be processed either because:
- You have consented to the processing for the specific purposes described in this notice;
- The processing is necessary in order for us to comply with our obligations under a contract between you and us; or
- The processing is necessary in pursuit of a “legitimate interest”, a legitimate interest in this context means a valid interest we have or a third party has in processing your personal data which is not overridden by your interests in data privacy and security.
Personal data we collect
We may collect and process the following personal data (information that can be uniquely identified with you) about you:
- Certain information you provide, including first name, last name, email address and telephone number, when completing an online form to submit a query or book a meeting with us ((“Communication Information”);
- Certain information you may provide including first name, last name, email address and telephone number when contacting Unboxed by emailing email@example.com or firstname.lastname@example.org (“Communication Information”);
- Certain information you may provide when signing up to receive our newsletter including email address, first name and last name (“Communication Information”),;
- Contact information we may collect from you (for example, first name, last name, address, telephone number, email address) including for the purposes of fulfilling a contract with you (“Contact Information”);
- A record and details of any correspondence or communication between you and us or relating to any complaint submitted to us (“Communication Information”);
- Details of your visits to the Site, the resources and pages that you access and any searches you make (“Technical Information”).
A cookie is a piece of data stored locally on your computer and contains information about your activities on the Internet. The information in a cookie does not contain any personally identifiable information you submit to our Site.
If you choose not to accept the cookies, this will not affect your access to the majority of information available on our Site. However, you will not be able to make full use of our online services.
An Internet Protocol (IP) address is a number assigned to your computer by your Internet Service Provider (ISP), so you can access the Internet. We may use your IP address to diagnose problems with our server, report aggregate information, and determine the fastest route for your computer to use in connecting to our Site, and to administer and improve the Site.
How we process your personal data
Please see the table below, which sets out the manner in which we will process the different types of personal data we hold:
Purpose/ActivityType of dataLawful basis for processing including basis of legitimate interestTo respond to queries or arrange meetings after contact initiated by youCommunication InformationLegitimate Interest (communication with you in running our business after direct contact from you)To correspond with you in the process of fulfilling a contract with you including for the purposes of invoicingContact InformationPerformance of a contract with youTo use data analytics to improve the Site, services, marketing, customer relationships and experiences.Technical InformationNecessary 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).
Sharing Your Information
We may share data with cloud services providers for the following purposes:
- We host www.unboxed.co on Netlify (https://www.netlify.com/) and certain Technical Information may be stored with Netlify
- We send our newsletter via MailChimp (https://mailchimp.com/) and will share certain details, in particular your name and email address for the purposes of sending you emails via their service
- We capture queries and meeting requests from you in Calendly (https://calendly.com/unboxed), Formspree (https://formspree.io/) and Hubspot (https://www.hubspot.com) and will share certain details, in particular your name, email address and telephone number for the purpose of arranging calls or meetings
- We host our email with Google (https://mailchimp.com/) and will store certain information with them, in particular any email correspondence we have with you
- We use Slack (https://slack.com) for the purposes of team communication and will store certain Communication Information with them, in particular name, email address and the contents of any correspondance we have with you over Slack
- We use Xero (https://xero.com) for customer and financial management and invoicing and may store certain Contact Information with them
We do not disclose any personal data you provide to any third parties other than as explained above.
We may also share data for the following purposes:
- If we are responding to an emergency and need to pass your information to emergency responders;
- Where we carry out research to gain an insight into the use of our services, the results of this research (but not your personal data itself) may be transferred to interested third parties;
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation (for example, if required to do so by a court order or for the purposes of prevention of fraud or other crime);
- We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation, but we will take steps with the aim of ensuring that your privacy rights continue to be protected;
- To protect our rights, property and safety, or the rights, property and safety of our users or any other third parties. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Other than as set out above, we shall not disclose any of your personal information unless you give us permission to do so. If we do supply your personal information to a third party we will take steps to ensure that your privacy rights are protected and that third party complies with the terms of this notice.
Our current data retention policy is to delete or destroy (to the extent we are able to) the personal data we hold about you in accordance with the following:
Category of personal dataLength of retentionPersonal data processed in relation to a contract between you and us7 years from either the end of the contract or the date you last used our services or placed an order with us, being the length of time following a breach of contract in which a contract party is entitled to make a legal claim.Personal data held on marketing or business development records3 years from the last date on which a data subject has interacted with us.
For any category of personal data not specifically defined in this notice, and unless otherwise specified by applicable law, the required retention period for any personal data will be deemed to be 7 years from the date of receipt by us of that data.
The retention periods stated in this notice can be prolonged or shortened as may be required (for example, in the event that legal proceedings apply to the data or if there is an ongoing investigation into the data).
We review the personal data (and the categories of personal data) we are holding on a regular basis to ensure the data we are holding is still relevant to our business and is accurate. If we discover that certain data we are holding is no longer necessary or accurate, we will take reasonable steps to correct or delete this data as may be required.
If you wish to request that data we hold about you is amended or deleted, please refer to “Your Privacy Rights” below..
Your privacy rights
The GDPR gives you the following rights in respect of personal data we hold about you (and we agree that such rights will be available to you up before the GDPR is in force):
The right to be informed
You have a right to know about our personal data protection and data processing activities, details of which are contained in this notice.
The right of access
You can make what is known as a Subject Access Request (“SAR”) to request information about the personal data we hold about you (free of charge, save for reasonable expenses for repeat requests). If you wish to make a SAR please contact us as described below.
The right to correction
Please inform us if information we hold about you is incomplete or inaccurate in any way and we will update our records as soon as possible, but in any event within one month. We will take reasonable steps to communicate the change to any third parties to whom we have passed the same information.
The right to erasure (the ‘right to be forgotten’)
Please notify us if you no longer wish us to hold personal data about you (although in practice it is not possible to provide our services without holding your personal data). Unless we have reasonable grounds to refuse the erasure, on receipt of such a request we will securely delete the personal data in question within one month. The data may continue to exist in certain backup, but we will take steps to ensure that it will not be accessible. We will communicate the erasure to any third parties to whom we have passed the same information.
The right to restrict processing
You can request that we no longer process your personal data in certain ways, whilst not requiring us to delete the same data.
The right to data portability
You have right to receive copies of personal data we hold about you in a commonly used and easily storable format (please let us know a format which suits you). You may also request that we transfer your personal data directly to third party (where technically possible).
The right to object
Unless we have overriding legitimate grounds for such processing, you may object to us using your personal data if you feel your fundamental rights and freedoms are impacted. You may also object if we use your personal data for direct marketing purposes (including profiling) or for research or statistical purposes. Please notify your objection to us and we will gladly cease such processing, unless we have overriding legitimate grounds.
Rights with respect to automated decision-making and profiling
You have a right not to be subject to automated decision-making (including profiling) when those decisions have a legal (or similarly significant effect) on you. You are not entitled to this right when the automated processing is necessary for us to perform our obligations under a contract with you, it is permitted by law, or if you have given your explicit consent.
Right to withdraw consent
If we are relying on your consent as the basis on which we are processing your personal data, you have the right to withdraw your consent at any time. Even if you have not expressly given your consent to our processing, you also have the right to object (see above).
All SARs and other requests or notifications in respect of your above rights must be sent to us in writing to email@example.com or by telephoning +44 (0)20 7183 4250.
We will endeavour to comply with such requests as soon as possible but in any event we will comply within one month of receipt (unless a longer period of time to respond is reasonable by virtue of the complexity or number of your requests).
If personal data we hold about you is subject to a breach or unauthorised disclosure or access, we will report this to the Information Commissioner’s Office (ICO).
If a breach is likely to result in a risk to your data rights and freedoms, we will notify you as soon as possible.
Our Sites may contain links and references to other websites. Please be aware that this notice does not apply to those websites.
We cannot be responsible for the privacy policies and practices of sites that are not operated by us, even if you access them via the Site. We recommend that you check the policy of each site you visit and contact its owner or operator if you have any concerns or questions.
In addition, if you came to this Site via a third party site, we cannot be responsible for the privacy policies and practices of the owners or operators of that third party site and recommend that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.
Transferring your information outside Europe
As part of the services provided to you the information you provide to us may be transferred to, processed and stored at, countries or international organisations outside of the EEA.
Other than through standard use of the cloud services listed in “Sharing your Information” we will not transfer the personal data of EEA customers in a systematic way outside of the EEA but there may be circumstances in which certain personal information is transferred outside of the EEA, in particular:
- If you use our Site while you are outside the EEA, your information may be transferred outside the EEA in order to provide you with our services;
- We may communicate with individuals or organisations outside of the EEA in delivering our services, those communications may include personal information (such as contact information) for example you may be outside of the EEA when we communicate with you;
- From time-to-time your information may be stored in devices which are used by our staff outside of the EEA (but staff will be subject to our cyber-security policies).
If we transfer your information outside of the EEA, and the third country or international organisation in question has not been deemed by the EU Commission to have adequate data protection laws, we will provide appropriate safeguards and we will be responsible for ensuring your privacy rights continue to be protected as outlined in this notice. If you would like to obtain details of the safeguards we have put in place then please contact us at: firstname.lastname@example.org;
By submitting your personal information to us you agree to the transfer, storing or processing of your information outside the EEA in the manner described above.
Notification of changes to the contents of this notice
We will post details of any changes to our policy on the Site to help ensure you are always aware of the information we collect, how we use it, and in what circumstances, if any, we share it with other parties.
If at any time you would like to contact us with your views about our privacy practices, or with any enquiry or complaint relating to your personal information or how it is handled, you can do so via the following:
Unboxed Consulting Limited
60-62 Commercial Street
Or contact us via:
Telephone: +44 (0)20 7183 4250
If we are unable to resolve any issues you may have or you would like to make a further complaint, you can contact the Information Commissioner’s Office by visiting http://www.ico.org.uk/