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Privacy Policy

25th April 2022 FLAIR

FLAIR PRIVACY NOTICE – MARKET RESEARCH PARTICIPANTS

At Flair, we are committed to protecting your personal information. We have published this privacy notice to ensure that you are fully aware of what personal information we collect from you, how we use it, who we share it with and what your rights are. This privacy notice applies to those who have been asked to take part in our market research survey by their School, College, University or Employer.

WHO ARE WE?

“We”, “our” or “us” means Flair Global Ltd. Our company number is 10646795. Our registered office is at 16-19 Eastcastle Street, Fitzrovia, London, W1W8DY, United Kingdom.

We are the controller of your personal information. This means that we are responsible for deciding how we collect, store and use personal information about you.

If you have any questions about this privacy notice, please contact us at [email protected]

THIS PRIVACY NOTICE ANSWERS THE FOLLOWING QUESTIONS

  • What personal information do we collect when you participate in our surveys, how do we use it and what is our legal basis for using it?
  • How do we use your sensitive personal information?
  • What happens if you don’t provide the personal information we have asked for?
  • Can we change the purpose for which we use your personal information?
  • How long will we keep your personal information?
  • Who will we share your personal information with?
  • Will we transfer your personal information outside the UK/EEA?
  • How do we keep your personal information secure?
  • What rights do you have over your personal information?
  • How will you tell me about changes to this privacy notice?
  • How can you contact us?

WHAT PERSONAL INFORMATION DO WE COLLECT WHEN YOU PARTICIPATE IN OUR SURVEYS, HOW DO WE USE IT AND WHAT IS OUR LEGAL BASIS FOR USING IT?

When you take part in our market research surveys, we will collect your responses to the different questions in the survey. The questions in the survey will depend on the survey that you are participating in and we will only collect the personal information that is relevant to the type of survey we are carrying out for your School, College, University or Employer.

When you take part in the market research surveys, we will also collect personal information to help us understand more about your background such as your gender and ethnicity. This is to help us understand the different views of people from different backgrounds.

We will not collect your name or contact details and will work with your School, College, University or Employer to provide you with a link to the survey.

We will use the information you have given in the survey to:

  • Review your opinion on different topics;
  • Provide market research;
  • Provide feedback to your School, College, University or Employer on the views of its pupils or employees;
  • Create a report to provide to your School, College, University or Employer;
  • Create a dashboard of responses for your School, College, University or Employer to review;

    and

  • Publish aggregated findings and statistics to raise awareness on the topic.

Your responses to the questions will be kept anonymous. When we provide the feedback and the report to your School, College, University or Employer all the responses will be combined together, and the information will be limited to make sure that you cannot be identified.

Under data protection law we must have a legal basis to use your personal information. We will collect, store and use the personal information that you give to us when you participate in our surveys on the legal basis that it is in our legitimate interests as a business to provide insights on the survey topics. We have considered our legitimate interests carefully and have balanced our legitimate interests against your rights under data protection law. We consider that this use is proportionate because it is relevant and appropriate to our relationship with you, it is in your reasonable expectations that we would use your responses in this way and any results are aggregated.

HOW DO WE USE YOUR SENSITIVE PERSONAL INFORMATION?

As part of our surveys we collect, store and use details about your health, racial or ethnic origin to help with understanding the views of people from different backgrounds. Details about your health, racial or ethnic origin is considered more sensitive or “special category of personal information.

Our legal basis for this use is that it is necessary for reasons of substantial public interests. Our market research surveys are designed to assist your School, College, University or Employer address any concerns in relation to equality and opportunity of treatment as well as addressing racial and ethnic diversity.

WHAT HAPPENS IF YOU DON’T PROVIDE THE PERSONAL INFORMATION WE HAVE ASKED FOR?

We will include the information you have provided in our insight response to your School, College, University or Employer. If you don’t provide the personal information your opinion will not be included in the feedback to your School, College, University or Employer. If you have concerns about whether you need to provide your personal information, please contact us at [email protected].

WILL WE USE YOUR PERSONAL INFORMATION FOR AUTOMATED DECISION-MAKING?

We do not use your personal information to make any decisions that will have a legal or significant impact on you based solely on automated decision making (i.e. without any human involvement).

CAN WE CHANGE THE PURPOSE FOR WHICH WE USE YOUR PERSONAL INFORMATION?

We will only use your personal information for the purposes set out above unless another purpose we want to use it for is compatible with those original purposes. If we change the purpose for which we are using your personal information and you would like an explanation as to how the new purpose is compatible with the original purpose, please contact us at [email protected]. If we would like to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do this.

HOW LONG WILL WE KEEP YOUR PERSONAL INFORMATION?

We will keep the personal information that we have collected from you as a participant in our survey for a period of 5 years from the date of the survey.

We may keep details of aggregated findings and statistics for longer than the 5 years to track changes over time.

If a dispute arises between us, we will keep your personal information for the purposes of responding to and dealing with this dispute and this may mean that we keep your personal information for longer.

Please contact us at [email protected] if you would like any further information about our retention periods.

WHO WILL WE SHARE YOUR PERSONAL INFORMATION WITH?

We may share your personal information with the people set out below. We will not, however, share your personal information with a third party for them to market to you unless we have your consent to do this:

  • With your School, College, University or Employer: We share the information from the surveys with your School, College, University or Employer so that they can use the results of our survey.
  • IT Suppliers: We use reputable third parties to provide us with our IT systems (including our CRM system and website) and support for them. They may access your personal information to the extent that they need to in order to provide their services and deal with any issues.
  • Legal and Regulatory Requirements: We will share your personal information with entities, companies or individuals where this is necessary to comply with any law, rule, regulation, legal procedure.
  • Mergers: In the unlikely event that we sell all or part of our business, or merge with another organisation, we may transfer personal information that we have collected as described in this privacy notice, along with our other business assets, to the organisation that we are selling to or merging with.
  • Professional Advisors: We may also share your personal information with our professional advisors (including lawyers, insurers and/or insurance brokers) to take advice e.g. in connection with any complaint or claim which you (or your school or the company you work for) make and to complete yours (or your school or the company you work for) purchase.

If you would like further information on our legal basis for sharing your personal information with third parties, please contact us at [email protected]

WILL WE TRANSFER YOUR PERSONAL INFORMATION OUTSIDE THE UK/EEA?

European Economic Area (“EEA”) countries are all EU Member countries together with Iceland, Liechtenstein and Norway. At the present time we store your personal information in the United Kingdom or in countries within the EEA. We do not currently store or transfer your personal information outside of the EEA.

HOW DO WE KEEP YOUR PERSONAL INFORMATION SECURE?

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know.

WHAT RIGHTS DO YOU HAVE OVER YOUR PERSONAL INFORMATION?

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. See www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO and so, if you are happy to do so, please contact us at [email protected]

You also have a number of other rights over your personal information, which are:

  • the right to ask us what personal information we have about you and to have a copy of your personal information from us;
  • the right to ask us to correct any errors in your personal information;
  • the right to object to our legitimate interests, profiling activities and marketing communications;
  • the right to ask us to provide you with a copy of the personal information you have provided to us, in a structured, commonly used and machine-readable format and the right to transmit that personal information to another entity where: (i) we are using your personal information on the basis of your consent or on the basis that it is necessary to perform a contract with you; and (ii) the use we are making of your personal information is carried out by automated means;
  • the right to ask us to delete your personal information where: (i) we don’t need your personal information anymore; (ii) you withdraw your consent to our use of your personal information and we have no other legal basis to keep your personal information; (iii) you have asked us to review and explain our legitimate interests to you and we don’t actually have a valid legitimate interest to do what we are doing; (iv) our use of your personal information is illegal; (v) we have to delete your personal information to comply with our legal obligations;
  • the right to ask us to restrict the use that we are making of your personal information where: (i) you don’t think the personal information we have about you is correct, so that we can check if it is correct; (ii) what we are doing with your personal information is illegal but you would rather we stop using your personal information rather than delete it; (iii) we don’t need your personal information anymore, but you need us to keep it so that you can exercise any legal rights; and (iv) you have asked us to review and explain our legitimate interests to you, so that we can check whether we actually have a valid legitimate interest to do what we are doing; and
  • where our use of your personal information is based on your consent, the right to withdraw your consent at any time by contacting us at [email protected]

HOW WILL YOU TELL ME ABOUT CHANGES TO THIS PRIVACY NOTICE?

We keep our privacy notice under regular review. Any changes we make to our privacy notice in the future will be posted on our website page. If the changes will have an effect on you or the way, we use your personal information we will bring them to your attention by email where appropriate. Please check back frequently to see any updates or changes to our privacy notice. This privacy notice was last updated in September 2020.

HOW CAN YOU CONTACT US?

If you have any questions about this privacy notice or about the ways we use your personal information, please contact us at [email protected].