Boston Tullis Ltd are committed to protecting and respecting your privacy.
This policy (together with any other documents referred to on it) sets out the basis on how we use any personal information we collect about you when you use this website or contact us directly and how it will be stored and processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).
Data controller – A controller determines the purposes and means of processing personal data.
Data processor – A processor is responsible for processing personal data on behalf of a controller.
Data subject – Natural person
Categories of data: Personal data and special categories of personal data
Personal data – The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.
Special categories personal data – The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.
Processing – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party – means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
2. Who are we?
Boston Tullis Ltd is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are: Boston Tullis Ltd, Suite 12, 340 The Crescent, Severalls Business Park, Colchester, Essex, CO4 (AD. Email: [email protected] Phone: 01206 699 319
For all data matters please contact our Data Representative; Jenna Kennedy on [email protected] or by phone on 01206 699 319
3. The purpose(s) of processing your personal data
We use your personal data for the following purposes:
- To maintain accounts and records
- To contact you regarding any contracted work taking place
- To contact you about any payment queries regarding the company
- To contact you regarding any special offers or products Boston Tullis are launching
- To contact you regarding any information/offers that are of legitimate interest
4. The categories of personal data concerned
With reference to the categories of personal data described in the definitions section, we process the following categories of your data:
- Personal data – Name, Company Email Address, Company phone number, Job Title).
5. What is our legal basis for processing your personal data?
- Personal data (article 6 of GDPR)
Our lawful basis for processing your general personal data:
|Consent of the data subject;||This is to allow Boston Tullis to directly update and inform clients or prospects of new product/podcast launches, special offers and other relevant industry information|
|Processing necessary for the performance of a contract with the data subject or to take steps to enter into a contract||To maintain accounts and records, to make contact regarding any outstanding or current contract enquires, to make contact about any payment queries regarding the company|
|Processing necessary for compliance with a legal obligation||To maintain details of unsubscribes to ensure no future contact.|
|Processing for B2B marketing with legitimate interest||Legitimate interest – B2B marketing|
Special categories of personal data (article 9 of GDPR)
Boston Tullis Ltd does not collect any information under the Special Categories or Personal Data section.
6. Sharing your personal data
Your personal data will be treated as strictly confidential and will only be shared with our external administration team, who will process any data in line with this policy.
How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary (if you would like further information on our retention guidelines, please contact our GDPR representative; Jenna Kennedy on [email protected] or by phone on 01206 699 319.
7. Providing us with your personal data
We require your personal data as it is necessary for the performance of a contract with the data subject or to take steps to enter into a contract.
Any data collected not necessary for contract purposes is done so to provide B2B marketing with legitimate interest.
8. Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
- The right to request a copy of the personal data which we hold about you;
- The right to request that we correct any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary to retain such data;
- The right to withdraw your consent to the processing at any time, where consent was your lawful basis for processing the data
- The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
- The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).
9. Transfer of Data Abroad
Boston Tullis will only transfer data outside of the UK to fulfil contractual terms previously discussed/agreed in writing with the client. Boston Tullis have implemented a safeguarding assessment for all third-party entities used.
10. Automated Decision Making
WE DO NOT USE ANY FORM OF AUTOMATED DECISION MAKING IN OUR BUSINESS.
11. Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.
13. How to make a complaint
To exercise all relevant rights, queries or complaints please in the first instance contact our Data Representative; Jenna Kennedy on [email protected] or by phone on 01206 797707.
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.