www.thedoubleagents.co.uk (the “Site”) is owned and operated by The Double Agents, a trading style of Cap It All Media. The Double Agents is the data controller and can be contacted at:
enquiries@capitallmedia.co.uk
Purpose
The purpose of this privacy policy (this “Privacy Policy”) is to inform users of our Site of the following:
The personal data we will collect;
Use of collected data;
Who has access to the data collected; and
The rights of Site users.
This Privacy Policy applies in addition to the terms and conditions of our Site.
GDPR
For users in the European Union, we adhere to the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, known as the General Data Protection Regulation (the “GDPR”). For users in the United Kingdom, we adhere to the GDPR as enshrined in the Data Protection Act 2018.
Consent
By using our Site users agree that they consent to:
The conditions set out in this Privacy Policy.
When the legal basis for us processing your personal data is that you have provided your consent to that processing, you may withdraw your consent at any time. If you withdraw your consent, it will not make processing which we completed before you withdrew your consent unlawful.
You can withdraw your consent by: Contacting the data protection officer.
Legal Basis for Processing
We collect and process personal data about users in the EU only when we have a legal basis for doing so under Article 6 of the GDPR.
We rely on the following legal bases to collect and process the personal data of users in the EU:
Users have provided their consent to the processing of their data for one or more specific purposes; and
Processing of user personal data is necessary for us to take, at the request of a user, steps before entering a contract or for the performance of a contract to which a user is a party. If a user does not provide the the personal data necessary to perform a contract the consequences are as follows: We cannot respond to your initial enquiry, process a joining form/agreement, or enter into a contract with you for services.
Personal Data We Collect
We only collect data that helps us achieve the purpose set out in this Privacy Policy. We will not collect any additional data beyond the data listed below without notifying you first.
Data Collected in a Non-Automatic Way
We may also collect the following data when you perform certain functions on our Site:
First and last name;
Email address;
Phone number; and
Any other information you provide via email..
This data may be collected using the following methods:
Contact form completion.
How We Use Personal Data
Data collected on our Site will only be used for the purposes specified in this Privacy Policy or indicated on the relevant pages of our Site. We will not use your data beyond what we disclose in this Privacy Policy.
The data we collect when the user performs certain functions may be used for the following purposes:
Responding to enquiries and, if you appoint us, for the purposes of contracting and the delivery of the Services.
Who We Share Personal Data With
Employees
We may disclose user data to any member of our organisation who reasonably needs access to user data to achieve the purposes set out in this Privacy Policy.
Third Parties
We may share user data with the following third parties:
Media outlets, users of The Double Agents website, Belters News, Palamedes PR, brands, organisations and other individuals/organisations who will need to contact to generate media and commercial opportunities on your behalf.
We may share the following user data with third parties:
Typically clients’ names, ages, biographies, and other information necessary to generate media and commercial opportunities.
We may share user data with third parties for the following purposes:
For the provision of the Services.
Third parties will not be able to access user data beyond what is reasonably necessary to achieve the given purpose.
Other Disclosures
We will not sell or share your data with other third parties, except in the following cases:
If the law requires it;
If it is required for any legal proceeding;
To prove or protect our legal rights; and
To buyers or potential buyers of this company in the event that we seek to sell the company.
If you follow hyperlinks from our Site to another Site, please note that we are not responsible for and have no control over their privacy policies and practices.
How Long We Store Personal Data
User data will be stored until the purpose the data was collected for has been achieved.
You will be notified if your data is kept for longer than this period.
Place of processing
The Data is processed at our operating offices and in any other places where the parties involved in the processing are located. Data is naturally transferred between members of Palamedes staff; to any representative, advisers and other third parties you have authorised to interact with us on your behalf; to media organisations through which we are seeking publicity on your behalf; to payment system operators and financial institutions; between call handling representatives (such as Virtually There, which has its own privacy policy here); to third party service providers who we engage for website design and graphic design projects; to government agencies or authorities, regulators, law enforcement agencies and other parties where authorised or required by law who ask us to disclose that information and to which we are legally required to disclose your personal information. If you have asked us to secure publicity outside of the UK, your personal data will necessarily be transferred outside of the UK for this purpose.
International data transfers
Data transfers will only ever take place outside of the UK if we are seeking publicity for you in a country outside of the UK or if you otherwise request a service from us that requires us to make such a transfer. In such cases, data we collect may be transferred to, stored and processed in any country or territory where one or more of our external service providers or consultants are based. While other countries or territories may not have the same standards of data protection as those in your home country, we will continue to protect personal data that we transfer in line with this privacy policy.
Whenever we transfer your personal data out of the UK or the European Economic Area (EEA), we ensure similar protection and use specific approved International Data Transfer Agreement contracts that give your personal data the same protection it has in the UK or the EEA.
How We Protect Your Personal Data
In order to protect your security, we use strong browser encryption and store all of the personal data we collect through enquiries on this website on servers in secure facilities. All personal data is only accessible to those who run and manage this website.
While we take all reasonable precautions to ensure that user data is secure and that users are protected, there always remains the risk of harm. The Internet as a whole can be insecure at times and therefore we are unable to guarantee the security of user data beyond what is reasonably practical.
Your Rights as a User
Under the GDPR, you have the following rights:
Right to be informed;
Right of access;
Right to rectification;
Right to erasure;
Right to restrict processing;
Right to data portability; and
Right to object.
Children
We do not knowingly collect or use personal data from children under 16 years of age. If we learn that we have collected personal data from a child under 16 years of age, the personal data will be deleted as soon as possible. If a child under 16 years of age has provided us with personal data their parent or guardian may contact our data protection officer.
How to Access, Modify, Delete, or Challenge the Data Collected
If you would like to know if we have collected your personal data, how we have used your personal data, if we have disclosed your personal data and to who we disclosed your personal data, if you would like your data to be deleted or modified in any way, or if you would like to exercise any of your other rights under the GDPR, please contact our data protection officer here:
Anthony Harvison
enquiries@capitallmedia.co.uk
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How to Opt-Out of Data Collection, Use or Disclosure
In addition to the method(s) described in the How to Access, Modify, Delete, or Challenge the Data Collected section, we provide the following specific opt-out methods for the forms of collection, use, or disclosure of your personal data specified below:
you can opt out of cookies being collected. You can opt-out by users of the website can deny the collection of cookies at the click of a button when they first access the website.
Modifications
This Privacy Policy may be amended from time to time in order to maintain compliance with the law and to reflect any changes to our data collection process. When we amend this Privacy Policy we will update the “Effective Date” at the top of this Privacy Policy. We recommend that our users periodically review our Privacy Policy to ensure that they are notified of any updates. If necessary, we may notify users by email of changes to this Privacy Policy.
Complaints
If you have any complaints about how we process your personal data, please contact us through the contact methods listed in the Contact Information section so that we can, where possible, resolve the issue. If you feel we have not addressed your concern in a satisfactory manner you may contact a supervisory authority. You also have the right to directly make a complaint to a supervisory authority. You can lodge a complaint with a supervisory authority by contacting the Information Commissioner’s Office in the UK.
Contact Information
If you have any questions, concerns or complaints, you can contact our data protection officer, Anthony Harvison, at:
enquiries@capitallmedia.co.uk
This privacy policy was last updated on 24/03/2024
