OUR PRIVACY POLICY

Privacy policy

introduction

Welcome to the Deviation privacy policy.

Deviation respects your privacy and is committed to protecting your personal data.

This privacy policy will inform you as to how we look after your personal data when you visit the Deviation company website (regardless of where you visit us from) and tell you about your privacy rights and how the law protects you.

Whenever we refer to “this website” or “website” we are referring to the deviation agency limited website which can be accessed via "wearedeviation.com" and also "wearedeviation.co.uk, ashleyliddell.co.uk, deviationagency.com & deviationagency.co.uk" but are ultimately the same experience.

Purpose of the privacy policy:

This privacy notice (together with our Terms of Use and Cookie Policy) sets out the basis on which we collect information from or about you, or that you provide to us, and how this information will be processed by us through your use of this website and our services.

Please read the following privacy policy carefully to understand our views and practices regarding your
information and how we will treat it.

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INFORMATION WE
COLLECT

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, maiden 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 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 notice.

We may collect some Special Categories of Personal Data about you if you give us your details relating to religious or philosophical beliefs, sexual orientation, and information about your health by corresponding with us.

We do not collect any Special Categories of Personal Data without processing it fairly, lawfully and transparently and without your explicit consent.

We do not 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.Information you provide to us.

We will not ask you to provide any Special Categories of Personal Data.

Any Special Categories of Personal Data collected will only be collected when you volunteer it.

Should you decide you want to disclose Special Categories of Personal Data relating to you, you must provide us with explicit consent.

You have the right to withdraw this consent at any time.

Should you decide to withdraw this consent, please contact the [email protected].

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HOW PERSONAL DATA
IS COLLECTED

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

Direct interactions. You may give us your Identity, Contact 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 for our products or services; completing contact forms; attend our events; subscribe to our service or publications; request marketing to be sent to you; enter a competition, promotion or survey; enter into discussions or correspondence with us in relation to our services; enter into a contract with us; interact with other services we offer now and in the future; send us your content for us to upload to our YouTube channel(s); or give us feedback or contact us.

Automated technologies or interactions. This is information we collect about you if you use any of the other websites we operate or other services we provide. In this case we will have informed you when we collected that data if we intend to share that data internally and combine it with data collected on this site.

We will also have told you for what purpose we will share and combine your data. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies).

Third parties or publicly available sources. We will combine this information with information you give to us and information we receive about you from other sources.

We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

Type of Data - Third Party:

Technical Data analytics providers such as Google based outside the UK.

Advertising networks such as Google, LinkedIn, Meta and Digital search.

Information providers such as Google Analytics based outside the UK
Contact, Financial and Transaction Data technical services providers Including Google Chrome who are based outside the UK

Payment services providers to deliver payment services who are based inside and outside the UK
E-commerce services providers, including contracted freelancers to deliver e-commerce services who are based outside the UK.

Identity and Contact Data, data brokers or aggregators. Publicly available sources such as Companies House and the Electoral Register based inside the UK

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HOW WE USE YOU
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; and where we need to comply with a legal obligation.

Generally, we do not rely on consent as a lawful 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.

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.


To register you as a new client

To process and deliver services to you including:(a) Managing payments, fees and charges(b) Administering your account with us(c)

Collect and recover money owed

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

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

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

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

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms: when signing up to our publications, you will be given the option to unsubscribe on each publication; when you complete a contact form or send an email to [email protected], you will be given the option to opt in/out of our marketing and advertising before submitting a personal account.

Promotional offers from us

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 purchased/used our services from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the Deviation group of companies for marketing purposes.

Opting out

You can ask us or third parties 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 at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, service experience or other transactions.

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 lawful 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.

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WHO WE SHARE YOUR
PERSONAL DATA WITH

We may share your personal data with third parties if they have a need to know the information for the purposes of providing the contracted services.

Set out below are some of the third parties we engage with for the purposes set out in "Purposes for which we will use your personal data" above.

Internal Third Parties include other companies in the Deviation group acting as joint controllers or processors and who are based in England and Wales and provide IT and system administration services and undertake leadership reporting.

Internal third parties including those within Deviation Agency Limited.

External Third Parties include: Service providers acting as processors based in the UK, Republic of Ireland, Singapore and USA who provide IT and system administration services and online media services.

Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

Service providers acting as processors based in the UK who provide credit check services.

Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.

Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

For further details, see the ICO website and the Department for Digital, Culture, Media & Sport’s (DCMS) website.

Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

For further details, see the ICO website.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

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HOW WE KEEP YOUR
DATA SECURE

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.

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HOW LONG DATA IS
RETAINED

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 your legal rights.

In some circumstances we may 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.

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UNDERSTAND YOUR
RIGHTS 

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

These circumstances include: 

Request access to your personal data
Request correction of your personal data
Request erasure of your personal data
Object to processing of your personal data
Request restriction of processing your personal data
Request transfer of your personal data
Right to withdraw consent
Right to be informed


If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

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.

What we may need from you

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.

Time to respond

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.

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THIRD PARTY LINKS

Our website may, from time to time, contain links to and from the websites and applications of our advertisers, affiliates, partner networks and other service providers such as YouTube, Facebook, Twitter, TikTok and Snapchat.

If you follow a link to any of these websites, please note that these websites may collect or share personal data about you and have their own privacy policies and that we do not accept any responsibility or liability for these policies.

Please check these privacy policies before you submit any information to these websites.

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PRIVACY POLICY
CHANGES

We keep our privacy notice under regular review.

It is important that the personal data we hold about you is accurate and current.

Please keep us informed if your personal data changes during your relationship with us.

This version was last updated January 2024.