INTRODUCTION

Lefty 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 our website and related platforms (regardless of where you visit them from) and tell you about your privacy rights and how the law protects you.

Please use the Glossary to understand the meaning of some of the terms used in this privacy policy.

PURPOSE OF THIS PRIVACY POLICY

This privacy policy aims to give you information on how Lefty collects and processes your personal data through your use of this website, including any data you may provide through this website or through our platforms.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

CONTROLLER

Lefty is made up of different legal entities which trade as “Lefty”, all of which are subsidiary undertakings of The Independents Holding Limited in the UK – CRN: 10186775 (together, the “Lefty Group”).

This privacy policy is issued on behalf of the Lefty Group so when we mention “Lefty”, “Company”, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the Lefty Group responsible for processing your data. Lefty is part of the group of agencies comprising The Independents Group (together, “The Independents Group”). Modern Agency SAS (in France – CRN: 810844399) is the controller and responsible for this website.

Our Group General Counsel is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, please contact the Group General Counsel using the details set out below.

CONTACT DETAILS

If you have any questions about this privacy policy or our privacy practices, please contact our Group General Counsel at legal@the-independents.com.

You have the right to make a complaint at any time to an applicable supervisory authority for data protection or privacy issues. We would, however, appreciate the chance to deal with your concerns before you approach such authorities, so please contact us in the first instance.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy policy 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.

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

THE DATA WE COLLECT ABOUT YOU

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). Please see the Glossary for details of personal data types which we may collect, use, store and transfer.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Personally-Identifiable Information: We may collect personally identifiable information when you specifically and knowingly provide it to us, for example when you request support, or register and provide personal information such as your email address, name, phone number or other details. Where applicable, personally identifiable information includes "personal data" as defined in applicable law.

Sensitive Personal Data: We ask that you not send us, and you not disclose, any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through our services or otherwise to us.

If you send or disclose any sensitive personal data to us, you consent to our processing and use of such sensitive personal data in accordance with this privacy policy. If you do not consent to our processing and use of such sensitive personal data, you must not submit such content to us.

Non-Personally-Identifiable Information: We may collect and aggregate non-personally identifiable information which is information which does not permit you to be identified or identifiable either by itself or in combination with other information available to a third party. This information may include information, such as a website that referred you to us, your IP address, browser type and language, hardware types, geographic location and access times and durations. We also may collect navigational information, including information about website content or pages you view, the links you click, and other actions taken.

Cookies: We install a cookie to differentiate you from other users and capture and remember certain information. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personalized experience.

The Independents Group uses the following types of cookies:

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

In addition we include the following third party SDKs which may install a cookie:

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.

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, The Independents Group will use your personal data in the following circumstances:

Please see the Glossary to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data, however you have the right to withdraw consent to marketing at any time by contacting us.

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.

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, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

To manage our relationship with you which will include (a) notifying you about changes to our terms or privacy policy, and (b) asking you to leave a review or take a survey.

Type of data: (a) Identity, (b) Contact, (c) Profile and (d) Marketing and Communications.

Lawful basis for processing including basis of legitimate interest: (a) Performance of a contract with you, (b) Necessary to comply with a legal obligation and (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).

Where we send users important notices – such as changes to our terms, conditions and policies – because this information is important to users interaction with us, they may not opt out of receiving these communications.

To administer and protect our business, website and related platforms (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).

Type of data: (a) Identity, (b) Contact and (c) Technical.

Lawful basis for processing including basis of legitimate interest: (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) and (b) Necessary to comply with a legal obligation.

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

Type of data: (a) Identity, (b) Contact, (c) Profile, (d) Usage, (e) Marketing and Communications and (f) Technical.

Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).

To use data analytics to improve our website, platform, products/services, marketing, customer relationships and experiences.

Type of data: (a) Technical and (b) Usage.

Lawful basis for processing including basis of legitimate interest: Necessary 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).

To make suggestions and recommendations to you about business opportunities, goods or services that may be of interest to you.

Type of data: (a) Identity, (b) Contact, (c) Technical, (d) Usage, (e) Profile and (f) Marketing and Communications.

Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to develop our products/services and grow our business).

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

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 services from us and you have not opted out of receiving that marketing.

We will get your express opt-in consent before we share your personal data with any third party 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 otherwise by contacting us at any time.

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 legal 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.

DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes set out in the table above.

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.

INTERNATIONAL TRANSFERS

We share your personal data within the Lefty Group and The Independents Group, and certain members of each are based outside the EEA. This will therefore involve transferring your data outside the European Economic Area (EEA).

We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data by way of a Group Data Sharing Agreement.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

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

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as reasonably necessary to fullfil 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.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we will 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.

Acceptance of these terms

By using this website or our platform, you signify your acceptance of this privacy policy. If you do not agree to this privacy policy, please do not use this website or our platform. Further, your continued use of our website and/or platform following the posting of changes to this privacy policy will be deemed your acceptance of those changes.

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see the Glossary below to find out more about these rights.

In particular, you can withdraw your email consent for marketing related communication at any time. You will find a sign-out or opt-out link at the end of each email. We reserve our rights to send business related communication for processing contract and/or service agreement.

Please contact us if you wish to exercise any of the rights set out above or you have any questions or concerns about this privacy policy or would like the personally identifiable information that you have provided to be removed from our files.

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 LIMIT 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.

GLOSSARY:

LAWFUL BASIS AND PERSONAL DATA TYPES

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Personal Data types which we may collect, use, store and transfer:

INTERNAL THIRD PARTIES

Other companies in the Lefty Group and The Independents Group (acting as joint controllers or processors) and who are based within and outside the EEA and provide IT and system administration services, undertake leadership reporting and/or have access to group-wide databases.

EXTERNAL THIRD PARTIES

Service providers (acting as processors) based within and outside the EEA who provide various IT and system administration services.

Professional advisers (acting as processors or joint controllers) including lawyers, bankers, auditors and insurers based within and outside the EEA who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue & Customs, regulators and other authorities (acting as processors or joint controllers) based within and outside the EEA who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.