1. This is a notice to inform you of our policy about all information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.
2. We take seriously the protection of your privacy and confidentiality. We understand that all visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them, and will not accidentally fall into the hands of a third party.
3. We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
4. Our policy complies with UK law, including that required by the EU General Data Protection Regulation (GDPR), which came into effect on 25 May 2018.
6. Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.
The bases on which we process information about you
The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.
If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.
If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.
1. Information we process because we have a contractual obligation with you
When you create an account on our website, buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.
In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.
We may use it in order to:
1.1. verify your identity for security purposes
1.2. sell products to you
1.3. provide you with our services
1.4. provide you with suggestions and advice on products, services and how to obtain the most from using our website
We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.
Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.
We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
2. Information we process with your consent
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including job opportunities and our products and services, you provide your consent to us to process information that may be personal information.
Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.
Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on our website.
If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.
We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by instructing us at email@example.com. However, if you do so, you may not be able to use our website or our services further.
3. Information we process for the purposes of legitimate interests
We may process information on the basis there is a legitimate interest, either to you or to us, of doing so. Where we process your information on this basis, we do after having given careful consideration to:
• whether the same objective could be achieved through other means
• whether processing (or not processing) might cause you harm
• whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so
For example, we may process your data on this basis for the purposes of:
• record-keeping for the proper and necessary administration of our organisation
• responding to unsolicited communication from you to which we believe you would expect a response
• protecting and asserting the legal rights of any party
• insuring against or obtaining professional advice that is required to manage organisational risk
• protecting your interests where we believe we have a duty to do so
• understanding our readers, promoting our services and operating any of our sites and apps efficiently for the creation, publication and distribution of news, media and related journalistic content both online and, if we choose, in print form, whether in the UK or globally. This means, for example, that we will rely on our legitimate interest to analyse what content has been viewed on our sites and apps. It is also in our legitimate interest to carry out marketing analysis to determine what products and services may be relevant to the interests of our readers.
4. Information we process because we have a legal obligation
We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation.
For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.
This may include your personal information.
Specific uses of information you provide to us
5. Information provided on the understanding that it will be shared with a third party
Our website allows you to post information with a view to that information being read, copied, downloaded, or used by other people.
Examples may include:
5.1. posting a message
5.2. tagging an image
5.3. clicking on an icon next to another visitor’s message to convey your agreement, disagreement or thanks
In posting personal information, it is up to you to satisfy yourself about the privacy level of every person who might use it.
We do not specifically use this information except to allow it to be displayed or shared.
We do store it, and we reserve a right to use it in the future in any way we decide.
Once your information enters the public domain, we have no control over what any individual third party may do with it. We can accept no responsibility for their actions at any time.
Provided your request is reasonable and there is no legal basis for us to retain it, then at our discretion we may agree to your request to delete personal information that you have posted. You can make a request by contacting us at firstname.lastname@example.org.
As outlined above, based on our legitimate interest we provide you with information about the CheekyLittleCareers’s products and services, and other information which we think you may find interesting. We may send you such information by e-mail unless you have asked us not to do so.
If at any time you do not want your information used for direct marketing purposes please contact us at email@example.com and if you decide that you no longer wish to receive marketing e-mails from us, please contact us at firstname.lastname@example.org.
7. Complaints regarding content on our website
Our website is a primarily a showcase for our membership organisation but also a publishing medium. Members are able to publish information about himself, herself or some other person.
We attempt to moderate user generated content, but we are not always able to do so as soon as that content is published.
If you complain about any of the content on our website, we shall investigate your complaint.
If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate.
Free speech is a fundamental right, so we have to make a judgement as to whose right will be obstructed: yours, or that of the person who posted the content that offends you.
If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.
8. Job application and employment
From time to time we may advertise employment opportunities at CheekyLittleCareers.
If you send us information in connection with a job application, we may keep it for up to three years in case we decide to contact you at a later date.
If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for six years before destroying or deleting it.
9. Sending a message to our support team
When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need.
We record your request and our reply in order to increase the efficiency of our organisation.
We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high-quality service.
When we receive a complaint, we record all the information you have given to us.
We use that information to resolve your complaint.
If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.
We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.
11. Affiliate and business partner information
This is information given to us by you in your capacity as an affiliate of us or as a business partner.
It allows us to recognise visitors that you have referred to us. It also includes information that allows us to transfer commission to you.
The information is not used for any other purpose.
We undertake to preserve the confidentiality of the information and of the terms of our relationship. We expect any affiliate or partner to agree to reciprocate this policy.
Use of information we collect through automated systems when you visit our website
What are Cookies?
Cookies are small bits of text that are downloaded to your browser as you use the internet. It is generated by a web page server, which is basically the computer that operates a website. Their purpose of cookies is to carry bits of useful information about your interaction with the website that sets them.
Cookies generally do not contain any information that would identify a person. Usually they contain a string of text or ‘unique identifier’. This acts like a label. When a website sees the string of text it has set in a cookie, it knows the browser is one it has seen before. A cookie can therefore be thought of as an internet user’s identification card, which tells a website when the user has returned.
If you use a different computer, open a new web browser or delete your cookies, the website will treat you as if you have arrived for the first time (and a new cookie will be set).
What Do They Do?
Cookies make the interaction between users and websites faster and easier. For example, without cookies, it would be very difficult to remember your preferences or registration details when you come back to a website.
Cookies are used to save time and make the browsing experience more efficient and tailored to you. They also allow website operators to monitor the way in which you use the website and build up a user profile for marketing and advertising purposes.
Different Types of Cookies
There are two types of cookies that are typically used – and we use both of these on the Website; ‘Session’ and ‘Persistent’ cookies.
Session cookies only last for your online session and disappear from your computer when you close your browser.
Persistent cookies are set the first time you visit a website. They help identify a unique browser to a website. They will remain there for a period determined by the web page server when the cookie is set. For example, analytics cookies (described in more detail below) are typically set for 18 months but can be for longer.
Cookies Set by CheekyLittleCareers
CheekyLittleCareers uses certain cookies which are essential to the proper functioning of the Website. This category of cookies includes those which: identify you as a valid user, maintain and recognise you when you login and keep track of your usage history.
Third Party Analytics Cookies
Google Analytics uses a number of cookies to determine unique users, keep track of pages within a given site and how you arrived at our Website. You can opt out of Google Analytics cookies by visiting http://tools.google.com/dlpage/gaoptout.
How Can I Disable Cookies Using my Browser?
Most browsers have cookies turned on as a default, but you can always disable cookies or only allow non-persistent cookies via your browser preferences. Please note that if you choose to disable cookies this will adversely affect the functionality on the Website and you won’t be able to enjoy it as much.
You can set your browser to delete cookies every time you finish browsing. Users can also set their browser to prompt them each time a cookie is offered. Find out more by visiting the ‘Help’ sections on your browser for more information.
Alternatively, you can visit www.aboutcookies.org which contains comprehensive information on how to disable cookies on a wide variety of browsers.
To track how you use our website.
To record whether you have seen specific messages we display on our website.
To keep you signed in our site.
To record your answers to surveys and questionnaires on our site while you complete them.
To record the conversation thread during a live chat with our support team.
13. Personal identifiers from your browsing activity
Requests by your web browser to our servers for web pages and other content on our website are recorded.
We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.
Disclosure and sharing of your information
14. Information we obtain from third parties
Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use.
15. Third party advertising on our website
Third parties may advertise on our website. In doing so, those parties, their agents or other companies working for them may use technology that automatically collects information about you when their advertisement is displayed on our website.
We do not have control over these technologies or the data that these parties obtain. Accordingly, this privacy notice does not cover the information practices of these third parties.
16. Credit reference
To assist in combating fraud, we may share information with credit reference agencies, so far as it relates to clients or customers who instruct their credit card issuer to cancel payment to us without having first provided an acceptable reason to us and given us the opportunity to refund their money.
17. Data may be processed outside the European Union
Our website is hosted in the United Kingdom.
We may also use outsourced services and consultants in countries outside the European Union from time to time in other aspects of our business.
Accordingly data obtained within the UK or any other country could be processed outside the European Union.
For example, some of the software our website uses may have been developed in the United States of America.
We use the following safeguards with respect to data transferred outside the European Union:
17.1. the processor is within the same corporate group as our business or
organisation and abides by the same binding corporate rules regarding data processing.
17.2. we comply with a code of conduct approved by a supervisory authority in the European Union
17.3. we aim to include in the contracts of our third party suppliers and consultants standard clauses approved by the European Commission (sometimes called ‘the EU Model Clauses’) to ensure that their processing meets the security standards required within the EU.
Access to your own information
18. Access to your personal information
18.1. At any time you may review or update personally identifiable information that we hold about you, by signing in to your account on our website.
18.2. To obtain a copy of any information that is not provided on our website you may send us a request at email@example.com.
18.3. After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.
19. Removal of your information
If you wish us to remove personally identifiable information from our website, you may contact us at firstname.lastname@example.org.
This may limit the service we can provide to you.
20. Verification of your information
When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
21. Use of site by children
21.1. We do not sell products or provide services for purchase by children, nor do we market to children.
21.2. If you are under 18, you may use our website only with consent from a parent or guardian
22. Encryption of data sent between us
We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.
Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.
23. How you can complain
23.2. If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
23.3. If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office. This can be done at https://ico.org.uk/concerns/
24. Retention period for personal data
Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:
24.1. to provide you with the services you have requested;
24.2. to comply with other law, including for the period demanded by our tax authorities;
24.3. to support a claim or defence in court.
25. Compliance with the law
However, ultimately it is your choice as to whether you wish to use our website.
We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.