TCF Data Policies

TCF Privacy Policy

Privacy Notice Effective Date: May 10th 2018
In order to see any updates to this Privacy Policy, please consult this page on a regular basis.

Your privacy is important to us. At The Customer Framework we are committed to ensuring that your privacy is respected and protected.

Thank you for visiting the Privacy Notice page within The Customer Framework website (www.thecustomerframework.com).

As part of this commitment, we have prepared this Privacy Notice (the “Notice”) to explain the manner in which The Customer Framework collects, uses, transfers, discloses and otherwise treats the personal data of visitors.

This Notice applies to all websites that are owned and operated by The Customer Framework Ltd. The Customer Framework is the data controller with respect to the personal data collected and processed via its respective website.

The Customer Framework Ltd (referred to as “our”, “us” and “we” in this notice) is a global management and marketing consultancy. We help our clients to improve how they market their products and services, providing subject matter expertise in all areas of business and marketing management. We believe that the responsible use of data supports business growth and builds strong relationships between brand and consumer. As a business, we are committed to respecting and protecting the privacy of all individuals with whom we interact. We are committed to being transparent in our handling of personal data and processing personal data at all times in accordance with applicable privacy and data protection laws. This Privacy Notice explains how we may collect and use personal data from you when you use our website www.thecustomerframework.com.   

About Us

We are The Customer Framework Ltd.
Our company registration number is 5972093.
Our office is registered at 27a High Street, Esher, Surrey, KT10 9RL.
Our VAT number is 901 7815 36.

This Privacy Notice explains the following:

  • What personal data we collect on this website;
  • How we use this information;
  • How we store your personal data;
  • How we secure your personal data;
  • Whether we disclose or share your personal data;
  • Your choice regarding the personal data you provide to us;
  • Our responsibility for website links;
  • How to contact us if you have any questions

In the Supplementary Information section of this Privacy Notice, we explain what is meant by “personal data” and other terms used in this notice.

The personal data we collect on this website
We collect information about how you use our website and the device(s) you use to access our site. This includes collecting unique mobile device ID or the internet protocol (IP) address online identifiers, which are numbers that can uniquely identify a specific computer or other network device on the internet. This information is linked to a cookie ID, which we receive and process.  For further information on our use of cookies, please see our Cookies Notice (available here).

We also collect information about you if you make use of any of the interactive features within our website that rely on a personalised response, or where you ask us to respond to a query you have, or where you download content, or add your details to one of our alert or subscription services. The information we collect is limited to the details we need to provide the specific service you have asked for.  We do not collect sensitive information, such as your political or religious beliefs, ethnic background, sexual preference, health or any other sensitive information.

We do not actively seek to collect information about children aged 16 or under.  If you have any concerns about your child’s privacy in relation to our services, or if you believe that your child may have entered personal data onto our Website, please contact us at nick.broomfield@thecustomerframework.com.
We will delete such information from our records within a reasonable time.

How we use this information

Except where required by law, we only use the personal data you provide for the following purposes:

  • to deliver the specific information or services you have requested. For example, if you have requested further information on our services or content, or wish to subscribe to our alert service, or download a piece of content, or submit an enquiry through this site. We will only use the email address you provide to us to respond to that request. Without your express consent, we will not use your contact details for any other purpose.
  • We ensure that we always have an appropriate legal basis for processing your personal information. For the most part, the processing of your personal data is based either on a) our legitimate interests related to us providing you services you have requested or otherwise your customer relationship with us, or b) your consent, where requested. 

How we store your personal data
We are committed to ensuring your personal data is kept secure and confidential and not kept for longer than is necessary. From time to time we may ask other members of our group, or third party service providers, to help us manage our information technology systems. Some of these systems may be located in countries overseas, including countries located outside the European Economic Area (EEA).  

We will only transfer your information to a third party service provider or overseas, where we are satisfied that adequate levels of protection are in place to protect the integrity and security of any information being processed and compliance with applicable privacy and data protection laws. These measures may include the use of Standard Contractual Clauses, the EU-US Privacy Shield, Swiss-US Privacy Shield or your consent. You may request further information on the legal security measures used for such transfers via the contact details given in this Privacy Notice.

How we secure your personal information
We have appropriate security measures in place to prevent unlawful or unauthorised use, access or accidental loss of personal information. We also seek to ensure our service providers do the same. 

Information Sharing and Disclosure
We do not sell or rent any personal data about you to any third party.

We may disclose personal datain response to legal process, for example in response to a court order or a subpoena, or in response to a law enforcement agency’s request, or where we believe it is necessary to investigate, prevent or take action regarding illegal activities, and as otherwise required by law. Our agents and contractors may have access to personally identifiable information to help carry out the services they are performing for us.

Your choice regarding the personal data you provide to us

General rights

  • If you wish to stop receiving marketing communications from us then please click on the “unsubscribe” link at the bottom of the relevant mailing. If you wish to opt-out completely then please contact us at using the details provided below.
  • If you would like us to delete your information from our records, please contact us using the contact details below and we will respond within a reasonable time. Please note that we may be required to retain certain information by law and/or for our own legitimate business purpose.

Users from the European Economic Area

If you are from the European Economic Area, you have rights (with some exceptions and restrictions) to:

  • object to our processing of your personal data.  You can object at any time and we shall stop processing the information you have objected to, unless we can show compelling legitimate grounds to continue that processing;
  • access your personal data. If you make this kind of request and we hold personal data about you, we are required to provide you with information on it, including a description and copy of the personal data and why we are processing it;
  • request erasure of your personal data in certain circumstances.
  • request correction or updating of the personal data that we hold about you and that is inaccurate;
  • request the restriction of our processing of your personal data in some situations. If you request this, we can continue to store your personal data but are restricted from processing it while the restriction is in place;
  • withdraw your consent to our use of your personal data. When you use our website you may have been asked to consent to the dropping of a cookie. You may withdraw your consent to our processing of your personal data that has been derived from cookies. If you do withdraw consent, that will not affect the lawfulness of what we have done with your personal data before you withdrew consent;
  • complain to your local data protection authority about our collection or use of your personal data. For example, in the UK, the local data protection authority is the UK Information Commissioner’s Office.

If you exercise the rights above and there is any question about who you are, we may require you to provide information from which we can satisfy ourselves as to your identity.

If you are from the European Economic Area and would like to exercise any of these rights in relation to any information we hold about you via this website please contact us using the contact details provided below. We will consider and respond to your request in accordance with the relevant law.

Our responsibility for website links

This Privacy Notice is limited to the personal data which we collect and use via this website. We do provide links within this site to other websites, including social media sites such as Facebook, Twitter and LinkedIn. If you follow these links, you should use these sites in conjunction with their applicable user and privacy notices as their data practices fall outside the scope of this Privacy Notice. Further, we can have no responsibility for or control over the information collected by any third party website and we cannot be responsible for the protection and privacy of any information which you may provide on such websites.

Updates
This Privacy Notice may be updated from time to time to reflect changes in law, best practice or a change in our practices regarding the treatment of personal information. If you do not agree to the changes, please do not continue to use our website. You should check this notice frequently for updates. This notice was last updated on May 10th 2018.

Contact us
If you have any questions about our approach to privacy or you would like to exercise any of the rights mentioned in this Privacy Notice you can contact our Data Protection Officer in any of the following ways:

Address: Mr Nick Broomfield, CMO & Data Protection Officer, The Customer Framework Ltd, Regent’s Place, 20 Triton Street, London, NW1 3BF, UK

Telephone: (+44) (0) 203 130 1090

Email: nick.broomfield@thecustomerframework.com

SUPPLEMENTARY INFORMATION
In this Supplementary Information section, we explain some of terminology used in this Privacy Notice.

personal data” – any information that relates to you (or from which you can be identified).

“processing” – means doing anything with data. For example, it includes collecting it, holding it, disclosing it and deleting it.

European Economic Area” – the 28 countries in the European Union plus Iceland, Liechtenstein and Norway.

transfer” – sending personal data outside the European Economic Area (e.g. by storing it on equipment located outside the European Economic Area), or allowing someone from outside the European Economic Area to access the personal data.


TCF Disclaimer

The information contained in this site is provided for informational purposes only, and should not be construed as legal advice on any subject matter.

You should not act or refrain from acting on the basis of any content included in this site without seeking legal or other professional advice. The contents of this site contain general information and may not reflect current legal developments or address your situation. We disclaim all liability for actions you take or fail to take based on any content on this site.

This site contains links to other web sites. We are not responsible for the privacy practices or the content of such web sites, and we do not endorse such sites.

Copyright and Reproduction Notice
Copyright © 2018, The Customer Framework Ltd. All rights reserved.

Any reproduction of any content of this site is prohibited other than reproductions for individual, non-commercial, and informational use. This limited permission to recopy does not allow you to modify or incorporate any portion of the contents in any work or publication regardless of the medium. You may not recopy and share reproductions with a third party.

The Customer Framework Blog Content
All blog content is provided for informational purposes only; it is not legal advice and may not be relied upon as such. The Customer Framework makes no representations as to the accuracy, completeness, suitability, or validity of any information within the blog content and will not be liable for any errors or omissions in them for delays in publication of information, or for any losses, injuries, or damages arising from the display or use for any other reason whatsoever. No endorsement of any product or service mentioned within the blog content is expressed or implied. All information is provided on an as-is basis. Linked resources are beyond the control of The Customer Framework, and The Customer Framework shall have no responsibility whatsoever for the acts or omissions of such third parties. Comments and blogs are solely the work of their authors and as such do not necessarily reflect the views of The Customer Framework Ltd. Neither the use of content provided on the blogs nor the submission of any information through the blogs creates any relationship between you and The Customer Framework.

Please be aware that any information that you provide through the blog is not secure and it is not privileged or confidential. In fact, by posting you intend that your comment be displayed so that others can read it and comment on it.

The Customer Framework reserves the right to edit submissions for any reason at its sole discretion.


TCF Cookies Notice

How we deploy “cookies”
Cookies are small packets of information stored by your web browser when you visit certain websites, including our website. Cookies are generally used by websites to improve your user experience by enabling that website to ‘remember’ you, either strictly for the duration of your visit (using a “Session” cookie which is erased when you close your browser) or for repeat visits (using a “Permanent” cookie). We do not use cookies to store any personally identifiable information about you.

Our site uses the following types of cookies:

Strictly necessary cookies
We deploy cookies to help us to identify how users navigate to and around our website and to enable some of the features within the site that may be beneficial to you (for example, language preferences, or print page features). This helps us deliver an effective online service to you. These are known as “First Party” cookies.

The strictly necessary cookies are listed below:

Cookie NamePurpose
__RequestVerificationTokenThis is an anti-forgery cookie set by web applications built using ASP.NET MVC technologies. It is designed to stop unauthorised posting of content to a website, known as Cross-Site Request Forgery. It holds no information about the user and is destroyed on closing the browser.

Functionality Cookies
These cookies allow our sites to remember choices you make (such as user name, or region you are in) and provide enhanced, more personal features.  These cookies can also be used to remember changes you have made to text size, fonts and other parts of web page which you can customise.  The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.

The functionality cookies are listed below:

Cookie NamePurpose
languageThis cookie is used to store language preferences, to serve up content in the stored language.

Performance cookies
We may also use cookies issued by third parties (“Third Party” cookies) to track the websites you visited or search terms you used immediately prior to visiting this site, or to collect information about how visitors use the site.  We use Google Analytics for this purpose.  Google Analytics uses its own cookies. These cookies don’t collect information that identify a visitor.  All information these cookies collect is aggregated and therefore anonymous.  It is only used to improve how the site works.  You can find out more about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies .

You can avoid the use of Google Analytics relating to your use of our site by downloading and installing the Browser Plugin available via this link: 

http://tools.google.com/dlpage/gaoptout?hl=en-GB

The performance cookies are listed below:

Cookie NamePurpose
_gid This cookie name is associated with Google Universal Analytics. This cookie stores and updates a unique value for each page visited.
_pk_id*This cookie name is associated with the Piwik open source web analytics platform. It is used to help website owners track visitor behaviour and measure site performance. It is a pattern type cookie, where the prefix _pk_id is followed by a short series of numbers and letters, which is believed to be a reference code for the domain setting the cookie.
_gatThis cookie name is associated with Google Universal Analytics, according to documentation it is used to throttle the request rate - limiting the collection of data on high traffic sites. It expires after 10 minutes.
_pk_ses*This cookie name is associated with the Piwik open source web analytics platform. It is used to help website owners track visitor behaviour and measure site performance. It is a pattern type cookie, where the prefix _pk_ses is followed by a short series of numbers and letters, which is believed to be a reference code for the domain setting the cookie.
_gaThis cookie name is asssociated with Google Universal Analytics - which is a significant update to Google's more commonly used analytics service. This cookie is used to distinguish unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports. By default it is set to expire after 2 years, although this is customisable by website owners.
JSESSIONIDThis domain is third party performance cookie. It is controlled by New Relic, which provides a platform for monitoring the performance of web and mobile applications.

Social Media Cookies 
These cookies are used when you share information using a social media sharing button or “like” button on our site or you link your account or engage with our content on or through a social networking site such as Facebook, Twitter or Google+.  The social network will record that you have done this.  This information may be linked to targeting/advertising activities.

The social media cookies are listed below:

Cookie NamePurpose
Google DoubleClick We use these cookies to measure the effectiveness of our online marketing campaigns; to improve reporting on campaign performance; and to avoid showing ads the user has already seen.
Google DoubleClick

Google Analytics

These cookies are used to collect information about how visitors use our website. We use the information to help us improve the website. The cookies collect information in an anonymous form, including the number of visitors to the website, where visitors have come to the website from and the pages they visited.
Twitter
auth_token
twll
__utmz
secure_session
guest_id
__utma
remember_checked
remember_checked_on
Twitter uses cookies and other similar technologies, such as pixels or local storage, to help provide you with a better, faster, and safer experience. Like many websites, Twitter uses cookies to discover how people are using their services and to make them work better.
YouTube
SID and HSID
YouTube is a Google owned platform for hosting and sharing videos. YouTube collects user data through videos embedded in websites, which is aggregated with profile data from other Google services in order to display targeted advertising to web visitors across a broad range of their own and other websites. the HSID cookies is used by Google in combination with SID to verify Google user account and most recent login time.
DemographicsThis cookie is used for demographic profiling and targeting for advertising.
VISITOR_INFO1_LIVEThis cookie is used as a unique identifier to track viewing of videos.
PREFThis is a common Google cookie, used across several of their services. Stores user preference, can be used to personalise ads on google searches.
APISID
SSID
LOGIN_INFO
YSC
SAPISID
These cookies are used by YouTube to collect user data through videos embedded in websites, which is aggregated with profile data from other Google services in order to display targeted advertising to web visitors across a broad range of their own and other websites.

How to reject cookies
If you don’t want to receive cookies, you can alter your browser settings.  The procedure for doing so varies from one browser application to another.  If you wish to reject cookies from our site, but wish to accept those from other sites, you may choose the option in your browser settings to receive a notice before a cookie is stored on your device.  Please consult the “Help” section of your browser for more information. 

To find out more, please consult the following:  http://www.allaboutcookies.org/manage-cookiies  and www.youronlinechoices.com .  By disabling cookies, you may be prevented from accessing some features of our site or certain content or functionality may not be available.