GRAVITY GLOBAL DATA PROTECTION POLICY

This is a statement of the data protection policy adopted by Gravity Global. Responsibility for the updating and dissemination of the policy rests with the Gravity Global’s Information Protection Officer. The policy is subject to regular review to reflect, for example, changes to legislation or to the structure or policies of Gravity Global. All staff are expected to apply the policy and to seek advice when required.

Gravity Global needs to collect and use certain types of information about people with whom it deals in order to operate. These include current, past and prospective clients, the company’s own employees, suppliers and others with whom the Gravity Global conducts business. This personal information must be dealt with properly however it is collected, recorded and used – whether on paper, electronically, or other means – and there are safeguards to ensure this in the Data Protection Act 1998 and EU GDPR.

We regard the lawful and correct treatment of personal information by Gravity Global as important to the achievement of our objectives and to the success of our operations, and to maintaining confidence between those with whom we deal and ourselves. We therefore need to ensure that our organisation treats personal information lawfully and correctly.

To this end, we fully endorse and adhere to the Principles of data protection, as set out in the Data Protection Act 1998 and EU GDPR.

The eight Principles require that personal information:

  1. shall be processed fairly and lawfully and, in particular, shall not be processed unless specific conditions are met;
  2. shall be obtained only for one or more specified and lawful purposes, and shall not be further processed in any manner incompatible with that purpose or those purposes;
  3. shall be adequate, relevant and not excessive in relation to the purpose or purposes for which they are processed;
  4. shall be accurate and, where necessary, kept up to date;
  5. shall not be kept for longer than is necessary for the specified purpose(s);
  6. shall be processed in accordance with the rights of data subjects under the Act;
  7. should be subject to appropriate technical and organisational measures to prevent the unauthorised or unlawful processing of personal data, or the accidental loss, destruction, or damage to personal data;
  8. shall not be transferred to a country or territory outside the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.

Therefore, Gravity Global will, through appropriate management and strict application of criteria and controls:

  • observe fully conditions regarding the fair collection and use of information;
  • meet its legal obligations to specify the purposes for which information is used;
  • collect and process appropriate information only to the extent that it is needed to fulfil our operational needs or to comply with any legal requirements;
  • ensure the quality of information used;
  • ensure that the information is held for no longer than is necessary;
  • ensure that the rights of people about whom information is held can be fully exercised under the Act (i.e. the right to be informed that processing is being undertaken, to access one’s personal information; to prevent processing in certain circumstances, and to correct, rectify, block or erase information that is regarded as wrong information);
  • take appropriate technical and organisational security measures to safeguard personal information;
  • ensure that personal information is not transferred abroad without suitable safeguards.

To assist in achieving compliance with the principles, Gravity Global:

  • has appointed an Information Protection Officer at a senior level with specific responsibility for data protection within Gravity Global;
  • created a dedicated Information Access Team to assist Gravity Global staff in understanding and applying the data protection principles and to liaise with external parties;

Our Data Protection Officer is:
Steve Long
slong@gravitylondon.com
02073308810

 

What we collect

We may collect the following information:

– name and job title
– contact information including email address
– demographic information such as postcode, preferences and interests
– other information relevant to customer surveys and/or offers

What we do with the information we gather

We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:

– Internal record keeping.
– We may use the information to improve our products and services.
– We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided.
– From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone, fax or mail. We may use the information to customise the website according to your interests.

Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use two types of cookies:

Session cookies, which are temporary cookies that remain in the cookie file of your computer until you close the browser (at which point they are deleted).

Persistent or stored cookies that remain permanently on the cookie file of your computer.

Also, we use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Controlling your personal information

We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.

You may request details of personal information which we hold about you under the Data Protection Act 1998. A small fee will be payable. If you would like a copy of the information held on you please write to Gravity London, 69 Wilson Street, London, EC2A 2BB.

If you believe that any information we are holding on you is incorrect or incomplete, please write to us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.