1.1 Important information and who we are
At 26 (“we”, “us”, or “our”) we are committed to protecting and respecting your privacy and Personal Data in compliance with the United Kingdom General Data Protection Regulation (“GDPR”), the Data Protection Act 2018 and all other relevant and applicable laws and regulations of the United Kingdom.
1.2 Who is Your Data Controller
As your Data Controller, 26 will determine the purposes for which and the manner in which any Personal Data is processed. Additionally, 26 will be responsible for your personal data as well as compliance with data protection principles.
Address: twentysix Ltd, 23 Bow Street, London, WC2E 7A
Privacy Contact Email: firstname.lastname@example.org
ICO Registration Number: Z1435694
Any inquiries about your data should be sent to the above email. It can also be sent directly to the company, if you prefer, in a letter to the listed address. We cannot guarantee prompt responses if physical mail is your chosen method of communication.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
1.3 26’s Processing as a Controller, and Processors’ responsibility to you - the visitor
While managing our responsibilities as a Data Controller, we have third party providers who will deal with your data on our behalf (known as “Processors”). The responsibilities described below may be assigned to a processor, or may be taken to apply to the organisation as a whole. The Data Controller and our Processors have the following responsibilities:
- Ensure that all processing of Personal Data is governed by one of the legal bases laid out in the GDPR (see section 2 below for more information on those bases);
- Ensure that Processors authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality;
- Implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk associated with the processing of Personal Data;
- Obtain the prior specific or general authorisation of the Controller before engaging another Processor;
- Assist the Controller in the fulfilment of the Controller's obligation to respond to requests for exercising the data subject's rights;
- Make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in the GDPR and allow for and contribute to audits, including inspections, conducted by the Controller or another auditor mandated by the Controller;
- Maintain a record of all categories of processing activities carried out on behalf of a Controller;
- Cooperate, on request, with the supervisory authority in the performance of its tasks;
- Ensure that any person acting under the authority of the Processor who has access to Personal Data does not process Personal Data except on instructions from the Controller; and Notify the Controller without undue delay after becoming aware of a Personal Data Breach
2. Legal basis for data collection
“Personal Data” 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 collect, use, store and transfer different kinds of Personal Data about you which we have grouped together below. Not all of the following types of data will necessarily be collected from you, but this is the full scope of data that we collect and when we collect it from you:
- Contact Data via contact form: This covers any data relating to your phone number, addresses, email addresses, and message content.
- Legal basis: Legitimate interest.
- Marketing and Communications Data: This is your preferences in receiving marketing information and other information from us for our marketing newsletters. It will include your name & email address.
- Legal basis: Consent.
- Job application data: containing information such as your name, location, email, cv data and cover letter, we use this to decide if you are a suitable candidate for the role you have applied for.
- Legal basis: Contract, legal obligation for any adjustment data covered by the Equality Act 2010, sensitive data will be processed according to Article 9(2)(b).
- Technical Data: This is your IP address, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to engage with us. This is used for the purpose of analytics, with your consent, as well as to improve site functionality.
- Legal basis: Legitimate interest, consent.
For further information on the legal bases and what they mean, please refer to section 2.2 below.
While visiting our website, 26 will not collect any special categories of Personal Data according to the UK GDPR. While applying for a job at 26, you may provide us with special category data. You can find more information on how and why we process this data in the privacy notice available on our Applicant Tracking System (ATS) presented during the registration process.
26 will access and use your personal data only for the purposes for which you have submitted it to us to (a) provide information to you, (b) make contact with you, (c) provide services to you, or (d) maintain the operations and security of the website and services we provide to you. We will not use your personal information for any other purposes, for example for the communication of marketing materials, unless we have your specific consent that permits us to do so.
2.2 Legal Bases Explained
There are several justifiable reasons under the UK GDPR that allow the collection and processing of Personal Data. The main bases we rely upon are the following:
- “Consent”: Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’ to a service.
- “Contractual Obligations”: We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.
- “Compliance with legal obligations”: Organisations occasionally have to process data in order to comply with legal regulations and legal & regulatory requirements.
- “Legitimate Interest”: We might need to collect certain information from you to be able to meet our legitimate interests - this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. Examples could be your name, so that we have a record of who to contact when you use our contact form. When legitimate interest is relied upon, Twentysix will conduct a Legitimate Interest Assessment (LIA) to validate the processing is not considered unfair or infringing on the data protection rights of any individuals we work with.
2.3 Other Scenarios Where We Process Your Data
CCTV – We monitor our premises both internal and external on and around the premises for the purpose of providing security and investigating any crimes or serious complaints relating to our business or anyone visiting our premises.
A retention policy in place to ensure data is not retained beyond the aforementioned purpose, and access is limited to necessary personnel. The lawful basis of this processing is Article 6 (1) (f) which allows us to process personal data when its necessary for the purposes of our legitimate interests, contract, legal compliance and vital interests.
We have a legal and contractual duty to protect our employees from harm and we have a legitimate interest in making sure people aren’t kept waiting outside. For more information, please contact our Data Protection Officer at email@example.com.
Guest WiFi - Guests at the 26 office have access to wireless internet. We will provide you with a username and password and record the device address & automatically assign you an IP Address. We don’t ask for you to agree to terms, just to the fact that we have no responsibility over your use of the internet while on site.
Data retained is limited to technical information (e.g., IP Address) and usage information (e.g., Session length) which is used for security purposes and to guarantee quality service.
The lawful basis of this processing is Article 6 (1) (f) which allows us to process personal data when its necessary for the purposes of our legitimate interests and your legitimate interest in receiving free WiFi when you request to be connected to it.
3. How we use your personal data
3.1 Sources of Data
We primarily obtain the data from you (including via the devices you use) while visiting the site. If we do not collect the personal data directly from you, we will also tell you the source of the personal data and, if applicable, whether it is sourced from publicly available sources.
3.2 Social media
Note: Information processed on our social media pages is covered in this policy because providing a notice on the social media page itself is often challenging. You have likely been redirected here from one of our social media pages.
26 operates the following social media pages:
- Facebook: facebook.com or mobile app by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA or Facebook Ireland Ltd., 4 Grand Canal Square, Dublin 2, Ireland, please refer to privacy notice https://www.facebook.com/policy.php, opt-out: https://www.facebook.com/ads/preferences or https://www.facebook.com/settings;
- Twitter: twitter.com or mobile app by Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA, please also refer to privacy notice https://twitter.com/en/privacy, opt-out: https://twitter.com/personalization;
- LinkedIn: linkedin.com or linkedin mobile app by LinkedIn Corporation, Legal Department – Privacy, 1000 W. Maude Ave, Sunnyvale, CA 94085, USA / LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland, please also refer to https://www.linkedin.com/legal/privacy-policy / https://www.linkedin.com/psettings/privacy
- Instagram: instagram.com or mobile app by Facebook Ireland Ltd., 4 Grand Canal Square, Dublin 2, Ireland, please refer to privacy notice http://instagram.com/about/legal/privacy/; opt-out: https://www.instagram.com/accounts/privacy_and_security/
Controller: When you visit our social media pages, personal data is processed both by us and by the responsible social media provider as the responsible party. The provider assumes legal data protection obligations towards you as the user, such as information on processing, and is the contact person for your rights.
Data Transfer: For our UK and EU visitors, you should be aware that the use of the above social media sites will involve a transfer of data to the United States. If your personal data is transferred to countries outside the United Kingdom or European Union, the Social Media provider regularly provide appropriate guarantees, for example by concluding the Standard Contractual Clauses issued by the European Commission, the International Data Transfer Agreements of the UK, or by adhering to approved Binding Corporate Rules to ensure that the transfer of data takes place with the same level of data protection that corresponds to the GDPR. Adhering to these requirements are the responsibility of the social media provider, though we are happy to help if you have queries about how this works.
Legal Basis: We can communicate with you on social media and provide you with relevant business information. We may also receive data from you via comments, shared images/files or reactions. Data processing occurs according to several legal bases, depending on the interaction.
- Art 6 (1) (a) - Consent, will be used if you enter a contest linked on one of our social media channels.
- Art 6 (1) (b) - Necessary for contract or prior to a contract, if we are processing your contact information prior to engaging in a contract.
- Art 6 (1) (f) - Legitimate interest, as we aim to improve our services by interacting with customers and clients that have a clear interest in the service we provide.
Note: the providers of the social media pages may use your data to analyse and improve their services, but this information can be found in their privacy policies.
Your Rights: Your rights will generally be managed by contacting the social media platform directly. You also have the right to lodge a complaint with the supervisory authority - ICO, for our UK visitors, respective EU authority for EU countries.
3.3 Recipients, or Categories of Recipients, of the Personal Data
When processing your data, we work with service providers who have access to your data. The categories of recipients are as follows:
- software companies that enable us to provide our services, help us to improve them and/or serve us for marketing purposes (for example, to send newsletters, emails, manage customer contacts or applications);
- public bodies and administrations to the extent that we are legally obliged to do so;
- hosting providers;
- social media platforms; and
- email marketing - Hubspot (EEA)
- web hosting - Microsoft Azure (UK)
- ads/targeting/statistics - Google Analytics (USA), LinkedIn (USA), Microsoft Clarirty (USA)
- cookie consent management - Cookiebot (EEA)
- external platform content - Vimeo (USA), Zoom (USA)
3.4 Marketing and Content Updates
You will receive marketing and new content communications from us if you opt into receiving those communications. We may make suggestions and recommendations to you about goods or services that may be of interest to you, but only if we have a reasonable expectation that you would benefit from or be interested in these services in line with the PECR. The lawful basis for this processing is legitimate interest, and a complementary legitimate interest assessment will be conducted when required.
3.5 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.
4. Your rights and how you are protected by us
4.1 What Rights Do I Have Over 26's Use Of My Personal Data?
As a data subject under the UK GDPR, you may have the right in law to:
- Information, in accordance with Art. 15 UK GDPR,
- Rectification, in accordance with Art. 16 UK GDPR,
- Data erasure ("right to be forgotten"), in accordance with Art. 17 UK GDPR,
- Limitation of processing, pursuant to Art. 18 UK GDPR,
- Data portability, according to Art. 20 UK GDPR and/or
- Objection to the processing, pursuant to Art. 21 UK GDPR.
To exercise these rights, you can send an email to us at any point at the following email address: firstname.lastname@example.org.
We will handle any request to exercise these rights in accordance with the relevant laws, but please note that these rights may not be absolute. 26 may refuse or deny a request in accordance with these rules, though where possible you will be informed why this is happening.
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, we could refuse to comply with your request.
We may also need to request specific information from you to help us confirm your identity and ensure you have the 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.
4.2 Information On The Right To Object Pursuant To Article 21 (4) UK GDPR
You have the right to object at any time, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f) of the UK GDPR; this also applies to profiling based on these provisions. We will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the assertion, exercise, or defence of legal claims.
If your personal data is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling that is related to direct marketing.
4.3 How Does 26 Protect Customers' Personal Data?
We are concerned with keeping your data secure and protecting it from inappropriate disclosure. Any Personal Data collected by us is only accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of confidentiality. When we use subcontractors to store your data, we will not relinquish control of your Personal Data or expose it to security risks that would not have arisen had the data remained in our possession. 26 is ISO27001 accredited, and if you wish to receive more information you can always reach out to the Data Protection Officer at email@example.com.
4.4 Opting Out Of Marketing Promotions
You can ask us to stop sending you marketing messages at any time by unsubscribing.
Where you opt out of receiving these marketing messages, we will continue to retain other Personal Data provided to us as a result of interactions with us not related to your marketing preferences.
5. Your data and third parties
5.1 Will We Share Your Data With Third Parties?
We share non-Personal Data with third parties. We may share your Personal Data with subcontractors when necessary and with your consent. The sub-contractors are also subject to our confidentiality obligations, and we ensure that they adhere to the UK GDPR data protection obligations through the use of Article 28 Data Processing Agreements: they only use the personal data for the purposes for which we disclose it to them and pursuant to our instructions. If the provider is located in a third country, we apply appropriate measures. See section 9 for more information on international data transfers.
We may also share Personal Data with interested parties in the event that 26 anticipates a change in control or the acquisition of all or part of our business or assets or with interested parties in connection with the licensing of our technology.
5.2 Is my data shared with anyone else?
26 is a part of the MSQ Partners Limited group of companies. MSQ is a group of controlled undertakings which, in accordance with the UK GDPR Art. 4 (19), Recital 37 + 48, allow for a legitimate interest in sharing certain personal data within the group. This data sharing is limited to what is necessary, and primarily applies to your application to a job position at Twentysix. Your data will not be shared with other agencies within the group or with no purpose. If your data is to be shared, you will be provided with notice.
5.3 Third-Party Links
6. How long will we keep your data?
We store your personal data only as long as it is necessary to achieve the purpose of processing. In most normal cases, we store your data if you have consented to the processing until you revoke your consent. If we use the data on the basis of a legitimate interest, we will retain your data for as long as your interest in deletion or anonymization does not prevail. 26 maintains a retention policy and schedule to ensure that data is not kept longer than is necessary.
In addition, data may be stored beyond the outlined periods in certain rare circumstances where data must be kept in order to exercise legal rights or to comply with other legal obligations. In these cases, the data is deleted when a storage or retention period prescribed by law expires.
We store applicant documents for a period of six months if the application does not lead to an employment relationship and no further storage has been agreed.
7. Applying for a job at 26
When applying for a job at Twentysix, you will be redirected to our Applicant Tracking System. We’ll use all the information you provide during the recruitment process to progress your application with a view to considering your suitability for, and potentially offering you, an employment contract with us and, where required, to fulfil our legal or regulatory requirements.
We will not share any of the information you provide with any third parties for marketing purposes.
We’ll use the contact details you give us to contact you to progress your application. We may also contact you to request your feedback about our recruitment process based on our legitimate interest in developing and improving our future recruitment campaigns.
Further information can be found on our ATS site, which contains a specific privacy notice covering application data. It can be found here.
Cookies are small text files sent by us to your computer, and from your computer or mobile device to us each time you visit our website. They are unique to you or your web browser. Session-based cookies last only while your browser is open and are automatically deleted when you close your browser session. Persistent cookies last until you or your browser delete them, or until they expire.
8.1 What about other tracking technologies, like web beacons?
Cookies are not the only way to recognize or track visitors to a website. We may use other, similar technologies from time to time, like web beacons (sometimes called "tracking pixels" or "clear gifs"). These are tiny graphics files that contain a unique identifier that enable us to recognize when someone has visited our Website or opened an e-mail including them.
This allows us, for example, to monitor the traffic patterns of users from one page within a website to another, to deliver or communicate with cookies, to understand whether you have come to the website from an online advertisement displayed on a third-party website, to improve site performance, and to measure the success of e-mail marketing campaigns. In many instances, these technologies are reliant on cookies to function properly, and so declining cookies will impair their functioning.
9. International data transfers
There is a transfer of data to third countries outside of the United Kingdom and European Union. Information we collect from you could be processed in the United States or other third countries. Some third countries, such as the United States, have not currently received an adequacy decision from the European Union or UK under Article 45 of the GDPR which means that your data may not receive the same level of protection there as it does under the UK GDPR and European GDPR.
10. Notification of changes and acceptance of policy
Date: Wednesday 8th March 2023