1. Introduction
1.1 We are committed to safeguarding the privacy of our website visitors and supporters. In this policy we explain how we will handle your personal data.
1.2 This policy applies where we are acting as a data controller with respect to your personal data; in other words, where we determine the purposes and means of the processing of that personal data.
1.3 We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.
1.4 In this policy, "we", "us" and "our" refer to The Pop Factory Ltd., a company registered in England and Wales under company number 17109994, whose registered office is at Welsh Hills Works, Jenkin Street, Porth, Rhondda Cynon Taf, CF39 9PP. For more information about us, see Section 16.
2. How we use your personal data
2.1 In this Section 2 we have set out the general categories of personal data that we may process, the purposes for which we may process personal data, and the legal bases of the processing.
2.2 We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
2.3 We may process information contained in any enquiry you submit to us ("enquiry data"). The enquiry data may be processed for the purposes of responding to your enquiry and, where relevant, keeping records of that correspondence. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and campaign.
2.4 We may process information that you provide to us for the purpose of subscribing to our email updates and newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and campaign updates. The legal basis for this processing is consent.
2.5 We may process information contained in or relating to any communication that you send to us ("communication data"). The communication data may include the communication content and metadata associated with the communication. The communication data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely communications with our website visitors and supporters and the proper administration of our website and campaign.
2.6 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.7 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
3. Providing your personal data to others
3.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims.
3.2 Your personal data held in our website database will be stored on the servers of our hosting services provider. Our hosting facilities are situated within the United Kingdom.
3.3 We use Sendy, a self-hosted email platform, to manage our mailing list and send campaign updates. Sendy processes data within the United Kingdom.
3.4 We use CrowdFunder.co.uk as our crowdfunding platform. Donations made through CrowdFunder are processed by CrowdFunder and are subject to their own privacy policy, which you can view at crowdfunder.co.uk/privacy.
3.5 In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
4. International transfers of your personal data
4.1 Our website hosting facilities and email platform (Sendy) are situated within the United Kingdom. We do not routinely transfer your personal data outside the UK.
4.2 Some of our third-party service providers, including Google Analytics and Meta (Facebook), may process data outside the UK. Where this occurs, we rely on appropriate safeguards in accordance with applicable UK data protection law, including the UK International Data Transfer Agreement or equivalent mechanisms.
4.3 You acknowledge that personal data that you submit for publication through our website may be available, via the internet, around the world. We cannot prevent the use or misuse of such personal data by others.
5. Retaining and deleting personal data
5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2 Personal data that we process for any purpose shall not be kept for longer than is necessary for that purpose.
5.3 We will retain your personal data as follows:
(a) usage data will be retained for a period of 26 months following the date of collection, in line with Google Analytics default retention settings;
(b) enquiry data will be retained for a period of two years following the date of the enquiry;
(c) notification data will be retained until you unsubscribe or request deletion, after which it will be removed within 30 days;
(d) communication data will be retained for a period of two years following the date of the communication.
5.4 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
6. Security of personal data
6.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
6.2 We will store all your personal data on secure servers and in secure record-keeping systems.
6.3 Data that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.
6.4 You acknowledge that the transmission of unencrypted data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
7. Your rights
7.1 In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
7.2 Your principal rights under data protection law are:
(a) the right to access - you can ask for copies of your personal data;
(b) the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
(c) the right to erasure - you can ask us to erase your personal data;
(d) the right to restrict processing - you can ask us to restrict the processing of your personal data;
(e) the right to object to processing - you can object to the processing of your personal data;
(f) the right to data portability - you can ask that we transfer your personal data to another organisation or to you;
(g) the right to complain to a supervisory authority - you can complain about our processing of your personal data; and
(h) the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent at any time.
7.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
7.4 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected; you withdraw consent to consent-based processing; or the personal data have been unlawfully processed.
7.5 If you consider that our processing of your personal data infringes data protection laws, you have a legal right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk or by calling 0303 123 1113.
7.6 You may exercise any of your rights in relation to your personal data by contacting us using the details in Section 16.
8. Third party websites
8.1 Our website includes hyperlinks to third party websites, including CrowdFunder.co.uk, Facebook and Instagram.
8.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
9. Personal data of children
9.1 Our website and services are targeted at persons aged 13 and over.
9.2 If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
10. Updating information
10.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
11. About cookies
11.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
11.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie will expire at the end of the user session, when the web browser is closed.
11.3 Cookies do not typically contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
12. Cookies that we use
12.1 We use cookies for the following purposes:
(a) authentication and status - we use cookies to identify you when you visit our website and to help us determine if you are logged in;
(b) personalisation - we use cookies to store information about your preferences and to personalise your experience;
(c) security - we use cookies as an element of the security measures used to protect our website and services generally;
(d) analysis - we use cookies to help us analyse the use and performance of our website and services; and
(e) cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally.
13. Cookies used by our service providers
13.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
13.2 We use Google Analytics. Google Analytics gathers information about the use of our website by means of cookies. The information gathered is used to create reports about the use of our website. You can find out more about Google's use of information by visiting google.com/policies/privacy/partners and you can review Google's privacy policy at policies.google.com/privacy.
13.3 We use a Facebook pixel on our website. Using the pixel, Facebook collects information about visitors and use of our website. This information is used to help us measure the effectiveness of our campaign advertising and to understand how visitors interact with our site. To find out more about the Facebook pixel and Facebook's use of personal data generally, see the Facebook cookie policy at facebook.com/policies/cookies and the Facebook privacy policy at facebook.com/about/privacy. If you are a registered Facebook user, you can adjust how advertisements are targeted by following the instructions at facebook.com/help/568137493302217.
14. Managing cookies
14.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647 (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) https://help.opera.com/en/latest/security-and-privacy/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
14.2 Blocking all cookies will have a negative impact upon the usability of many websites.
14.3 If you block cookies, you will not be able to use all the features on our website.
15. Amendments
15.1 We may update this policy from time to time by publishing a new version on our website.
15.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
15.3 We will notify you of significant changes to this policy by email where we hold your email address.
16. Our details
16.1 This website is owned and operated by The Pop Factory Ltd.
16.2 We are registered in England and Wales under company number 17109994. Our registered office is at Welsh Hills Works, Jenkin Street, Porth, Rhondda Cynon Taf, CF39 9PP.
16.3 You can contact us:
(a) by post, to Welsh Hills Works, Jenkin Street, Porth, Rhondda Cynon Taf, CF39 9PP;
(b) using our website contact form at thepopfactory.co.uk; or
(c) by email, at
17. Data protection registration
17.1 The Pop Factory Ltd. intends to register as a data controller with the UK Information Commissioner's Office (ICO). Our data protection registration number will be published here once registration is complete.
17.2 In the meantime, if you have any concerns about how we handle your personal data, you have the right to complain to the ICO at ico.org.uk or by calling 0303 123 1113.