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Ada Privacy Policy

This the website and platform known as “ADA” is operated by Talon Outdoor Limited (" we” or “us”"). We, here at Talon respect your privacy and recognise that when you opt to provide us with information about you, you place confidence in us that we act in a responsible manner when handling such information, a trust which we are committed to adhere to. This privacy policy contains important information as to how we look after information about you known as “Personal Data” in line with the General Data Protection Regulation and Data Protection Act 2018 (together the "Data Protection Laws").

1. Who we are?

We, Talon Outdoor Ltd, own and operate Ada and as such are the controller and responsible for your personal data. If you have any questions about this privacy policy including how to exercise your legal rights, please contact us at privacy@talonoutdoor.com

2. What data do we collect

We may at times ask you to voluntarily provide us with Personal Data. For example, when you want us to provide you with information or services. In addition, we may collect information about how you use our website, social media, marketing channels and from the devices you use to access the website. This may be collected on the basis of our legitimate interests (as set out for fully below).

We may gather following information about you when you use or access Ada such as but not limited to: 

  • Name
  • Email address
  • Telephone number
  • IP address (a unique identifier for your computer or other device)
  • Mobile device ID
  • Marketing preferences

Data collected from the website is linked to cookies which we receive and process.

3. What about Sensitive Personal Data?

We do not collect Sensitive Personal Data (including, for example, information on race or ethnic origin, political or religious beliefs, trade union membership, physical or mental health, criminal record or other sensitive issues) except to the extent that any such information may be appropriate as part of Talon’s recruitment processes as an equal opportunities’ employer.

4. What if you believe the Personal Data we collect is inaccurate?

To the extent that any Sensitive Personal Data is collected, we will be collected this either on the basis of specific consent or where necessary for assessing your working capacity or otherwise because we have to by law. Talon will only disclose Sensitive Personal Data to trusted third parties where such disclosure is with your specific consent. We also have additional security measures in place to protect Sensitive Personal Data and its confidentiality. If you have reason to believe that any Personal Data that we have about you is out of date or inaccurate, please contact us using the contact details below, so that we can arrange for this to be amended.

5. Why do we collect Personal Data?

We collect and process Personal Data generally, for the provision of our services or for the purposes of our legitimate business interests which we have set out below. We balance our legitimate interests against the impact on you and we ensure that our processing of your Personal Data does not unreasonably intrude on your privacy:

How we will use your personal information

Our legal basis for processing

to provide you with information that you have requested e.g. a newsletter, bulletins;

Consent - we only use your personal information for this purpose if you have asked us to do so. You can withdraw your consent at any time.

to respond to specific queries you may raise;

Consent - we only use your personal information for this purpose if you have asked us to do so. You can withdraw your consent at any time. .

to provide you with better ways of accessing information from Ada;

Our legitimate interests - we use your personal information to help us to deliver the best online experience to you and other website users.

to provide you with better ways of accessing information from Ada, including to perform data analysis and other processing (including market and consumer research and trend analysis)

Our legitimate interests - we use your personal information to help us to deliver the best online experience to you and other website users.

To protect against, identifying and preventing fraud and other criminal activity, claims and other liabilities;

Our legitimate interests - we only use your personal information for this purpose to help us to protect your personal information

To comply with and enforcing applicable legal requirements; and

Our legitimate interests - we only use your personal information for this purpose to comply with legal obligations

to process and consider your job application;

Our legitimate interests - we use your personal information to assess your job application, and to keep you updated throughout the application process.

We also may use the information we obtain about you in other ways for which we provide specific notice at the time of collection.

6. What Personal Data collected by Third Parties?

We may also obtain Personal Data from third parties such as our Clients, Ad Partners, and other third party data providers which share information with us such as browser cookie IDs, mobile device IDs, IP address, device type, operating system, hashed email address, or hashed mobile ID (e.g., Apple IDFA or Android advertising ID), as well as location-based data such as Wi-Fi, cell tower, GPS or diagnostic location information, contextual information, and demographic information including age, gender and zip code."

7. Your rights

Under the Data Protection Laws, you have a number of important rights in respect of Personal Data such as:

  • Ask for a copy of Personal Data we hold about you, and details how we are processing your Personal Data;
  • Object to our processing of your Personal Data, including profiling. If you raise an objection to this, we will stop processing the data, unless we can show compelling legitimate grounds to continue processing;
  • Ask if we are processing your Personal Data by automated means and on the basis of your consent (see "How do we use it?", above), and ask us to provide you your Personal Data in a structured, commonly used and machine-readable format. You can also ask us to provide your Personal Data directly to a third party in this format, and, if technically feasible, we will do so; and
  • Ask to have Personal Data we have collected from you or maintain about you to be deleted in certain circumstances, for example, where we no longer have the right to process information, but this will not apply where the data is required for legal purposes, or for legitimate business purposes (such as research or statistical purposes);
  • Request the restriction of our processing of your Personal Data in some situations, for example where the processing is unlawful and you oppose the erasure of Personal Data and request restriction instead, or where you contest the accuracy of the Personal Data.

You also have the right to make a complaint to the supervisory authority if you're not happy with how we've handled your Personal Data. In the UK, the supervisory authority is the Information Commissioner's Office (http://www.ico.org.uk).

If you wish to exercise any of your rights in relation to Personal Data, please contact us on privacy@talonoutdoor.com. To the extent you are entitled to engage the above rights, your request will be dealt with promptly and generally within one month from when we receive your request and free of charge, except in extenuating circumstances (for example in the case of excessively large requests). If such extenuating circumstances means we are unable to comply with your request within one month, we will tell you as soon as possible about this delay.

8. Can I opt out or ask to have my Personal Data moved or erased?

You can at any time let us know that you wish to opt out to us using of your Personal Data, where we process your Personal Data based on your consent. If you do withdraw consent, that will not affect the lawfulness of what we have done with your Personal Data before you withdrew consent;

You may also seek portability of your Personal Data, where we process your personal data on the basis of consent and automated processing is carried out. Example: "If end users do not want client name to identify their mobile device, they can: (a) delete the Customer app or adjust the in-app settings of the Customer app if the app makes that option available(this will limit data collection from this app alone); or (b) opt-out of sharing your mobile advertiser ID by limiting ad tracking on the device.

9. How do we store Personal Data

Talon holds Personal Data in a combination of electronic and hard copy files, and may also store Personal Data with a third-party data storage provider. We take reasonable steps, including the use of secure storage, to ensure that the personal data we hold is protected from misuse, loss, unauthorised access, modification or disclosure. Where we store Personal Data with a third-party data storage provider, we require them to keep it secure and only use, or make it available to us, for the purpose for which it was provided.

10. Retention of Personal Data

The period for which we may retain Personal Data will depend on the purposes for which the information was collected, but we will not keep the Personal Data for longer than is necessary for the purposes for which it was provided, unless we are required by law or we have other legitimate interests (for example regulatory compliance) which requires us to keep it longer.  Where we process your Personal Data for the contractual provision of our services, we will hold your Personal Data for 7 years following the completion of the contract for services with you.

Where we process your Personal Data on the basis of our legitimate interests, we will hold your Personal Data for 3 years following our last contact with you.

11. How do we protect Personal Data

Personal Data is kept confidential, secure and up to date, through a range of physical, technical, administrative and operational safeguards that are designed to prevent loss, disclosure and unauthorised access (by both employees and third parties). We also take reasonable steps to ensure that third parties that we deal with, have similar safeguards to ensure that any Personal Data is protected.

Talon uses a third-party service to help maintain the security and performance of the Talon website. As part of this service, the third party processes the IP addresses of visitors to the site, but these IP addresses are not tied to any other form of identification. This monitoring protects the website from malicious attacks.

Notwithstanding the security measures taken, and although we will do our best to protect personal data, complete security cannot be guaranteed. For example, the transmission of information via the internet is not completely secure. Therefore any sharing of Data by you needs to be at your own risk.

12. Transfer of Personal Data

Talon operates on a global basis and we may therefore need to transfer Personal Data to group companies and trusted third-parties in other countries, including the US and other countries outside the European Union. To the extent that we make such transfers, we take all necessary steps to ensure that there are adequate safeguards in place to protect the security and confidentiality of the information transferred in accordance with this Privacy Policy.

Personal Data may be transferred to other group companies and trusted third parties outside the UK, but the Lead Supervisory Authority in respect of cross border transfers to and from Talon will be the Information Commissioner’s Office (ICO) in the United Kingdom.

13. What Personal Data do we share

Talon does not sell or otherwise share Personal Data, except as set out in this Privacy Policy. While we may share some limited Personal Data with trusted third parties who perform services on our behalf, these third parties are only authorised to use the information to perform the relevant services or comply with legal requirements.

In addition, Talon may disclose information to third parties in certain other limited circumstances, as follows:

  • if we are required to do so by law or legal process,
  • to law enforcement authorities or other government officials based on a lawful disclosure request, or
  • if we believe disclosure is necessary in connection with an investigation of suspected or actual fraudulent or illegal activity.

In the event that Talon sells or buys any business or assets, we reserve the right to disclose Personal Data to the prospective buyer or seller of such business or assets, subject to their being appropriate confidentiality provisions in place.

14. Our responsibility for website links

The Talon website may contain links to other non-Talon websites. However, when you select a link to a third-party website, you will be leaving the Talon website and this Privacy Policy does not cover any data collected through any other website. Any information that you disclose on the third-party site will be governed by that site's Privacy Policy. Talon is not responsible or liable for the privacy practices or policies of any websites not operated by Talon. 

15. Protection of Children

Our services, platforms and websites, including Ada, are designed for a general audience, but it is not our intention to attract children under 13 to our website, platform, social media, or other marketing channels, and we do not knowingly collect or process Personal Data relating to any person under the age of 13. We would discourage children under the age of 13 from using our website social media or other marketing channels, or from providing any Personal Data to the company. If a parent or guardian learns that a child has provided us with personal identifiable information, that child’s parents or guardian should contact us and send a request marked Privacy- Urgent” if they would like the information submitted by the child to be deleted from our database. We will use all reasonable efforts to delete such information from our database.

16. What to do if your information or choices change

If you wish to update your Personal Data, make changes to your preferences, no longer wish to receive information that you have requested or if you have any queries about how we use your Personal Data, please contact us on privacy@talonoutdoor.com . We will take action to make any changes requested as soon as we reasonably can.

17. Changes to Privacy Policy

We review this privacy policy on a regular basis to ensure it reflects changes in legislation, best practice and other changes to the treatment of personal data. We reserve the right at our sole discretion to revise this policy at any time and will endeavour to highlight any significant changes to the policy through a notice on the company’s website and encourage you to review his policy from time to time. Continued use of the website or social media channels, or further provision of Personal Data will be taken to mean that you accept the changes to the Privacy Policy. 

18. Contact us

If you have any questions or comments in relation to this policy, or if you would like to update any information we may have about you or your preferences, please contact us by email on privacy@talonoutdoor.com or write to us at:

Privacy and Data Protection Talon Outdoor Limited Holden House (2nd Floor) 57 Rathbone Place London W1T 1JU

19. Applicable Law

This privacy policy is governed and construed in accordance with English law.

19. Further information

If you require further information on privacy and data protection generally, please visit the ICO website which oversees data protection compliance in the UK: ico.org.uk

Last updated 30th April 2020.