Privacy Policy

This is the pri­va­cy notice of The Church of Lon­don Ltd (TCOL), trad­ing as ​“TCO”, ​“Huck”, ​“Lit­tle White Lies” and ​“71a” at 71A Leonard Street, Lon­don EC2A 4QS. In this doc­u­ment, ​“we”, ​“our”, or ​“us” refers to TCOL.

We are com­pa­ny num­ber 05813483 reg­is­tered in the Unit­ed Kingdom

Our reg­is­tered office is at 71A Leonard Street, Lon­don EC2A 4QS.

Intro­duc­tion

1. This is a notice to inform you of our pol­i­cy about all infor­ma­tion that we record about you. It sets out the con­di­tions under which we may process any infor­ma­tion that we col­lect from you, or that you pro­vide to us. It cov­ers infor­ma­tion that could iden­ti­fy you (“per­son­al infor­ma­tion”) and infor­ma­tion that could not. In the con­text of the law and this notice, ​“process” means col­lect, store, trans­fer, use or oth­er­wise act on information.
2. We regret that if there are one or more points below with which you are not hap­py, please leave our web­site immediately.
3. We take seri­ous­ly the pro­tec­tion of your pri­va­cy and con­fi­den­tial­i­ty. As such, all vis­i­tors to our web­site should know that their per­son­al data will not be used for any pur­pose unin­tend­ed by them, and will not acci­den­tal­ly fall into the hands of a third party.
4. We under­take to pre­serve the con­fi­den­tial­i­ty of all infor­ma­tion you pro­vide to us, and hope that you reciprocate.
5. Our pol­i­cy com­plies with UK law accord­ing­ly imple­ment­ed, includ­ing that required by the EU Gen­er­al Data Pro­tec­tion Reg­u­la­tion (GDPR).
6. The law requires us to tell you about your rights and our oblig­a­tions to you regard­ing the pro­cess­ing and con­trol of your per­son­al data. We do this now, by request­ing that you read the infor­ma­tion pro­vid­ed at knowyour​pri​va​cyrights​.org
7. Except as set out below, we do not share, or sell, or dis­close to a third par­ty, any infor­ma­tion col­lect­ed through our website.

The bases on which we process infor­ma­tion about you

The law requires us to deter­mine under which of six defined bases we process dif­fer­ent cat­e­gories of your per­son­al infor­ma­tion, and to noti­fy you of the basis for each category.

If a basis on which we process your per­son­al infor­ma­tion is no longer rel­e­vant then we shall imme­di­ate­ly stop pro­cess­ing your data.

If the basis changes then if required by law we shall noti­fy you of the change and of any new basis under which we have deter­mined that we can con­tin­ue to process your information.

• Infor­ma­tion we process because we have a con­trac­tu­al oblig­a­tion with you

When you cre­ate an account on our web­site, buy a prod­uct or ser­vice from us, or oth­er­wise agree to our terms and con­di­tions, a con­tract is formed between you and us.

In order to car­ry out our oblig­a­tions under that con­tract we must process the infor­ma­tion you give us. Some of this infor­ma­tion may be per­son­al information.

We may use it in order to:

1. 1. ver­i­fy your iden­ti­ty for secu­ri­ty purposes
   2. sell prod­ucts to you
   3. pro­vide you with our services
   4. pro­vide you with sug­ges­tions and advice on prod­ucts, ser­vices and how to obtain the most from using our website

We process this infor­ma­tion on the basis there is a con­tract between us, or that you have request­ed we use the infor­ma­tion before we enter into a legal contract.

Addi­tion­al­ly, we may aggre­gate this infor­ma­tion in a gen­er­al way and use it to pro­vide class infor­ma­tion, for exam­ple to mon­i­tor our per­for­mance with respect to a par­tic­u­lar ser­vice we pro­vide. If we use it for this pur­pose, you as an indi­vid­ual will not be per­son­al­ly identifiable.

We shall con­tin­ue to process this infor­ma­tion until the con­tract between us ends or is ter­mi­nat­ed by either par­ty under the terms of the contract.

• Infor­ma­tion we process with your consent

Through cer­tain actions when oth­er­wise there is no con­trac­tu­al rela­tion­ship between us, such as when you browse our web­site or ask us to pro­vide you more infor­ma­tion about our busi­ness, includ­ing any job oppor­tu­ni­ties and/​or infor­ma­tion about our prod­ucts and ser­vices, you pro­vide your con­sent to us to process infor­ma­tion that may be per­son­al information.

Wher­ev­er pos­si­ble, we aim to obtain your explic­it con­sent to process this infor­ma­tion, for exam­ple, by ask­ing you to agree to our use of cookies.

Some­times you might give your con­sent implic­it­ly, such as when you send us a mes­sage by e‑mail to which you would rea­son­ably expect us to reply.

Except where you have con­sent­ed to our use of your infor­ma­tion for a spe­cif­ic pur­pose, we do not use your infor­ma­tion in any way that would iden­ti­fy you per­son­al­ly. We may aggre­gate it in a gen­er­al way and use it to pro­vide class infor­ma­tion, for exam­ple to mon­i­tor the per­for­mance of a par­tic­u­lar page on our website.

If you have giv­en us explic­it per­mis­sion to do so, we may from time to time pass your name and con­tact infor­ma­tion to select­ed asso­ciates whom we con­sid­er may pro­vide ser­vices or prod­ucts you would find useful.

We con­tin­ue to process your infor­ma­tion on this basis until you with­draw your con­sent or it can be rea­son­ably assumed that your con­sent no longer exists.

You may with­draw your con­sent at any time by instruct­ing us hello@​tcolondon.​com, mark­ing your email ​‘Urgent: Data pro­cess­ing request’. How­ev­er, if you do so, you may not be able to use our web­site or our ser­vices further.

• Infor­ma­tion we process for the pur­pos­es of legit­i­mate interests

We may process infor­ma­tion on the basis there is a legit­i­mate inter­est, either to you or to us, of doing so.

Where we process your infor­ma­tion on this basis, we do hav­ing giv­en care­ful con­sid­er­a­tion to:

• • whether the same objec­tive could be achieved through oth­er means
  • whether pro­cess­ing (or not pro­cess­ing) might cause you harm
  • whether you would expect us to process your data, and whether you would, in the round, con­sid­er it rea­son­able to do so

For exam­ple, we may process your data on this basis for the pur­pos­es of:

• • record-keep­ing for the prop­er and nec­es­sary admin­is­tra­tion of our business
  • respond­ing to unso­licit­ed com­mu­ni­ca­tion from you to which we believe you would expect a response
  • pro­tect­ing and assert­ing the legal rights of any party
  • insur­ing against or obtain­ing pro­fes­sion­al advice that is required to man­age busi­ness and organ­i­sa­tion­al risk
  • pro­tect­ing your inter­ests where we believe we have a duty to do so

• Infor­ma­tion we process because we have a legal obligation

We are sub­ject to the law like every­one else. Some­times, we must process your infor­ma­tion to com­ply with a statu­to­ry obligation.

For exam­ple, we may be required to give infor­ma­tion to legal author­i­ties if they so request or if they have the prop­er autho­ri­sa­tion such as a search war­rant or court order.

This may include your per­son­al information.

Spe­cif­ic uses of infor­ma­tion you pro­vide to us

• Infor­ma­tion pro­vid­ed on the under­stand­ing that it will be shared with a third party

Our web­site allows you to post infor­ma­tion with a view to that infor­ma­tion being read, copied, down­loaded, or used by oth­er people.

Exam­ples include:

1. 1. post­ing a mes­sage our forum
   2. tag­ging an image
   3. click­ing on an icon next to anoth­er visitor’s mes­sage to con­vey your agree­ment, dis­agree­ment or thanks

In post­ing per­son­al infor­ma­tion, it is up to you to sat­is­fy your­self about the pri­va­cy lev­el of every per­son who might use it.

We do store it, and we reserve a right to use it in the future in any law­ful way we decide.

Once your infor­ma­tion enters the pub­lic domain, we have no con­trol over what any indi­vid­ual third par­ty may do with it. We can there­fore accept no respon­si­bil­i­ty for their actions at any time.

Pro­vid­ed your request is rea­son­able and there is no legal basis for us to retain it, then at our dis­cre­tion we may agree to your request to delete per­son­al infor­ma­tion that you have post­ed. You can make a request by con­tact­ing us at hello@​tcolondon.​com , mark­ing your e‑mail ​‘Urgent: data pro­cess­ing request’.

• Com­plaints regard­ing con­tent on our website

Our web­site is a show­case for our brand and ser­vices, and also a pub­lish­ing medi­um. In its lat­ter guise, any­one may reg­is­ter and then pub­lish infor­ma­tion about him­self, her­self or some oth­er person.

If you com­plain about any of the con­tent on our web­site, we shall inves­ti­gate your com­plaint as soon as is rea­son­ably practicable.

If we feel it is jus­ti­fied or if we believe the law requires us to do so, we shall remove the con­tent while we investigate.

Free speech is a fun­da­men­tal right, so we have to make a judge­ment as to whose right will be obstruct­ed: yours, or that of the per­son who post­ed the con­tent that offends you.

We attempt to mod­er­ate user-gen­er­at­ed con­tent, but we are not always able to do so as soon as that con­tent is published.

If we think your com­plaint is vex­a­tious or with­out any basis, we shall not cor­re­spond with you about it.

• Job appli­ca­tion and employment

If you send us infor­ma­tion in con­nec­tion with a job appli­ca­tion, we may keep it for up to three years in case we decide to con­tact you at a lat­er date.

If we employ you, we col­lect infor­ma­tion about you and your work from time to time through­out the peri­od of your employ­ment. This infor­ma­tion will be used only for pur­pos­es direct­ly rel­e­vant to your employ­ment. After your employ­ment has end­ed, we will keep your file for six years before destroy­ing or delet­ing it.

• Send­ing a mes­sage to our sup­port team

When you con­tact us, whether by tele­phone, through our web­site or by e‑mail, we col­lect the data you have giv­en to us so that we can reply with the infor­ma­tion you need.

We record your request and our reply in order to increase the effi­cien­cy of our business.

We keep per­son­al­ly iden­ti­fi­able infor­ma­tion asso­ci­at­ed with your mes­sage, such as your name and email address so as to be able to track our com­mu­ni­ca­tions with you to pro­vide a high-qual­i­ty service.

• Com­plain­ing

When we receive a com­plaint, we record all the infor­ma­tion you have giv­en to us.

We use that infor­ma­tion to resolve your complaint.

If your com­plaint rea­son­ably requires us to con­tact some oth­er per­son, we may decide to give to that oth­er per­son some of the infor­ma­tion con­tained in your com­plaint. We do this as infre­quent­ly as pos­si­ble, but it is a mat­ter for our sole dis­cre­tion as to whether we do give infor­ma­tion, and if we do, what that infor­ma­tion is.

We may also com­pile sta­tis­tics show­ing infor­ma­tion obtained from this source to assess the lev­el of ser­vice we pro­vide, but not in a way that could iden­ti­fy you or any oth­er person.

• Affil­i­ate and busi­ness part­ner information

This is infor­ma­tion giv­en to us by you in your capac­i­ty as one of our affil­i­ates or as a busi­ness partner.

It allows us to recog­nise vis­i­tors that you have referred to us, and to cred­it to you com­mis­sion due for such refer­rals. It also includes infor­ma­tion that allows us to trans­fer com­mis­sion to you.

The infor­ma­tion is not used for any oth­er purpose.

We under­take to pre­serve the con­fi­den­tial­i­ty of the infor­ma­tion and of the terms of our relationship.

We expect any affil­i­ate or part­ner to agree to rec­i­p­ro­cate this policy.

Use of infor­ma­tion we col­lect through auto­mat­ed sys­tems when you vis­it our website

• Cook­ies

Cook­ies are small text files that are placed on your computer’s hard dri­ve by your web brows­er when you vis­it any web­site. They allow infor­ma­tion gath­ered on one web page to be stored until it is need­ed for use on anoth­er, allow­ing a web­site to pro­vide you with a per­son­alised expe­ri­ence and the web­site own­er with sta­tis­tics about how you use the web­site so that it can be improved.

Some cook­ies may last for a defined peri­od of time, such as one day or until you close your brows­er. Oth­ers last indefinitely.

Your web brows­er should allow you to delete any you choose. It also should allow you to pre­vent or lim­it their use.

Our web­site uses cook­ies. They are placed by soft­ware that oper­ates on our servers, and by soft­ware oper­at­ed by third par­ties whose ser­vices we use.

When you first vis­it our web­site, we ask you whether you wish us to use cook­ies. If you choose not to accept them, we shall not use them for your vis­it except to record that you have not con­sent­ed to their use for any oth­er purpose.

If you choose not to use cook­ies or you pre­vent their use through your brows­er set­tings, you may not be able to use all the func­tion­al­i­ty of our website.

We use cook­ies in the fol­low­ing ways:

1. 1. 1. to track how you use our website
      2. to record whether you have seen spe­cif­ic mes­sages we dis­play on our website
      3. to keep you signed in our site
      4. to record your answers to sur­veys and ques­tion­naires on our site while you com­plete them
      5. to record the con­ver­sa­tion thread dur­ing a live chat with our sup­port team

• Per­son­al iden­ti­fiers from your brows­ing activity

Requests by your web brows­er to our servers for web pages and oth­er con­tent on our web­site are recorded.

We record infor­ma­tion such as your geo­graph­i­cal loca­tion, your Inter­net ser­vice provider and your IP address. We also record infor­ma­tion about the soft­ware you are using to browse our web­site, such as the type of com­put­er or device and the screen resolution.

We use this infor­ma­tion in aggre­gate to assess the pop­u­lar­i­ty of the web­pages on our web­site and how we per­form in pro­vid­ing con­tent to you.

If com­bined with oth­er infor­ma­tion we know about you from pre­vi­ous vis­its, the data pos­si­bly could be used to iden­ti­fy you per­son­al­ly, even if you are not signed in to our website.

• Our use of re-marketing

Re-mar­ket­ing involves plac­ing a cook­ie on your com­put­er when you browse our web­site in order to be able to serve to you an advert for our prod­ucts or ser­vices when you vis­it some oth­er website.

We may use a third par­ty to pro­vide us with re-mar­ket­ing ser­vices from time to time. If so, then if you have con­sent­ed to our use of cook­ies, you may see adver­tise­ments for our prod­ucts and ser­vices on oth­er websites.

Dis­clo­sure and shar­ing of your information

• Infor­ma­tion we obtain from third parties

Although we do not dis­close your per­son­al infor­ma­tion to any third par­ty (except as set out in this notice), we some­times receive data that is indi­rect­ly made up from your per­son­al infor­ma­tion from third par­ties whose ser­vices we use.

No such infor­ma­tion is per­son­al­ly iden­ti­fi­able to you.

• Third par­ty adver­tis­ing on our website

Third par­ties may adver­tise on our web­site. In doing so, those par­ties, their agents or oth­er com­pa­nies work­ing for them may use tech­nol­o­gy that auto­mat­i­cal­ly col­lects infor­ma­tion about you when their adver­tise­ment is dis­played on our website.

They may also use oth­er tech­nol­o­gy such as cook­ies or JavaScript to per­son­alise the con­tent of, and to mea­sure the per­for­mance of their adverts.

We do not have con­trol over these tech­nolo­gies or the data that these par­ties obtain. Accord­ing­ly, this pri­va­cy notice does not cov­er the infor­ma­tion prac­tices of these third parties.

• Cred­it reference

To assist in com­bat­ing fraud, we may share infor­ma­tion with cred­it ref­er­ence agen­cies, so far as it relates to clients or cus­tomers who instruct their cred­it card issuer to can­cel pay­ment to us with­out hav­ing first pro­vid­ed an accept­able rea­son to us and giv­en us the oppor­tu­ni­ty to refund their money.

• Data may be processed out­side the Euro­pean Union

Our web­sites are host­ed in the Unit­ed Kingdom.

We may also use out­sourced ser­vices and con­sul­tants in coun­tries out­side the Euro­pean Union from time to time in oth­er aspects of our business.

Accord­ing­ly data obtained with­in the UK or any oth­er coun­try could be processed out­side the Euro­pean Union.

For exam­ple, some of the soft­ware our web­site uses may have been devel­oped in the Unit­ed States of America.

We use the fol­low­ing safe­guards with respect to data trans­ferred out­side the Euro­pean Union:

1. 1. the proces­sor is with­in the same cor­po­rate group as our busi­ness or organ­i­sa­tion and abides by the same bind­ing cor­po­rate rules regard­ing data processing.
   2. we com­ply with a code of con­duct approved by a super­vi­so­ry author­i­ty in the Euro­pean Union
   3. we aim to include in the con­tracts of our third par­ty sup­pli­ers and con­sul­tants stan­dard claus­es approved by the Euro­pean Com­mis­sion (some­times called ​‘the EU Mod­el Claus­es’) to ensure that their pro­cess­ing meets the secu­ri­ty stan­dards required with­in the EU. 

Access to your own information

• Access to your per­son­al information

1. 1. 1. At any time you may review or update per­son­al­ly iden­ti­fi­able infor­ma­tion that we hold about you.
      2. To obtain a copy of any infor­ma­tion that is not pro­vid­ed on our web­site you may send us a request at hello@​tcolondon.​com, mark­ing your e‑mail ​‘Urgent: data pro­cess­ing request’.
      3. After receiv­ing the request, we will tell you when we expect to pro­vide you with the infor­ma­tion, and whether we require any fee for pro­vid­ing it to you.

• Removal of your information

If you wish us to remove per­son­al­ly iden­ti­fi­able infor­ma­tion from our web­site, you may con­tact us at hello@​tcolondon.​com, mark­ing your e‑mail ​‘Urgent: data pro­cess­ing request’.

This may lim­it the ser­vice we can pro­vide to you.

• Ver­i­fi­ca­tion of your information

When we receive any request to access, edit or delete per­son­al iden­ti­fi­able infor­ma­tion we shall first take rea­son­able steps to ver­i­fy your iden­ti­ty before grant­i­ng you access or oth­er­wise tak­ing any action. This is impor­tant to safe­guard your information.

Oth­er matters

• Use of site by children

1. 1. 1. We do not sell prod­ucts or pro­vide ser­vices for pur­chase by chil­dren, nor do we mar­ket to children.
      2. We col­lect data about all users of and vis­i­tors to these areas regard­less of age, and we antic­i­pate that some of those users and vis­i­tors will be children.
      3. If so, the data of such child users and vis­i­tors will be processed law­ful­ly, and in accor­dance with the terms of this Pri­va­cy notice.

• Encryp­tion of data sent between us

We use Secure Sock­ets Lay­er (SSL) cer­tifi­cates to ver­i­fy our iden­ti­ty to your brows­er and to encrypt any data you give us.

When­ev­er infor­ma­tion is trans­ferred between us, you can check that it is done so using SSL by look­ing for a closed pad­lock sym­bol or oth­er trust mark in your browser’s URL bar or toolbar.

• How you can complain

1. 1. 1. If you are not hap­py with our pri­va­cy pol­i­cy or if have any com­plaint then you should tell us by email. Our address is hello@​tcolondon.​com. Please mark your e‑mail ​‘Urgent: data pro­cess­ing complaint’.].
      2. If a dis­pute is not set­tled then we hope you will agree to attempt to resolve it by engag­ing in good faith with us in a process of medi­a­tion or arbitration.
      3. If you are in any way dis­sat­is­fied about how we process your per­son­al infor­ma­tion, you have a right to lodge a com­plaint with the Infor­ma­tion Commissioner’s Office. This can be done at https://​ico​.org​.uk/​c​o​n​c​erns/

• Reten­tion peri­od for per­son­al data

Except as oth­er­wise men­tioned in this pri­va­cy notice, we keep your per­son­al infor­ma­tion only for as long as required by us:

1. 1. 1. to pro­vide you with the ser­vices you have requested;
      2. to com­ply with oth­er law, includ­ing for the peri­od demand­ed by our tax authorities;
      3. to sup­port a claim or defence in court.

• Com­pli­ance with the law

Our pri­va­cy pol­i­cy has been com­piled so as to com­ply with the law of every coun­try or legal juris­dic­tion in which we aim to do busi­ness. If you think it fails to sat­is­fy the law of your juris­dic­tion, we should like to hear from you.

How­ev­er, ulti­mate­ly it is your choice as to whether you wish to use our website.

• Review of this pri­va­cy policy

We may update this pri­va­cy notice from time to time as nec­es­sary. The terms that apply to you are those post­ed here on our web­site on the day you use our web­site. We advise you to print a copy for your records.

If you have any ques­tion regard­ing our pri­va­cy pol­i­cy, please con­tact us at hello@​tcolondon.​com, mark­ing your e‑mail ​‘Urgent: data pro­cess­ing request’.