This Privacy Notice (“Privacy Notice”) applies to the processing of personal data in connection with the provision of the Wolff Olins website at www.wolffolins.com (the “Site”), and all of the goods and services that we offer, including from the Site, Wolff Olins offices and other such locations around the world (“Services”). We respect the privacy of every person who visits our Site and/or uses our Services and we are committed to ensuring a safe online experience for all.
1. Purpose of this privacy notice
This Privacy Notice explains our approach to any personal data that we might collect from you or which we have obtained about you from a third party and the purposes for which we process your personal data. This Privacy Notice also sets out your rights in respect of our processing of your personal data.
When we talk about “personal data”, we mean any information which relates to an identified or identifiable living individual. Individuals might be identified by reference to a name, an identification number, location data, an online identifier (such as an IP address) or to other factors that are specific to them, such as their physical appearance.
This Privacy Notice informs you of the nature of the personal data about you that is processed by us and how you can request that we delete it, update it, transfer it and/or provide you with access to it.
This Privacy Notice only applies to the use of your personal data obtained by us, whether from you directly or from a third party. It does not apply to personal data collected by third parties during your communications with those third parties or your use of their products or services (for example, where you follow links to third party websites over which we have no control, or you purchase goods or services from those third parties).
2. About us
The Site and our Services are made available by Wolff Olins Limited (“Wolff Olins”, “we”, “us, “our”). Wolff Olins is the data controller responsible for your personal data.
Wolff Olins Limited (company no: 01945130) is an English company with its registered office at Bankside 3, 90-100 Southwark Street, London, SE1 0SW, England.
3. How to contact us
If you have any questions about this Privacy Notice or want to exercise your rights set out in this Privacy Notice, you can contact us by:
- sending an email to email@example.com;
- writing to Bankside 3, 90-100 Southwark Street, London, SE1 0SW, England.
4. How we collect and receive personal data
We collect and receive personal data using different methods:
- Personal data you provide to us
You may give us your personal data directly. This will be the case when, for example, you contact us with enquiries or complete forms on our Site, subscribe to receive our marketing communications or provide feedback to us.
- Personal data we collect using cookies and other similar technologies
- Personal data received from third parties
From time to time, we will receive personal data about you from third parties. Such third parties may include analytics providers, payment providers, hotel and transport providers and third parties that provide technical services to us so that we can operate our Site and provide our Services.
- Publicly available personal data
From time to time we may collect personal data about you (including your contact details, biography, interests or affiliations) from publicly available sources (including open source data sets), media reports or that you or a third party may otherwise make publicly available (for example through speeches at events or publishing articles or other news stories or posts on social media platforms).
5. Who we collect personal data about
We collect and process personal data from the following people:
- Site visitors
If you browse our Site, register for updates on our Site, contact us with an enquiry through our Site, submit a complaint through our Site or use any Services available on our Site, we will collect and process your personal data in connection with your interaction with us and our Site.
If you buy products or services from us, we may collect and process your personal data in connection with the supply of goods or services to you.
- Event attendees
If you attend one of our events, we will process personal data about you in connection with your attendance at the event. For example, we may ask you to complete a registration or feedback form, or other document relating to the event.
- Personnel that work for our partners and suppliers (including subcontractors)
If you (or your organisation) supply products or services to us or otherwise partner with us, we may collect and process your personal data in connection with our receipt of those products and services and/or partnership. This may include personal data included in any email or telephone communications or recorded on any document relating to an order for the products or services.
- Job applicants
If you apply for a job with us (whether in London or anywhere else we operate), whether through the Site or otherwise, we will collect and process your personal data in connection with your application.
6. Personal data we collect
We use your personal data for the following purposes:
- Fulfilment of our Services
We collect and maintain personal data that you submit to us for the purpose of supplying Services that you have requested from us via our Site or where we contract with you to provide our Services. We may collect and process your personal data whether you are interacting with us on your own behalf or on behalf of any organisation you represent.
The personal data we process may include your name and contact information (such as email address, postal address and telephone number) and your payment information (where applicable). We process this information so that we can fulfil the supply of Services, maintain our user databases and to keep a record of how our Services are being used.
If you attend one of our events, we will process personal data about you which you volunteer in connection with your visit and any enquiries you may have. Some Services we offer are also subject to separate terms and conditions which will also apply.
Our legal basis for processing: It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you, or it is in our legitimate interest or a third party’s legitimate interest to use personal data in such a way to ensure that we provide the our Services in an effective, safe and efficient way.
- Linking to social media sites and interacting with our social media pages
If you click on one of the social media links on our Site or otherwise interact with our social media pages such as on Facebook or Instagram (including interacting with any ‘like’ or similar embedded features on our Site or social media accounts) we and the relevant social media platform may receive information relating to such interaction and may share your personal data in connection with this purpose. For more information about how we use this personal data, please see the Insight and Analysis section below.
Our legal basis for processing: It is in our legitimate interest or a third party’s legitimate interest to use personal data in such a way to ensure that we provide the Site and our Services in an effective way and to promote our Site and our Services via social media.
- Customer service and general enquiries
Our Site feature a “Get in touch” page which invites you to submit general enquiries about our Site and our Services by email, telephone or post.
When you make an enquiry, we will collect and process your name, contact information (including email address and/or telephone number) and any other personal data that is relevant to your enquiry. We use this information to manage and respond to your enquiry.
Our legal basis for processing: It is in our legitimate interest to use your personal data in the ways described above to ensure that we are able to help you with your enquiry and provide a good standard of service to you.
- Hosting and managing events
From time to time, we may organise and host events. We may process your name and contact information (including email address, postal address and telephone number) to communicate with you about such events where you have specifically requested information about such events or where we have another lawful basis for sending that information to you.
If you attend one of our events, we may use your personal data to record your attendance at the event and for related record-keeping purposes and, if relevant, we may collect and process any dietary requirements you may have. You may also feature in photographs taken at our events and such photographs may appear in publications that we make available.
Our legal basis for processing: It is necessary for us to use your personal data in this way to perform our obligations in accordance with any contract that we may have with you where you have signed up to attend an event, or it is in our legitimate interest or a third party’s legitimate interest to use personal data in such a way to ensure that the event is operated in an effective way.
We may specifically ask your permission to use your photographs, quotes, testimonials, or other content that you make available or publish at the event. Where this is the case, our processing of your personal data will be based on consent.
- Email and SMS/MMS marketing activities
We use your name and email address to send you (or the organisation you represent) marketing communications by email. We may use your mobile telephone number to send you marketing communications by SMS/MMS. Our email and SMS/MMS marketing communications will include press releases, information, thought pieces, articles and details for events, as well as general information about our organisation, our Site, our US offices, the Services we provide and the events and promotions we offer.
We may share your personal information with a variety of this party email or text message marketing providers (including MailChimp) who assist us in delivering our email marketing campaigns, newsletters, event invites and other mass emails or text messages to you.
Where your personal data is not in an anonymous form (for example, your email address), it is in our legitimate interest to use your personal data for postal marketing purposes.
We will only send you marketing communications by email where you have consented to receive such communications, or where we have another lawful right to send such communications to you.
We use your personal data for recruitment purposes, in particular, to assess your suitability for any of our positions that you apply for, whether such application has been received by us online, by email or by hard copy and whether submitted directly by you, by a third party recruitment agency on your behalf or via the Wolff Olins Workable recruitment portal (see the Workable privacy notice here). We also use your personal data to communicate with you about the recruitment process, to keep records about our recruitment process and to comply with our legal and regulatory obligations in relation to recruitment.
We will process any personal data about you that you volunteer, including during any interview, when you apply for a position with us. We may also process your personal data obtained from any third parties we work with in relation to our recruitment activities, including without limitation, recruitment agencies, background check providers, credit reference agencies and your referees.
The personal data we process may include your name and contact information (including your email address, postal address and telephone number), details of your education, qualifications and employment history, any other personal data which appears in your curriculum vitae or application, any personal data that you volunteer during an interview or your interactions with us, or any personal data which is contained in any reference about you that we receive. Such information may also include special categories of personal data (such as information about your health, any medical conditions and your health and sickness records) and information relating to criminal convictions and offences if that information is relevant to the role you are applying for.
We also use your personal data for the purposes of reviewing our equal opportunity profile in accordance with applicable legislation. We do not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability or any other basis covered by local legislation. All employment-related decisions are made entirely on merit.
Our legal basis for processing: Where we use your personal data in connection with recruitment, it will be in connection with us taking steps at your request to enter into a contract we may have with you or it is in our legitimate interest to use personal data in such a way to ensure that we can make the best recruitment decisions.
We will not process any special (or sensitive) categories of personal data or personal data relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.
- Receipt of services from suppliers
If we have engaged you or the organisation you represent to provide us with products or services (for example, if you or the organisation you represent provide us with services such as IT support, production, artwork or financial advice), we will collect and process your personal data in order to manage our relationship with you or the organisation you represent, to receive products and services from you or the organisation you represent and, where relevant, to provide our Services to others.
The personal data we collect from you may include your name, job title, contact information (including email address, telephone number and postal address), bank account or other payment details and any other personal data you volunteer which is relevant to our relationship with you or the organisation you represent.
Our legal basis for processing: It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you or it is in our legitimate interest to use personal data in such a way to ensure that we have an effective working relationship with you or the organisation you represent and are able to receive the services that you or your organisation provides, and provide our Services to others, in an effective way.
We have security measures in place at our offices, including CCTV and building access controls. There are signs in place showing that CCTV is in operation. The images captured are securely stored and only accessed on a need to know basis (e.g. to look into an incident). CCTV recordings are typically automatically overwritten after a short period of time unless an issue is identified that requires investigation (such as a theft).
We may require visitors to our premises to sign in on arrival and where that is the case we will keep a record of visitors for a short period of time. Our visitor records are securely stored and only accessible on a need-to-know basis (e.g. to look into an incident).
Our legal basis for processing: It is in our legitimate interests to process your personal data so that we can keep our offices secure and provide a safe environment for our personnel and visitors to our offices.
- Business administration and legal compliance
We use your personal data for the following business administration and legal compliance purposes:
- to comply with our legal obligations;
- to enforce our legal rights;
- to protect the rights of third parties; and
- in connection with a business transition such as a merger, reorganisation, acquisition by another company, or sale of all or a portion of our assets.
Our legal basis for processing: Where we use your personal data in connection with a business transition, to enforce our legal rights or to protect the rights of third parties, it is in our legitimate interest to do so. For all other purposes described in this section, we have a legal obligation to use your personal data to comply with any legal obligations imposed upon us such as a court order.
We will not process any special (or sensitive) categories of personal data or personal data relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.
- Any other purposes for which we wish to use your personal data that are not listed above, or any other changes we propose to make to the existing purposes, will be notified to you using the contact details we hold for you.
7. If you fail to provide your personal data
Where we are required by law to collect your personal data, or we need to collect your personal data under the terms of a contract we have with you, and you fail to provide that personal data when we request it, we may not be able to perform the contract we have or are trying to enter into with you. This may apply where you do not provide the personal data we need in order to provide the Services you have requested from us or to process an application for employment with us. In this case, we may have to cancel your application or the provision of the relevant Services to you, in which case we will notify you.
8. How we obtain your consent
Where our use of your personal data requires consent, you can provide or withdraw such consent:
- at the time we collect your personal data following the instructions provided; or
- by informing us using the contact details set out in the “How to contact us” section above.
10. Third party links and services
This Privacy Notice does not apply to your interaction with services provided by third parties.
Our Site may contain links to third party websites and services.
When you use a link to go from our Site to another website (even if you don’t leave our Site) or you request a service from a third party, this Privacy Notice shall not apply to the processing of your personal data carried out by the relevant third party provider.
Your browsing and interactions on any other websites, or your dealings with any other third party service provider, is subject to that website’s or third party service provider’s own rules and policies. For example, our website invites you to view videos on platforms such as Vimeo. When you click on the links we provide to such platforms, you will be transferred from our website to the relevant platform and the privacy notice (and other terms and conditions) of that platform will apply to you.
We do not monitor, control or endorse the privacy practices of any third parties.
We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you use in connection with your interaction with us and to contact them if you have any questions about their respective privacy notices and practices.
This Privacy Notice applies solely to personal data processed by us through your use of our Site, your receipt of our Services and/or in connection with our business operations. It does not apply to the processing of your personal data by these third party websites and third party service providers.
11. Sharing personal data
We will only share personal data with others when we are legally permitted to do so. When we share personal data with others, we put contractual arrangements and security mechanisms in place to protect the personal data shared and to comply with our data protection, confidentiality and security standards and obligations.
When processing your personal data, we may need to share it with third parties (including other entities within our group of companies) as follows:
- Payment providers and banks: We share personal data with third parties who assist us with the processing of payments and refunds.
- Event partners and suppliers: When we run events, we will share your personal data with third-party services providers that are assisting us with the operation and administration of that event. If we are running an event in partnership with other organisations, we will share your personal data with such organisations for use in relation to the event.
- Third-party email marketing and CRM specialists: We share personal data with specialist suppliers who assist us in managing our marketing database and sending out our email marketing communications and membership-related communications.
- Recruitment agencies and related organisations: We share personal data with external recruiters, third-party providers that undertake background checks on our behalf and other entities within our group of companies.
- Auditors, lawyers, accountants and other professional advisers: We share personal data with professional services firms who advise and assist us in relation to the lawful and effective management of our organisation and in relation to any disputes we may become involved in.
- Law enforcement or other government and regulatory agencies and bodies: We share personal data with law enforcement or other government and regulatory agencies or other third parties as required by, and in accordance with, applicable law or regulation.
- Sharing with other third parties: Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, or to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.
This list is non-exhaustive and there may be circumstances where we need to share personal data with other third parties in order to operate our Site and to provide our Services.
12. Transfers outside the European Economic Area (“eea”)
Where necessary in order to operate our Site and to otherwise deliver our Services, we will transfer personal data to countries outside the EEA.
Non-EEA countries do not have the same data protection laws as the EEA. In particular, non-EEA countries may not provide the same degree of protection for your personal data, may not give you the same rights in relation to your personal data and may not have a data protection supervisory authority to help you if you have any concerns about the processing of your personal data. However, when transferring your personal data outside the EEA, we will comply with our legal and regulatory obligations in relation to your personal data, including having a lawful basis for transferring personal data and putting appropriate safeguards in place to ensure an adequate level of protection for the personal data.
We will take reasonable steps to ensure the security of your personal data in accordance with applicable data protection laws.
When transferring your personal data outside the EEA, we will ensure that, where required by applicable law, at least one of the following safeguards is implemented:
- Adequacy decisions: We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.
- Model clauses: Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.
- EU-U.S. Privacy Shield: Where we have partners or suppliers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-privacy-shield_en.
Please contact us if you would like further information on the specific mechanisms used by us when transferring your personal data outside the EEA.
13. How long we keep your personal data
In respect of personal data that we process in connection with the supply of our Services, we may retain your personal data for up to six years from the date of supply of the relevant Services and in compliance with our data protection obligations. We may then destroy such files without further notice or liability.
In respect of any other personal data that we process, we will retain relevant personal data for up to three years from the date of our last interaction with you and in compliance with our data protect obligations. We may then destroy such files without further notice or liability.
If any personal data is only useful for a short period (e.g. for a specific event or marketing campaign or in relation to recruitment), we will not retain it for longer than the period for which it is used by us.
If you have opted out of receiving marketing communications from us, we will need to retain certain personal data on a suppression list indefinitely so that we know not to send you further marketing communications in the future.
14. Confidentiality and security of your personal data
We are committed to keeping the personal data you provide to us secure and we will take reasonable precautions to protect your personal data from loss, misuse or alteration.
We have implemented information security policies, rules and technical measures to protect the personal data that we have under our control from:
- unauthorised access;
- improper use or disclosure;
- unauthorised modification; and
- unlawful destruction or accidental loss.
All our employees and data processors (i.e. those who process your personal data on our behalf, for the purposes listed above) who have access to and are associated with the processing of personal data are obliged to respect the confidentiality of the personal data of all users of our Site and our Services.
15. Personal data of children
We do not specifically target our Site or our Services at children. However, due to the nature of our organisation and the Services we provide, we may from time to time collect and process personal data relating to individuals under the age of 18. Where we do so, we will comply with all applicable laws and regulations relating to the processing of personal data of minors.
16. How to access your information and your other rights
You have the following rights in relation to the personal data we hold about you. If you would like to exercise any of these rights, please contact us using the details set out in on our Contact page.
- Your right of access
If you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a copy of that personal data (along with certain other details). If you require additional copies, we may charge a reasonable fee for producing those additional copies.
- Your right to rectification
If the personal data we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have shared your personal data with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you who we’ve shared your personal data with so that you can contact them directly.
- Your right to erasure
You can ask us to delete or remove your personal data in some circumstances, such as where we no longer need it or where you withdraw your consent (where applicable). If we have shared your personal data with others, we will let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal data with so that you can contact them directly.
- Your right to restrict processing
You can ask us to ‘block’ or suppress the processing of your personal data in certain circumstances such as where you contest the accuracy of that personal data or you object to us processing it for a particular purpose. This may not mean that we will stop storing your personal data but, where we do keep it, we will tell you if we remove any restriction that we have placed on your personal data to stop us processing it further. If we’ve shared your personal data with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal data with so that you can contact them directly.
- Your right to data portability
You have the right, in certain circumstances, to obtain personal data you have provided to us (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer it to a third party of your choice.
- Your right to object
You can ask us to stop processing your personal data, and we will do so, if we are:
- relying on our own or someone else’s legitimate interest to process your personal data, except if we can demonstrate compelling legal grounds for the processing; or
- processing your personal data for the purposes direct marketing.
- Your rights in relation to automated decision-making and profiling
You have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for the entering into, or the performance of, a contract between you and us.
- Your right to withdraw consent
If we rely on your consent (or explicit consent) as our legal basis for processing your personal data, you have the right to withdraw that consent at any time. You can exercise your right of withdrawal by contacting us using our contact details in the “Get in touch” section above or by using any other opt-out mechanism we may provide, such as an unsubscribe link in an email.
- Your right to lodge a complaint with the supervisory authority
If you have a concern about any aspect of our privacy practices, including the way we have handled your personal data, please contact us using the contact details provided in the “How to contact us” section above. You can also report any issues or concerns to a national supervisory authority in the Member State of your residence or the place of the alleged infringement. You can find a list of contact details for all EU supervisory authorities at: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. As we are incorporated in the UK, our regulatory authority is https://ico.org.uk.
17. Changes to this privacy notice
We may make changes to this Privacy Notice from time to time
To ensure that you are always aware of how we use your personal data, we will update this Privacy Notice from time to time to reflect any changes or proposed changes to our use of your personal data. We may also make changes to comply with changes in applicable law or regulatory requirements.
We will notify you by e-mail of any significant changes to this Privacy Notice. However, we encourage you to review this Privacy Notice periodically to be informed of how we use your personal data.
Last updated 24 September 2019