Privacy Policy

EFFECTIVE DATE: 19th January 2024


We take the privacy of your personal information seriously at Ascendant Fox. This privacy policy outlines how we collect, store, and utilise your information when you use our website, www.ascendant-fox.com or interact with us using our social media pages, or participate in any competitions run by us.


In this policy, references to “Ascendant Fox,” “us,” “we,” or “our” means Ascendant Fox Limited, a company registered in England and Wales under number 10393595. The registered office is at Suite 21 Fmtv, Adam House 7-10 Adam Street, London, England, WC2N 6AA, along with its subsidiaries. Ascendant Fox Limited is the data controller for information processed under this privacy policy.

You possess the right to raise objections if we utilise, share, or undertake the processing of your information in specific situations, such as employing your information for direct marketing. Please feel free to get in touch with us at any time using the contact details provided below for further information and to assert this right where applicable.

 

WHAT PERSONAL INFORMATION DO WE COLLECT ABOUT YOU?

What is personal data?

  • Where this policy refers to ‘personal data’ it is referring to data about you from which you could be identified – such as your name, your date of birth, your contact details and even your IP address. 
  • By law, all organisations who process your personal data in the UK are obliged to process your personal data in certain ways and to ensure that you are given an appropriate amount of information about how they use it. You also have various rights to seek information from those organisations about how they are using your data, and to prevent them from processing it unlawfully. For more information about these rights, please see the ‘Your Rights’ section of this policy.

 

What types of data we collect from you when you use our website

The personal data we collect from you may include:

  • Identity Data which includes your name, date of birth, gender and image (whether in photograph or image format).
  • Contact Data which includes your e-mail address.
  • Technical Data which includes your IP address, your login data and browser type and version.
  • Profile Data which includes your username and password, your interests, preferences, competition entries, feedback and survey responses.
  • Usage Data which includes information about how you use our website or interact with our social media pages.
  • Marketing and Communications Data which includes your preferences in receiving marketing from us and our associated third parties.

 

Special Category Data

 

  • We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data. Nor do we collect any information about criminal convictions and offences.

 

We collect and process your information in the following ways:

 

Information you give us

  • You provide us with information about yourself when you get in touch with us or engage with us in any manner, whether through our website, email, letter, phone call, or social media including to enter any competition or promotion we may run from time to time.

 

Information from third parties

  • We gather information from other entities within our group for internal purposes, mainly for business and operational needs, and we guarantee that your information is handled in accordance with this privacy policy.

 

Automatically collected information

  • We automatically collect specific information, such as through cookies and web beacons, each time you visit our website. This may encompass your IP address, browser type, operating system, referral URLs, details about actions taken on our website, and the dates and times of website visits. For more information about how we use cookies, please see the ‘How Do We Use Cookies To Collect Personal Data About You’ section of this policy. 

 

Personal data of Children

  • Please note that we may collect and process personal data of children under the age of 18 (each a “Child” or “Children.”) Where we rely on performance of a contract as the lawful basis for processing Children’s data, we shall consider whether the Child is capable of understanding the obligations it is entering into. Where we rely on legitimate interest as the lawful basis for processing of Children’s data, we shall give due weight to the additional risks to Children of processing of their personal data. Where we rely on consent as the lawful basis for the processing of Children’s data and any Child is under the age of 13 years, we shall seek the consent of a parent or guardian to process the personal data.

 

HOW DO WE USE YOUR PERSONAL INFORMATION?

 

To provide a requested service or carry out a contract with you

  • To fulfil any agreement established between you and us.
  • To enable you to participate in any competitions we run.

 

Where we have a legitimate interest

  • To handle and examine inquiries, questions, and complaints, and to provide responses to any feedback.
  • To gather statistics on the behaviour of our website visitors and other users of our services.
  • To aid in achieving a successful resolution of disputes.
  • To advance and enhance our interaction with you.
  • To ensure the efficient operational management and internal administration of our business, including document retention, compliance with regulatory guidance, and the exercise or defence of legal claims.
  • To enforce any agreement in place with you, or to safeguard the rights, property, safety, or security of Ascendant Fox Limited, third parties, users of our services, or the public.

 

Where we have a legal obligation

  • When we are obligated to process your information to adhere to (and/or when we reasonably believe we are obligated to adhere to) any legal obligation.

 

Where we have your consent

  • To allow us to market or promote any competitions we run and publicise the winners of that competition.
  • For any situation where we specifically ask for your consent.

 

Where we rely on legitimate interest for processing your information, we carry out a ‘balancing test’ to ensure that our processing is necessary and that your fundamental rights of privacy are not outweighed by our legitimate interests, before we carry out such processing. 

 

MARKETING AND COMMUNICATIONS 

 

  • We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you.  This is how we decide which services and offers may be relevant for you (we call this marketing).
  • You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
  • We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

 

Opting Out of Marketing 

  • To unsubscribe from marketing emails at any time, please click on the unsubscribe link at the bottom of any marketing email and update your preferences. You may also contact us or the third party directly if you do not wish to receive any marketing materials from us or them. 

 

HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?

We retain your information only for the duration required to utilise it as explained above, whether in our legitimate interest or to fulfil our legal obligations. Nevertheless, it’s important to note that certain information may be retained even after you stop using our services. This retention could be necessary to fulfil our legal obligations, such as retaining information for tax and accounting purposes.

 

In determining the appropriate retention periods, we consider various factors, including:

 

  1. Our contractual obligations and rights related to the information involved;
  2. Legal obligation(s) under applicable law necessitating data retention for a specific duration;
  3. Our legitimate interest, subject to a balancing test;
  4. Statute of limitations under applicable law(s);
  5. (Potential) disputes;
  6. Requests for information deletion from you, if any; and
  7. Guidelines provided by relevant data protection authorities.

 

If there is no longer a legitimate reason for retaining your information, we securely erase or anonymise it.

 

WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?

  • We disclose your personal information to trusted third parties whom we have engaged to provide services on our behalf. This includes professional advisors (such as lawyers and accountants), service providers (like our communications and website design agencies), IT consultants handling testing and development on our website, and analytics/search engine providers aiding in the enhancement and optimisation of our services.
  • We also share your personal information with our affiliated group companies for internal purposes, mainly for business and operational needs.
  • In instances where necessary, we may share your personal information with third parties to fulfil a legal obligation, comply with applicable laws, respond to governmental investigations, verify or enforce our Competition Terms and Conditions or other policies, detect and protect against fraud or security vulnerabilities, respond to emergencies, or safeguard the rights, property, safety, or security of third parties, website visitors, our business, or the public.
  • As our business evolves, we may engage in asset sales or purchases. If another entity acquires or merges with us, your personal information will be disclosed to that entity. In the event of bankruptcy or reorganisation proceedings involving us, such information may be considered an asset and could be sold or transferred to third parties.

 

WHAT HAPPENS IF YOU DO NOT PROVIDE US WITH THE INFORMATION WE REQUEST OR ASK THAT WE STOP PROCESSING YOUR INFORMATION?

  • If you choose not to provide the personal information necessary, or decide to withdraw your consent for the processing of your personal information, where this information is necessary for us to provide services to you, we will be unable to provide these services to you.

 

DO WE MAKE AUTOMATED DECISIONS CONCERNING YOU?

  • No, we do not carry out automated decision making.

 

HOW DO WE USE COOKIES TO COLLECT PERSONAL DATA ABOUT YOU?

 

  • This website uses “cookies” to help you personalise your online experience. A cookie is a text file that is placed by us or our partners on your hard drive by a web page server. Our cookies do not run programs or deliver viruses to your computer. Cookies are uniquely assigned to your computer and can only be read by a web server in the domain that issued the cookie to your computer. The following are examples of information we may collect:
    • information about your device, browser or operating system;
    • your IP address;
    • information about links that you click and pages you view on our website;
    • length of visits to certain pages;
    • subjects you viewed or searched for; 
    • page response times;
    • records of download errors and/or broken links;
    • page interaction information (such as details of your scrolling, clicks, and mouse-overs);
    • methods used to browse away from the page; and
  • the full Uniform Resource Locators (URL) clickstream to, through and from this website (including date and time). 
  • One of the primary purposes of cookies is to provide a convenient feature to save you time. The cookie tells the server that you have returned to a specific page. For example, if you personalise the website pages, a cookie helps the website recall your specific information on subsequent visits. This simplifies the process of recording your personal data, such as your identity information or site preferences. When you return to the website, the information you previously provided can be retrieved, so you can easily use the website features that you customised.

We may place the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of the website. They include, for example, cookies that enable you to log into secure areas of our website or make use of e-billing services.
  • Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies. These are used to recognise you when you return to the website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  • Targeting cookies. These cookies record your visit to the website, the pages you have visited and the links you have followed. We will use this information to make our website more relevant to your interests.

If you want to check or change what types of cookies you accept, this can usually be done within your browser settings. Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control.

 

You can see a complete list of all cookies used on our website and services by clicking here. 

How to reject cookies:

  • You can change your cookie preferences at any time by opting out. 
  • Alternatively, most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set, visit www.aboutcookies.org.

 

DO WE TRANSFER YOUR PERSONAL INFORMATION OUTSIDE THE UK?

  • Under specific circumstances, we might transfer your information beyond the UK. For instance, if we utilise cloud-based solutions, your data may be stored on servers located outside the UK, including the EEA and the USA. When transferring your information to these regions, we only do so where the Information Commissioner’s Office (“ICO”), the UK’s regulator for data protection issues, has deemed that country as providing an adequate level of protection for personal data or, where no such adequacy decision has been reached, where we have put in place suitable safeguards as permitted by UK data protection law, such as the standard contractual clauses issued by the ICO.

 

WHAT ARE YOUR RIGHTS?

  • Legally, you possess several rights concerning your personal information. To exercise any of these rights, please reach out to us using the contact details provided below. Additional information and guidance regarding your rights can be obtained from the data protection regulator in your country.

 

Rights What does this mean?
The right to object to processing You hold the right to object to specific types of processing, including activities related to direct marketing (i.e., if you wish to stop receiving communications from us).
The right to be informed You hold the right to receive clear, transparent, and easily understandable information about how we utilise your information and the rights you hold. 
The right of access You possess the right to obtain access to copies of your information (if we’re processing it), and certain other information (similar to what is outlined in this policy).

This allows you to stay informed and verify that we are handling your information in accordance with data protection laws.
The right to rectification You have the right to request the correction of your information if it is inaccurate or incomplete.
The right to erasure This is commonly referred to as ‘the right to be forgotten,’ allowing you to request the deletion or removal of your information when there is no compelling reason for us to retain it. It’s important to note that this is not an absolute right, and certain exceptions apply.
The right to restrict processing You possess the right to ‘block’ or suppress the further use of your information. When processing is restricted, your information can still be stored but cannot be used further. We maintain lists of individuals who have requested the ‘blocking’ of their information to ensure that the restriction is adhered to in the future.
The right to data portability You possess the right to obtain and reuse your personal information for your own purposes across various services.
The right to lodge a complaint You hold the right to file a complaint regarding the manner in which we handle or process your personal information with the ICO. Please refer to the contact details for the ICO in the section below.
The right to withdraw consent If you have granted consent for any processing of your personal information, you retain the right to withdraw your consent at any time. It is important to note that withdrawing consent does not render any prior processing of your personal information, conducted with your consent, unlawful. This includes your right to withdraw consent for the use of your personal information for marketing purposes.

 

Typically, we fulfil requests and furnish information without charge. However, in certain cases, we may impose a reasonable fee to cover administrative costs for:

  • Manifestly unfounded or excessive/repeated requests, or
  • Additional copies of the same information.

 

Alternatively, we may be entitled to decline to act on the request.

 

We encourage responsible consideration of your request before submission. We aim to respond promptly, generally within one month of receiving your request. If additional time is required to address the request, we will inform you accordingly.

 

WILL WE UPDATE THIS PRIVACY POLICY?

We may make occasional revisions to this privacy policy. In cases where we have an ongoing relationship with you, we will inform you of any substantial changes. Otherwise, updated versions will be posted on our website at www.ascendant-fox.com/privacy.

 

HOW CAN YOU CONTACT US?

If you have any questions or requests regarding this privacy policy or how we manage your information, please contact us using the following details:

 

Email: info@ascendantfox.com

Post: Suite 21 Fmtv, Adam House 7-10 Adam Street, London, England, WC2N 6AA

 

HOW CAN I MAKE A COMPLAINT?

If you are dissatisfied with our response to a complaint you have filed, or believe that we are not in compliance with data protection law, you have the option to lodge a complaint with the ICO. The contact details for the regulator are provided below:

 

Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

Phone number: 0303 123 1113

Website: https://ico.org.uk/make-a-complaint