• Third parties or publicly available sources. We will not send your personal data about you to any various third parties without your express consent to do so, such as Mailchimp who are based in the United States of America.  
   

• Technical Data from the following parties:

  • advertising networks such as Mailchimp based outside of the EU.
     

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
 

• Where we need to perform the contract with you.
   

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
   

• Where we need to comply with a legal obligation.
   

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications and you have the right to withdraw your consent at any time and for any purpose.
 

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.
 

We strive to provide you with choices regarding certain personal data uses, particularly around marketing however we do not conduct any marketing activities.
 

• Third-party marketing: we will get your express opt-in consent before we share your personal data with any third party and shall inform you of such third party, for marketing purposes and generally we do not share your personal data with any third party.
   

• Opting out: you can ask us to stop sending you marketing messages or our newsletter at any time by contacting us  or clicking our unsubscribe links sent in any e-mails. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase.
   

• Cookies: You can set your browser to refuse all or some browser cookies however some part of our website might not work if you do this, please see our cookie policy here.
   

Change of purpose

We will only ever use your personal data for the purposes for which we collected it.
 

If we need to use your personal data for any unrelated purpose which shall not be for which we collect it, we will notify you and we will explain the legal basis of this.  
 

We may process your personal data without your knowledge or consent, where this is required or permitted by law.

 

Disclosures of your personal data

We may share your personal data with, Internal or External or Specific Third Parities as set out herein this privacy policy and as set out above in Purposes for which we will use your personal data.
 

• Internal Third Parties other companies such as Mailchimp acting as joint controllers or processors and who are based United Servers and provide IT and system administration services and undertake leadership reporting.
   

• External Third Parties Service providers acting as processors based the United Kingdom or the United States such a Mailchimp who provide IT and system administration services.
   

• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
   

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions and your consent at all times.

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International transfers
We share your personal data within the Mailchimp. This will involve transferring your data outside the European Economic Area (EEA) to the United States of America.
 

Our external third parties including Mailchimp are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA from them.
 

Whenever we transfer your personal data out of the EEA via Mailchimp, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: - 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 European Commission: Adequacy of the protection of personal data in non-EU countries.
 

• Where we use certain service providers such as Mailchimp, 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 European Commission: Model contracts for the transfer of personal data to third countries. 
   

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
 

Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
 

Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
 

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us. In some circumstances you can ask us to delete your data: see your legal rights below for further information.
 

Your legal rights: You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
 

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
 

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
 

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

 

• If you want us to establish the data's accuracy.

• Where our use of the data is unlawful but you do not want us to erase it.

• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
   

 

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
 

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
 

If you wish to exercise any of the rights set out above, please contact our data privacy manager, Tom Cornfoot, email address of tom@astudioofourown.com address of 73a Beak Street, London. W1F 9SR Subject Access Request - you will not have to pay a fee to access your personal data (or to exercise any of the other rights). We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.