Data Privacy Notice
Effective Date: 4 July 2018
This privacy statement applies to our website and service at Poplar (https://poplar.studio). We are an online creative community linking up Augmented Reality (“AR”) content creators with major brands, allowing them to create content, get paid for any content selected up by a brand and build their creative chops in the process. Poplar is operated by FF Poplar Limited (“Poplar”), a company registered in England.
Poplar works with its brand partners (each, a “Brand”) to establish creative briefs to be published on Poplar’s creative platform and offered to Poplar’s creative community of which creators produce 2D, 3D and AR content (each, a “brief”).
This privacy statement describes how Poplar (‘Poplar’, ‘We’, ‘Us’ or ‘Our’) collects and uses the personal information you provide on our web Site at https://poplar.studio (the “Site”) and our Poplar service (the “Service”). It also describes the choices available to you regarding our use of your personal information and how you can access and update this information.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting our Site and using our Service you are accepting and consenting to the practices described in this policy.
For the purpose of the Data Protection Act 1998 (the Act), the data controller is Poplar, 45-47 Clerkenwell Green, Clerkenwell, London EC1R 0EB, UK and our Data Protection Officer can be contacted by email at firstname.lastname@example.org.
1. Information We May Collect About You
1.1 Information you give us. You may give us information about you by filling in forms on our Site or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you contact us through our Site, become a customer of our Service, brief us on a campaign or submit a support ticket or otherwise report a problem with our Site. The information you give us may include your name, address, e-mail address and phone number, company you work for and job position, along with details pertaining to the reason you are communicating with us.
1.2 Information we collect about you. Each time you visit our Site, we will typically collect the following usage information:
details of visits to our Site (which enable our Site to remember information about you and your preferences) and use of our Site. This may include information about your visit, including the full URL, clicks through to and from our Site (including date and time), pages you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any data you input into forms on the Site.
Each time you visit our Site or are served an advert from our Service, we will typically collect the following technical information:
what devices you use to connect to our Site or Service, device location data where this function is not disabled by you on your device, the IP address used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform
2. On What Basis Can We Process Your Information?
The legal grounds for processing your personal data are as follows:
It is necessary for the performance of a contract entered into between you and us, or to take steps prior to entering into a contract with you, including operating our Site and Service to perform the features and functionality of the product
Where you have given us consent to the processing of your personal data for one or more specific purposes.
It is necessary for the purposes of our legitimate interests, except where our interests are overridden by the interests, rights or freedoms of affected individuals (such as you). To determine this we shall consider a number of factors, such as what you were told at the time you provided your data, what your expectations are about the processing of the data, the nature of the data, and the impact of the processing on you. Our legitimate interests are to provide a service to our customers, to improve and to promote our services and products and to better understand our customers’ interests and needs.
Where it is necessary for us to do so, including sharing your information with others, in order to comply with a legal obligation.
3. Uses Made Of Your Information
We use the data you give us, we collect about you and we receive from others to:
personalise each audio advert that you will be served, making it more relevant to you. We measure your exposure to each advert by tracking the number of times you have requested it, heard it or clicked it for statistics reporting purposes and for improving our service over time. Nothing we store can be traced back to you as we use a unique and meaningless identifier to refer to the tracking data. We use aggregate trend data to improve the quality of the ads you will be served in the future and to maintain, improve and develop new services. We occasionally produce reports and analytics for our partners and customers. These reports show aggregate data over time to show historical performance and trends and do not contain individual data;
carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us and to notify you about changes to our service.
ensure that content from our Site is presented in the most effective manner for you and for your computer.
provide you with information about our services we feel may interest you, where you have provided permission for us to do so or, if you are an existing customer only, where we choose to contact you by electronic means (including e-mail) with information about our own services similar to those which you have already obtained from us or negotiated to obtain from us . For those marketing messages you can unsubscribe at any time by clicking on the unsubscribe link in the message or replying asking us to stop communicating with you.
communicate with you during the course of providing our services, for example with your enquiries and requests.
5. Disclosure Of Your Information
We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006, for the purposes of operating our service in another territory, or reporting. Our current group members are Poplar Holdings Ltd and Poplar Inc.
We share data with the following third-party data processors or ad exchanges, who we use to help us provide our services. Their privacy policies are linked below:
Customer data: Hubspot CRM
Financial and accounting data: Xero Accounting
Mailing Lists: MailChimp
Email, Calendar, Documents: Google Cloud for Business
Operating system: Windows
Log analysis: SumoLogic
Session tracking: SmartLook
Cloud services: Amazon Web Services
Website hosting: Squarespace
Team communications: Slack
Project management: Atlassian Jira
File sharing: WeTransfer
We may share information with companies, organisations or individuals outside of Poplar if we have a good-faith belief that we are obliged to do so by law.
6. Where We Store Your Personal Data
Your data will sometimes (depending on where the server is located) be held on secure servers within the European Economic Area (“EEA”) with all reasonable technological and operation measures put in place to safeguard it from unauthorised access. Where possible any identifiable information will be encrypted or minimised.
There may be occasions however where data that we collect from or about you may be transferred to, and stored at, a destination outside the EEA where data protection laws are not as strict as they are in the UK. For example, it may also be processed by our staff operating outside the EEA. Such staff may be engaged in, among other things, the fulfilment of your contract and the provision of support services.
Where your personal data is being transferred outside the EEA, we will make sure that any transfers are not repetitive and only limited to the minimum amount of information possible. In certain circumstances we may need to seek your consent unless there is an overriding legal need to transfer the information. In all cases where your information is transferred outside the EEA, you have a right to contact us for information on the measures we have put in place.
7. How Long We Keep Your Data For
We will retain your personal data for only as long as is necessary for the purposes we set out above, but which may at times be a longer period than that for which we need to hold your data to provide those services, i.e. where we are under regulatory or statutory duties to hold your data for a longer period. The following data will be held by us for the periods set out below as is necessary to meet the purposes for which we initially collected this information:
Type of data Retention period
Site data One month, at which point it is aggregated into reporting data and the deleted
Service data One month, at which point it is aggregated into reporting data and the deleted
Customer data For as long as we have an agreement in place or for 1 year after the term of the agreement expires
8. Other WebSite
Our Site may, from time to time, contain links to and from the webSite of our partner networks, advertisers and affiliates. If you follow a link to any of these webSite, please note that these webSite have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these webSite.
9. Data Security
We take all reasonable measures to protect the information we collect and store. All transfers to, from and within our Platform are over HTTPS, our servers are located in a secure facility and we strictly control access to the data via strong passwords and two-factor authentication.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Site or our Service, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
10. Your Rights
Access to your information
You have a right to request a copy of the personal information we hold about you, known as a data subject access request. You also have the right to request that information we hold about you which may be incorrect, or which has been changed since you first told us, is updated or removed. These requests are free of charge and can be sent to email@example.com
Erasure of your information
You can 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 you have withdrawn consent for us to process it (as explained 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.
Withdrawing your consent
You have the right at any time to withdraw any consent you have given us to process your personal data. Please note if you withdraw your consent it will not affect the lawfulness of any processing of your personal data we have carried out before you withdrew your consent. Should you wish to do so you can change your consent preferences at any time, such as to unsubscribe or opt out of marketing emails by replying to the email, contacting us at firstname.lastname@example.org or by unsubscribing on the link in the email.
Restricting or objecting to us using your Information
You can ask us to suspend the way in which we are using your information in certain scenarios, or object to our processing your data where we are relying on a legitimate interest ground (or those of a third party) and you feel it impacts on your fundamental rights and freedoms, or where we are processing your personal data for direct marketing purposes. In some cases where you object, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Please note that if you want us to restrict or stop processing your data this may impact on our ability to provide our services. Depending on the extent of your request we may be unable to continue providing you with our service.
Any queries or concerns about the way in which your data is being used can be sent to email@example.com
Moving your information to another organisation
In the event that we process your data by automated means where you have either provided us with consent for us to use your information or where we used the information to perform a contract with you, you have the right to request that we send to you or to another organisation, a copy of the personal data we hold about you, for example when you are dealing with a different service provider. If you would like us to move, copy, or transfer your information please let us know by email to firstname.lastname@example.org. We will respond to you within one month after assessing whether or not this is possible, taking into account the technical compatibility with the other organisation in question.
Automated decision making and Profiling
In order to provide you with our services, it is necessary for us to conduct profiling on your data, consisting of such as combining data from multiple sources to make a more intelligent decision around which advert to serve you (for example, we may take your rough location and combine it with the weather conditions in your local area so that the ad we serve can reference the weather where you are).
We do not use your information for automated decision making or profiling that may have a legal or similarly significant effect on you.
Our services are not aimed at children.
11. Changes To This Policy
12. Questions Or Comments And Complaints
If you have questions or comments regarding this privacy statement, please contact us at email@example.com. If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to the UK data protection regulator, the Information Commissioner’s Office. Further details can be found at www.ico.org.uk or 0303 123 1113.
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