This privacy notice explains what you can expect us to do with your personal information.

You can access our Cookie policy separately here.

Who we are

JR Humphreys Consulting Limited, trading as Kitedown Creative.

Contact details
Telephone: 07740292015
Email: jenny@kitedowncreative.com

What information we collect, use, and why

We collect or use the following information to provide services and goods, including delivery:
• Names and contact details
• Addresses
• Photographs or video recordings
• Call recordings
• Records of meetings and decisions

We collect or use the following information for service updates or marketing purposes:
• Names and contact details
• Marketing preferences

We collect or use the following personal information for dealing with queries, complaints or claims:
• Names and contact details

Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
• Your right of access – You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.
• Your right to rectification – You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.
• Your right to erasure – You have the right to ask us to delete your personal information. Read more about the right to erasure.
• Your right to restriction of processing – You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.
• Your right to object to processing – You have the right to object to the processing of your personal data. Read more about the right to object to processing.
• Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.
• Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. 
If you make a request, we must respond to you without undue delay and in any event within one month.
To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information to provide services and goods are:
• Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

Our lawful bases for collecting or using personal information for service updates or marketing purposes are:
• Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:
• Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

Where we get personal information from

• Directly from you

How long we keep information

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, including meeting legal, accounting and contractual obligations.
Our standard retention periods are:
• General enquiries: Where an enquiry does not result in an appointment or engagement, we normally delete the associated personal information 12 months after our last meaningful communication.
• Unsuccessful quotations and proposals: We normally retain relevant correspondence, proposals and quotations for up to 24 months after our last meaningful communication.
• Client projects and consultations: We normally retain relevant project records, agreements, correspondence and design documentation for six years following completion of our services, to maintain appropriate business records and respond to potential contractual queries or disputes. Information that is no longer necessary may be deleted sooner.
• Financial and accounting records: We retain invoices, payment records and supporting documentation for at least six years from the end of the relevant accounting period, or longer where required by law.
• Supplier and contractor records: We retain relevant information for as long as necessary to administer our business relationships and projects, generally up to six years following the relevant project or transaction where appropriate.
• Marketing communications: Where we hold contact details for marketing purposes, we review these at least annually and remove information that is no longer necessary. We respect requests to stop marketing communications and may retain minimal details to ensure those preferences continue to be honoured.
• Data protection complaints: We normally retain records of complaints and their resolution for three years after closure, unless an ongoing dispute, legal obligation or other justified reason requires longer retention.

We review personal information periodically and securely delete or anonymise information that is no longer required.
In some circumstances, we may need to retain information for longer, for example where there is an ongoing legal dispute, regulatory investigation or statutory obligation. We will limit such retention to what is reasonably necessary.

Who we share information with

Others we share personal information with
• Other relevant third parties: Your address and contact details may be passed to suppliers and service providers so that they can contact your directly – with your permission only.

How to complain

If you have any concerns about our use of your personal information, you can make a data protection complaint to us:

Email: jenny@kitedowncreative.com

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.
The ICO’s address:
ICO Head Office
4th Floor, No.3 Circle Square
5 Hawkshaw Street
Manchester
M1 7BL
Helpline number: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint