Privacy Policy

DATA PROTECTION POLICY

FOR NOISY CLAN LTD

LAST UPDATED: December 19, 2023

DEFINITIONS

Company: Noisy Clan, Ltd

Company Address: 272 Bath Street, Glasgow G2 4JR.

Registration: SC655535

GDPR means the General Data Protection Regulation.

Responsible Person means the CEO of Noisy Clan ltd. 

Register of Systems means a register of all systems or contexts in which personal data is processed by Noisy Clan ltd.

1. DATA PROTECTION PRINCIPLES

Noisy Clan, Ltd. is committed to processing data in accordance with its responsibilities under the GDPR.

Article 5 of the GDPR requires that personal data shall be:

1. processed lawfully, fairly and in a transparent manner in relation to individuals;
2. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
4. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
5. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
6. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”

2. GENERAL PROVISIONS

1. This policy applies to all personal data processed by Noisy Clan, Ltd..
2. The Responsible Person shall take responsibility for Noisy Clan, Ltd.’s ongoing compliance with this policy.
3. This policy shall be reviewed at least annually.
4. Noisy Clan, Ltd. shall register with the Information Commissioner’s Office as an organisation that processes personal data.

3. LAWFUL, FAIR AND TRANSPARENT PROCESSING

1. To ensure its processing of data is lawful, fair and transparent, Noisy Clan, Ltd. shall maintain a Register of Systems.
2. The Register of Systems shall be reviewed at least annually.
3. Individuals have the right to access their personal data and any such requests made to Noisy Clan, Ltd. shall be dealt with in a timely manner.

4. LAWFUL PURPOSES

1. All data processed by Noisy Clan, Ltd. must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information).
2. Noisy Clan, Ltd. shall note the appropriate lawful basis in the Register of Systems.
3. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in  consent shall be kept with the personal data.
4. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in Noisy Clan Ltd.’s systems. 

5. DATA MINIMISATION

1. Noisy Clan, Ltd. shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
2. Noisy Clan Ltd. uses marketing retargeting pixels from Meta, TikTok and Google. These pixels and API data are use first and third party cookies to combine data-sharing to optimize ads performance and reach the most customers. This data is anonymous to Noisy Clan and we will not be able to control how users see or interact with ads. To learn more about controlling your ad personalizations please visit Google, TikTok, Meta. 

6. ACCURACY

1. Noisy Clan, Ltd. shall take reasonable steps to ensure personal data is accurate.
2. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.

7. ARCHIVING / REMOVAL

1. To ensure that personal data is kept for no longer than necessary, Noisy Clan, Ltd. shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
2. The archiving policy shall consider what data should/must be retained, for how long, and why.
3. All email addresses are opted in by the user on the website user or Meta. To stop receiving communications from Noisy Clan, please use the unsubscribe option at the bottom of email correspondence. 

8. SECURITY

1. Noisy Clan, Ltd. shall ensure that personal data is stored securely using modern software that is kept-up-to-date. 
2. Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
3. When personal data is deleted this should be done safely such that the data is irrecoverable.
4. Appropriate back-up and disaster recovery solutions shall be in place.

9. BREACH

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, Noisy Clan, Ltd. shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website).