Privacy policy
Short Version
Your privacy is important to us. It is New Groove Creative policy to respect your privacy regarding any information we may collect from you across our website, https://www.newgroove.com, and other sites we own and operate.
We only ask for personal information when we truly need it to provide a service to you. We collect it by fair and lawful means, with your knowledge and consent. We also let you know why we’re collecting it and how it will be used.
We only retain collected information for as long as necessary to provide you with your requested service. What data we store, we’ll protect within commercially acceptable means to prevent loss and theft, as well as unauthorised access, disclosure, copying, use or modification.
We don’t share any personally identifying information publicly or with third-parties, except when required to by law.
Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and practices of these sites, and cannot accept responsibility or liability for their respective privacy policies.
You are free to refuse our request for your personal information, with the understanding that we may be unable to provide you with some of your desired services.
Your continued use of our website will be regarded as acceptance of our practices around privacy and personal information. If you have any questions about how we handle user data and personal information, feel free to contact us.
This policy is effective as of 30th July 2019.
Extended Version
1 Our Privacy Principles
We take privacy seriously. Here are our 6 privacy promises to you:
We will respond to any questions on processing of your Personal Data without undue delay.
We will ensure that your Personal Data is used in line with applicable data protection laws.
We will be transparent with you about how we use your Personal Data. This includes informing you about what information we collect, what we do with it, with whom we share it and whom you should contact if you have any concerns.
We will provide you simple options to say 'STOP' when you are no longer happy with our marketing communications.
We will protect online and offline data in a similar manner.
We will take reasonable steps to make sure no unauthorised person accesses your Personal Data.
2 Our Privacy Policy
We are committed to safeguarding your privacy and ensuring that your Personal Data is protected. This Privacy Policy explains the types of Personal Data we collect and how we process and protect that data.
This Privacy Policy applies to Personal Data processed by us in connection with the services and products we offer to you, including through the website https://www.newgroovecreative.com/. This includes Personal Data collected offline through our applications and branded pages on third party platforms and applications accessed or used through such websites or third party platforms.
This Privacy Policy also applies to our targeted content, including online offers and advertisements for products and services, which we (or a service provider acting on our behalf) may send to you on third party websites, platforms and applications based on your use of the internet. These Third-Party Sites may have their own privacy policies and terms and conditions. We encourage you to read them before using those Third-Party Sites.
2.1 When do we ask for your consent?
By using our Services and our Sites, you acknowledge that we are processing your Personal Data in accordance with this Privacy Policy. If you do not wish that we process your Personal Data in this way, please do not use our Service or Sites or otherwise provide our Sites with your Personal Data.
We process your Personal Data to provide you the Services and the Site. In certain instances, we only process your Personal Data if you have consented, for example in certain cases where we process your Personal Data for marketing purposes, use cookies or process your sensitive Personal Data. Where we process your Personal Data on the basis of your consent, we will ask for your consent explicitly but, in some cases and only where permitted by applicable law, we may infer in a transparent manner consent from your actions. We may also ask you to provide additional consent if we need to use your Personal Data for purposes not covered by this Privacy Policy or before sharing your Personal Data with group companies or relevant subsidiaries of New Groove Creative for the purposes of marketing.
2.2 What happens if our customer is a child?
Our Services and Sites are intended for adults, but there could be instances where some customers under the age of 16 decide to view or purchase Services on our Sites. Our rule is that if we know a customer is under the age of 16, we will not use such customer’s Personal Data for marketing purposes unless parental consent is provided to us in writing. We will not sell any Services to customers under the age of 16.
To provide parental consent, please write to the New Groove Creative. Note however that access to certain parts of our Sites and/or Services may be limited to users over a certain age. We may use your Personal Data to carry out age verification checks and enforce any such age restrictions.
2.3 For which purposes do we process your Personal Data?
We collect your Personal Data directly when you provide us with Personal Data when you visit our Sites, purchase Services, subscribe to our newsletter, receive information or mailings, use our applications, complete a survey, enter into one of our online competitions/giveaways and/or make a comment or enquiry or contact our customer services. We may also receive Personal Data about you from other sources, including information from commercially available sources, such as public databases and data aggregators, and information from third parties.
In more detail, we process the following categories of Personal Data for the following purposes:
2.4.1 Surfing on our Sites – with or without Cookies
2.4.1.1 Which Personal Data do we collect about you?
For this purpose (Surfing on our website) we process the following Personal Data: Information about the type of browser you use, details of the web pages you have viewed, your IP and device address, your Cookie ID, hyperlinks that you have clicked, your user name, profile picture, gender, networks, the websites you visited before arriving at our relevant Sites and information collected by cookies or similar tracking devices and any other information you choose to share when using Third Party Sites, e.g. when visiting New Groove Creative sites on social media networks, such as Facebook, Instagram, Twitter or New Groove Creative YouTube channel). Our Sites involve simple links to social media networks; depending on the technology used by the social media it may be the case that New Groove Creative will transmit Personal Data to the provider of the relevant social media network when you click on such link.
2.4.1.2 What is the purpose of processing your Personal Data?
We (and third-party service providers acting on our behalf or on their own behalf) use cookies and similar technologies to process data about you when you visit our relevant Sites. Cookies are files that store information on your computer hard drive or browser that mean that we can recognise that you have visited us before. We use cookies and similar technologies to improve our products and your experience on our Sites by evaluating the use of our Sites, products and services and understand your browsing and shopping habits, analysing the effectiveness of our advertisements, personalising your website experience as well as evaluating statistics on website activity, evaluating (anonymously and in the aggregate) statistics on website activity, such as what time you visited it, whether you've visited it before and what site referred you to it, reviewing the Services that you have searched online and ended up purchasing them, making our Sites easier to use and to better tailor our Sites and our Services to your interests and needs, identifying that you have visited our Sites but did not purchase a Service, collecting information about your device and linking this to your Personal Data so as to ensure that our Sites present the best web experience for you and supplementing the Personal Data that you provide to us with other information that we hold or that we may receive from commercially available sources, such as public databases and data aggregators, and third parties.
2.5.1.3 What is the legal basis for processing your Personal Data?
Your Consent is the legal basis for processing your Personal Data when surfing on our Sites. You can customise your browser's cookie settings to reflect your comfort level with cookie security.
2.4.2 Contact
2.4.2.1 Which Personal Data do we collect about you?
For this purpose (Contact) we process the following Personal Data: Surname, name, company email address, telephone or mobile number, medical information, country, posts and other content you submit to our Sites, other Personal Data you voluntarily provide to us, information on the handling of your request, queries from us and further information submitted with your request. Please, however, refrain from sending us information on your health or other sensitive data in unencrypted emails.
2.4.2.2 How long do we store your Personal Data?
We will store your Personal Data only until the aforementioned purposes for which we have collected or received your Personal Data are fulfilled and once our statutory obligations to preserve records have expired.
2.4.2.3 What is the legal basis for processing your Personal Data?
Applicable data protection legislation allows New Groove Creative to process your Personal Data for the purpose of performance of a contract with you (i.e. fulfil your contact request).
If you provide to us Personal Data that is considered sensitive (e.g. information on your health or ethnic origin), your consent will be the legal basis for processing your Personal Data.
2.4.3 Suggestion of our products and services which may be of interest for you; marketing communication
2.4.3.1 Which Personal Data do we collect about you?
For this purpose (suggestion of our products and services which may be of interest for you ) we process the following Personal Data: Surname, name, company email address, telephone or mobile number, passwords, company, country, Services you view on our Sites, actions you take on our website or when viewing our emails and your shopping habits and preferences.
2.5 Who is receiving your Personal Data?
2.5.1 Other recipients (controllers)
We may share your Personal Data with the following controllers (i.e. third parties that process your Personal Data for their own purposes):
social media platforms (e.g. Facebook, Instagram) so that they can help us deliver our advertisements directly to your social media page or mailbox;
law enforcement or other agencies if we are required to do so by law, or by a warrant, subpoena or court order to disclose your Personal Data.
Companies we are running campaigns/promotions with.
2.5.2 Sharing your Site usage information
We may with your consent share site usage information with trusted third parties (e.g. advertisers, advertising agencies, advertising networks, data exchanges, etc.) in order to offer you tailored content, including more relevant advertising for products and services which may be of interest to you. These trusted third parties may set and access their own cookies, web beacons and similar tracking technologies on your device in order to help us deliver customised content and advertising to you when you visit our relevant Sites or third-party sites.
2.6 To which countries do we transfer your Personal Data?
Many of the recipients of your Personal Data are based in the European Union / the European Economic Area. However, we may need to transfer your Personal Data to a location outside of the European Economic Area, including to countries that do not offer the same level of protection with respect to Personal Data as required in the European Economic Area and where there is no adequacy decision by the European Commission. If your Personal Data should be transferred to such country, we have ensured that an adequate level of data protection is achieved by a recognised legal mechanism, e.g. by means of the EU-U.S. Privacy Shield certification, so-called Standard Contractual Clauses, as published by the European Commission or Binding Corporate Rules.
2.7 How long do we process your Personal Data?
We will store your Personal Data only until the aforementioned purposes for which we have collected or received your Personal Data have been fulfilled and once our statutory obligations to retain records have expired.
2.8 What are your rights?
You have the right to request from us
Confirmation as to whether or not we process Personal Data from you and, where that is the case, access to your Personal Data;
Rectification of inaccurate Personal Data;
Erasure of Personal Data;
Restriction of processing of Personal Data; and
To receive the Personal Data which you have provided to us and to have transmitted those Personal Data to another data controller without hindrance.
2.9 Can you withdraw your consent to the processing of Personal Data?
If your consent is the legal basis for the processing of your Personal Data, you can withdraw your consent at any time. This will not affect the lawfulness of the processing based on your consent before the withdrawal. You can withdraw your consent by sending us an email, or by calling us.
2.10 Can you complain with the data protection authorities?
If you think that the processing of Personal Data by us violates applicable data protection laws, you can lodge a complaint with the competent supervisory authority.
2.11 How do we protect your Personal Data?
We maintain appropriate technical and organisational measures to protect the Personal Data you provide to us against accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to your Personal Data. Our security measures are being improved continuously as new technology develops. The processing and transmission of data through our Sites is encrypted by Secure Sockets Layer protocol (“SSL”), which is an encrypting technology to ensure the highest possible security for the transmission of your data, including Personal Data, between your web browser and our internet system. The URL of a website with SSL connection to your browser starts with “https://”. Most browsers indicate SSL-encrypted websites by displaying an icon that depicts a closed padlock. This icon might be located in the address bar or the bottom status bar. If you have turned off your status bar, this icon may not be visible, even on websites that use SSL.
Our Sites may contain hyperlinks to other websites provided by third parties. We do not control these third-party websites or any of the content contained on those websites. Once you have left our relevant Sites, we cannot be responsible for the protection and privacy of any information which you provide. You should exercise caution and look at the relevant privacy policy for the website you visit.
2.14 Can we change our Privacy Policy?
We may change this Privacy Policy from time to time by posting the updated version of the privacy policy here. To the extent processing of your Personal Data be based on your consent, we will not change the scope of such processing, unless you have given additional consent to the changed scope of such processing. We encourage you to visit this area frequently to stay informed.