This Application collects some Personal Data from its Users.
Owner and Data Controller
WCCM, Bridget Chetwynd – St Marks, Myddelton Square London EC1R 1XX +44 (0) 020 7278 2070
Owner contact email: officemanager@beingdesign
Types of Data collected
Among the types of Personal Data that this Application collects, by itself or through third parties, there are:
email address, first name, last name, Cookies, Usage Data, phone number, profession, province, state,
country, ZIP/Postal code, gender, date of birth, city, address, company name and website.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when
using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this
Data may make it impossible for this Application to provide its services. In cases where this Application
specifically states that some Data is not mandatory, Users are free not to communicate this Data without
consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
used by this Application serves the purpose of providing the Service required by the User, in addition to any
Users are responsible for any third-party Personal Data obtained, published or shared through this
Application and confirm that they have the third party’s consent to provide the Data to the Owner.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or
unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational
procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the
Data may be accessible to certain types of persons in charge, involved with the operation of this Application
(administration, sales, marketing, legal, system administration) or external parties (such as third-party
technical service providers, mail carriers, hosting providers, IT companies, communications agencies)
appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested
from the Owner at any time.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
Users have given their consent for one or more specific purposes. Note: Under some legislations the
Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”),
without having to rely on consent or any other of the following legal bases. This, however, does not
apply, whenever the processing of Personal Data is subject to European data protection law;
provision of Data is necessary for the performance of an agreement with the User and/or for any precontractual obligations thereof;
processing is necessary for compliance with a legal obligation to which the Owner is subject;
processing is related to a task that is carried out in the public interest or in the exercise of official
authority vested in the Owner; processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in
particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement
necessary to enter into a contract.
The Data is processed at the Owner’s operating offices and in any other places where the parties involved in
the processing are located.
Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other
than their own. To find out more about the place of processing of such transferred Data, Users can check the
section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union
or to any international organization governed by public international law or set up by two or more countries,
such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document
or inquire with the Owner using the information provided in the contact section.
Personal Data shall be processed and stored for as long as required by the purpose they have been collected
Personal Data collected for purposes related to the performance of a contract between the Owner and
the User shall be retained until such contract has been fully performed.
Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as
needed to fulfill such purposes. Users may find specific information regarding the legitimate interests
pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent
to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to
retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation
or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to
erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the
following purposes: Contacting the User, Managing contacts and sending messages, Advertising, Handling
payments, Interaction with external social networks and platforms and Analytics.
Users can find further detailed information about such purposes of processing and about the specific Personal
Data used for each purpose in the respective sections of this document.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
This type of service allows User Data to be utilized for advertising communication purposes displayed
in the form of banners and other advertisements on this Application, possibly based on User interests.
This does not mean that all Personal Data are used for this purpose. Information and conditions of use
are shown below.
retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those
detected outside this Application. For more information, please check the privacy policies of the
In addition to any opt out offered by any of the services below, the User may opt out of a third-party
Direct Email Marketing (DEM) (this Application)
This Application uses the User Data to propose services and products provided by third parties or
unrelated to the product or service provided by this Application.
Personal Data collected: email address.
The services contained in this section enable the Owner to monitor and analyze web traffic and can be
used to keep track of User behavior.
Google Analytics (Google Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the
Data collected to track and examine the use of this Application, to prepare reports on its activities and
share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising
Personal Data collected: Cookies and Usage Data.
Contacting the User
Mailing list or newsletter (this Application)
By registering on the mailing list or for the newsletter, the User’s email address will be added to the
contact list of those who may receive email messages containing information of commercial or
promotional nature concerning this Application. Your email address might also be added to this list as a
result of signing up to this Application or after making a purchase.
Personal Data collected: address, city, company name, Cookies, country, date of birth, email address,
first name, gender, last name, phone number, profession, province, state, Usage Data, website and
Payment processing services enable this Application to process payments by credit card, bank transfer
or other means. To ensure greater security, this Application shares only the information necessary to
execute the transaction with the financial intermediaries handling the transaction.
Some of these services may also enable the sending of timed messages to the User, such as emails
containing invoices or notifications concerning the payment.
PayPal (PayPal Inc.)
PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments.
Stripe (Stripe Inc)
Stripe is a payment service provided by Stripe Inc.
Interaction with external social networks and platforms
This type of service allows interaction with social networks or other external platforms directly from
the pages of this Application.
The interaction and information obtained through this Application are always subject to the User’s
privacy settings for each social network.
This type of service might still collect traffic data for the pages where the service is installed, even
when Users do not use it.
Facebook Like button and social widgets (Facebook, Inc.)
The Facebook Like button and social widgets are services allowing interaction with the Facebook
social network provided by Facebook, Inc.
Personal Data collected: Cookies and Usage Data.
Twitter Tweet button and social widgets (Twitter, Inc.)
The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social
network provided by Twitter, Inc.
Personal Data collected: Cookies and Usage Data.
Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any
other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by
the User, as well as when the User interacted with it, such as by clicking on links included in the
MailChimp (The Rocket Science Group, LLC.)
MailChimp is an email address management and message sending service provided by The Rocket
Science Group, LLC.
Personal Data collected: email address.
Mandrill (The Rocket Science Group, LLC.)
Mandrill is an email address management and message sending service provided by The Rocket
Science Group, LLC.
Personal Data collected: email address and Usage Data.
Further information about Personal Data
Selling goods and services online
The Personal Data collected are used to provide the User with services or to sell goods, including
payment and possible delivery.
The Personal Data collected to complete the payment may include the credit card, the bank account
used for the transfer, or any other means of payment envisaged. The kind of Data collected by this
Application depends on the payment system used.
Personal Data collected through sources other than the User
The Owner of this Application may have legitimately collected Personal Data relating to Users without
their knowledge by reusing or sourcing them from third parties on the grounds mentioned in the section
specifying the legal basis of processing.
Where the Owner has collected Personal Data in such a manner, Users may find specific information
regarding the source within the relevant sections of this document or by contacting the Owner.
Analysis and predictions based on the User’s Data (“profiling”)
The Owner may use the Personal and Usage Data collected through this Application to create or update
User profiles. This type of Data processing allows the Owner to evaluate User choices, preferences and
behaviour for the purposes outlined in the respective section of this document.
User profiles can also be created through the use of automated tools like algorithms, which can also be
provided by third parties. To find out more, about the profiling activities performed, Users can check
the relevant sections of this document.
The User always has a right to object to this kind of profiling activity. To find out more about the User’s
rights and how to exercise them, the User is invited to consult the section of this document outlining
the rights of the User.
The rights of Users
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:
Withdraw their consent at any time. Users have the right to withdraw consent where they have
previously given their consent to the processing of their Personal Data.
Object to processing of their Data. Users have the right to object to the processing of their Data if the
processing is carried out on a legal basis other than consent. Further details are provided in the
dedicated section below.
Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain
disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing
Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to
be updated or corrected.
Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the
processing of their Data. In this case, the Owner will not process their Data for any purpose other than
Have their Personal Data deleted or otherwise removed. Users have the right, under certain
circumstances, to obtain the erasure of their Data from the Owner.
Receive their Data and have it transferred to another controller. Users have the right to receive
their Data in a structured, commonly used and machine readable format and, if technically feasible, to
have it transmitted to another controller without any hindrance. This provision is applicable provided
that the Data is processed by automated means and that the processing is based on the User’s consent,
on a contract which the User is part of or on pre-contractual obligations thereof.
Lodge a complaint. Users have the right to bring a claim before their competent data protection
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the
Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such
processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they
can object to that processing at any time without providing any justification. To learn, whether the Owner is
processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this
document. These requests can be exercised free of charge and will be addressed by the Owner as early as
possible and always within one month.
Additional information about Data collection and processing
The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to
possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public
Additional information about User’s Personal Data
additional and contextual information concerning particular Services or the collection and processing of
Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, this Application and any third-party services may collect files that
record interaction with this Application (System logs) use other Personal Data (such as the IP Address) for
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at
any time. Please see the contact information at the beginning of this document.
How “Do Not Track” requests are handled
This Application does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read
their privacy policies.
on this page and possibly within this Application and/or – as far as technically and legally feasible – sending a
notice to Users via any contact information available to the Owner. It is strongly recommended to check this
page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall
collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal
identification number — allows for the identification or identifiability of a natural person.
Information collected automatically through this Application (or third-party services employed in this
Application), which can include: the IP addresses or domain names of the computers utilized by the Users
who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the
method utilized to submit the request to the server, the size of the file received in response, the numerical
code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the
features of the browser and the operating system utilized by the User, the various time details per visit (e.g.,
the time spent on each page within the Application) and the details about the path followed within the
Application with special reference to the sequence of pages visited, and other parameters about the device
operating system and/or the User’s IT environment.
The individual using this Application who, unless otherwise specified, coincides with the Data Subject.
The natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others,
determines the purposes and means of the processing of Personal Data, including the security measures
concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the
Owner of this Application.
The means by which the Personal Data of the User is collected and processed.
The service provided by this Application as described in the relative terms (if available) and on this
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all
current member states to the European Union and the European Economic Area.
Small sets of data stored in the User’s device.
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of
Regulation (EU) 2016/679 (General Data Protection Regulation).
Latest update: May 14, 2018