Privacy

Privacy Policy and Cookie Statement

Introduction

Spike Diamond Ltd is a private limited company with company number 12120023 and registered office address at Winnington House, 2 Woodberry Grove, London, United Kingdom, N12 0DR.

Personal data is information about individuals or information from which individuals can be identified (personal data).

We are a controller of your personal data under data protection legislation which means that we are responsible for how the personal data we hold about you is processed. We are registered with the Information Commissioner’s Office (ICO) as a controller and our ICO registration number is ZA831249.

Who do we collect personal data about?

This privacy notice mainly sets out how we will process your personal data when you use this website as a visitor (so whether you are simply visiting the website or if you have signed up for any of the features of the website that may require us to collect more information about you, for example, your email address).

We may also collect your personal data if you are an artist and/or contributor in any of the videos and/or other content we publish on our website, for example, if you are an individual who interviewed with a member of our team and their interviews is being featured on our website.

How do we collect personal data?

We collect personal data directly from you when you contact us and when you use our website, including when you provide it to us in the process of subscribing to our monthly online newsletter and taking part in our competitions to win prizes, and when you register and create a profile on the website.

We may also collect your personal data through Facebook, Instagram, and Twitter when you use tools to tag us and mention us in your posts, statuses and comments through your accounts on these platforms, when you click on the icons for Facebook, Instagram and Twitter on our website and are led to our accounts on these platforms, and when you provide us with your personal data on our accounts on these platforms, e.g. when you comment on one of our posts on Facebook.

We may also receive anonymised data that was derived from your personal data from YouTube when you play one of our YouTube videos embedded on our website.

We may also receive your personal data from other third parties, for example, service providers or partner organisations we use from time to time such as Amazon (our cloud computing platform service provider), OneTrust (our cookie consent management platform), Google (our analytics and search optimisation service provider) and any marketing service provider used from time to time.

We may also receive personal data from organisations who will be acting as sponsors and you will be able to interact with, via our website.

What personal data do we collect?

We will collect your email address when you subscribe to receive our newsletter and ask to take part in our competitions. We will also collect any account related information, for example, your username and password for your account on our website. When you win a competition, we may ask for your address to send you the relevant prize(s).

We may also receive personal data relating to your use of our website, for example, your IP address, user ID, usage data, device and browser type and identifiers, software and system information, and preferences for video features.

We may collect any personal data you provide to us, for example, any opinions, that you may provide as part of any communication you send us.

How do we use your personal data?

The following is a list of the purposes for which we process your personal data, and the lawful bases on which we carry out the processing:

To set-up, administer and manage your account with us

  • Lawful basis: Necessary for the performance of our contract with you

To send you our newsletters

  • Lawful basis: Your consent

To deliver marketing materials to you

  • Lawful basis: Our legitimate interests in promoting our offerings

To seek your views on our services

  • Lawful basis: Your consent

To allow you to take part in competitions and to send you a prize when you win a competition

  • Lawful basis: Your consent

To respond to communications, including customer support queries

  • Lawful basis: Your consent

To record and analyse customer communications for training purposes

  • Lawful basis: Our legitimate interests in improving our customer service

To send you service messages and updates about our website

  • Lawful basis: Necessary for the performance of our contract with you

To prepare and analyse statistics relating to the use of our website and services by you and other users, to investigate complaints and to seek and analyse feedback

  • Lawful basis: Our legitimate interests in ensuring our services and website are as enjoyable as possible

To run our everyday operations, e.g. communications between employees in connection with the provision of our services

  • Lawful basis: Our legitimate interests in running our business

To administer and protect our business and the website including troubleshooting, data analysis and system testing

  • Lawful basis: Our legitimate interests in running our business, including receiving/administrating IT services, including network security

To administer a sale or possible sale of the whole of or part of our business or the restructuring of our business

  • Lawful basis: Our legitimate interests in facilitating any such possible or actual transaction or restructuring

To consider any job applications we may receive

  • Lawful basis: Your consent

We may also process your personal data (a) to comply with a legal obligation we are under; and (b) for additional purposes in the future, but only if such purposes are compatible with those listed above and if we believe that the same lawful basis applies.

In certain circumstances, you may be obliged to provide us with your personal data under a statutory or contractual requirement. This might include, but is not limited to, personal data we require to enter into an agreement with you or your business; for tax and accounting purposes; and to enable us to fulfil our compliance and other obligations under relevant legislation or regulation. Failure to provide us with personal data required under a statutory or contractual requirement may prevent us from entering into or performing our obligations under a contract with you or your business.

Your communications preferences

We would love to stay in touch with you, but we completely understand if you do not want to receive communications from us via email. We always offer an unsubscribe option at the bottom of every email you receive from us and you are welcome to use it to change your email preferences.

If you unsubscribe from our communications, we will maintain a record of your unsubscribe request and associate it with your email address to ensure you do not receive future communications.

When do we disclose your personal data?

We may share your personal data with third parties. Some of these third parties may be based, or may process data in, the EEA. When we transfer personal data to third parties within the EEA, we currently do so on the basis of Article 28, General Data Protection Regulation ((EU) 2016/679) (GDPR) compliant terms. We may also share your personal data with third parties that process data in and/or are incorporated in territories outside of the UK and/or the EEA and which do not provide the same level of protection to personal data as countries subject to the GDPR (international partners).

Until such time as the Brexit transition period expires on 31 December 2020 no additional safeguards are required for the transfer of personal data between the UK and the EEA.

For such time as UK data controllers continue to remain subject to the GDPR, we will disclose your personal data to international partners only as permitted under the GDPR, which will generally be on the basis of appropriate safeguards approved under the GDPR (https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/international-transfers/), including standard contractual clauses approved by the European Commission which can be found at: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en. After the decision of the CJEU in the Schrems II case, in which the CJEU found that the US/EU Privacy Shield does not afford sufficient protection for personal data when transferred to the US, we have been monitoring the instances in which personal data is transferred to the US to establish whether any such transfer presents a significant risk to your rights and freedoms even when done under the relevant standard contractual clauses. If it does, we commit to making necessary changes.

To the extent that there are different or additional appropriate safeguards required for the transfer of personal data outside the UK following the end of the Brexit transition period, we will ensure those are put in place.

We may also share your personal data with the following third parties in the following capacities:

  • Amazon (our cloud computing platform service provider)
  • OneTrust (our cookie consent management platform)
  • Google (our analytics and search optimisation service provider)
  • any marketing, or other service provider or partner organization, engaged from time to time.

Your personal data may be shared with other parties and/or on our social media accounts for the purposes and the legitimate interests of facilitating our operations and promoting our offerings including on Facebook, Instagram, and Twitter, for example when we share a post that you commented on, or when you click on one of the icons for these platforms on our website. Your personal data will also be shared with YouTube when you play one of our YouTube videos embedded on our website.

We may also transfer your personal data to international partners or other third parties in the context of a sale or possible sale of the whole of or part of our business or the restructuring of our business.

We may also disclose your personal data to law enforcement agencies in order to assist with any investigations, when we bring a claim or defend ourselves against a claim that requires the disclosure of the personal data, and when we engage professional advisors.

How long do we keep your personal data for?

We will retain your personal data for the following purposes and retention periods.

User profile

  • Retention period: The period of time during which a user profile is live and up to 7 years after it is deactivated

Subscription

  • Retention period: Until you unsubscribe or after 3 years

Future employment opportunities with us when a job application has been unsuccessful

  • Retention period: Up to 2 years

Information regarding contracts and/or other interactions with us that we may be used to bring and/or defend Spike Diamond Ltd in legal claims

  • Retention period: Up to 7 years after the end of a matter/interaction with us

Your rights

You have the following rights under data protection legislation. If you have any questions about your rights, or you wish to exercise any of these rights, please email compliance@holler.country

We may require you to provide forms of identity should you wish to exercise one of your rights below.

Access: Upon request, you are entitled to confirmation that we process your personal data and to a copy of such personal data.

Rectification: If the personal data we hold on you is incorrect, you have the right for it to be rectified. You may also update your personal data through your account settings.

Erasure: You can request us to erase your personal data where there is no compelling reason for us to continue processing it, and in certain other circumstances.

Restriction: You may request a restriction on the processing we undertake on your personal data.This right will only apply where we no longer have a lawful basis on which to process your personal data, or if your personal data is inaccurate, or you object to our processing and in such cases there is a reason for us to continue holding the data.

Objection: You may object to our processing of your personal data if our processing is carried out on the basis of our legitimate interests. Please note, however, that should we determine that our interests are so compelling as to override your objection we may continue to process your personal data.

You may object to receiving direct marketing at any time.

Portability: You may have the right to receive some of your personal data in machine readable format.This right extends to you being able to request that such data is sent to a third-party controller.

Withdrawing consent: If the lawful basis we rely on to process your personal data is consent you have the right to withdraw this consent. Please email us at compliance@holler.countryto withdraw consent for the processing of your personal data.

To withdraw your consent for the processing of your personal data by a third party, please contact the relevant organisation.

Complaining to a supervisory authority: Further information about your rights can also be obtained from your national data protection regulator – in the UK, this is the ICO (https://ico.org.uk/). If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with your national data protection supervisory authority, although we would ask that you contact us in the first instance.

Your right to be informed: You can contact us to find out more or to ask any questions you may have about our use of your personal data.

Website cookies and trackers

We use cookies and similar technologies on this website (cookies). A "cookie" is a small file of text which is downloaded onto your computer or device when you access this website, and it allows us to recognise when you return to the website.

We will obtain your consent to use these cookies except where the use of the cookie is strictly necessary for the operation of our website.

The cookies used on our website are either set by us or by our third party service providersi.e. by domain providers (other than the provider of our website domain) that provide us with external services, such as analytics providers, and they fall into the following categories:

  • Necessary: Those that are necessary for the operation of the website, including those that allow you to interact with our website, that register your consent or opt-out of non-essential cookies, those that allow you to stay logged in to your account, and to enable core functionality such as security, network management and accessibility.
  • Functional: Those that enable you to use non-essential features on our website, such as to remember your username and to play YouTube videos embedded on our website.
  • Analytics:Those that analyse the use of our website by visitors, and monitor our web audience and traffic.
  • Advertising: Those that allow you to view advertisements on our website.

We use a combination of both session and persistent cookies. Session cookies keep track of your current visit and how you navigate the website and persistent cookies enable our website to recognise you as a repeat visitor when you return. The session cookies will be deleted from your device when you close your browser. Persistent cookies remain on your device after you have left the website.

Most browsers have cookies enabled by default, but you are able to change your cookies settings, which are usually found in the 'options' or 'preferences' menu of your internet browser. You can block any cookies from any website by activating the setting on your browser that allows you to refuse the setting of some or all cookies.You can also use your browser settings to delete cookies. For more information about cookies please visit https://ico.org.uk/your-data-matters/online/cookies/ .

Cookie List

A cookie is a small piece of data (text file) that a website – when visited by a user – asks your browser to store on your device in order to remember information about you, such as your language preference or login information. Those cookies are set by us and called first-party cookies. We also use third-party cookies – which are cookies from a domain different than the domain of the website you are visiting – for our advertising and marketing efforts. More specifically, we use cookies and other tracking technologies for the following purposes:

Social Media Cookies

These cookies are set by a range of social media services that we have added to the site to enable you to share our content with your friends and networks. They are capable of tracking your browser across other sites and building up a profile of your interests. This may impact the content and messages you see on other websites you visit. If you do not allow these cookies you may not be able to use or see these sharing tools.

Social Media Cookies

Cookie Subgroup: tiktok.com

  • Cookies: tt_webid, tt_csrf_token, tt_webid_v2
  • Cookies used: 3rd Party

Functional Cookies

These cookies enable the website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.

Functional Cookies

Cookie Subgroup: holler.country

Cookie Subgroup: spotify.com

  • Cookies: _ga, _gid, sp_t, sp_landing, _gat_gtag_xxxxxxxxxxxxxxxxxxxxxxxxxxx
  • Cookies used: 3rd Party

Strictly Necessary Cookies

These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.

Strictly Necessary Cookies

Cookie Subgroup: holler.country

Cookie Subgroup: cookielaw.org

  • Cookies: __cfduid
  • Cookies used: 3rd Party

Cookie Subgroup: onetrust.com

  • Cookies: __cfduid
  • Cookies used: 3rd Party

Performance Cookies

These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.

Performance Cookies

Cookie Subgroup: holler.country

  • Cookies: _ga
  • Cookies used: 1st Party

Targeting Cookies

These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

Targeting Cookies

Cookie Subgroup: youtube.com

  • Cookies: GPS, VISITOR_INFO1_LIVE, YSC
  • Cookies used: 3rd Party

Cookie Subgroup: doubleclick.net

  • Cookies: test_cookie
  • Cookies used: 3rd Party

Store and/or access information on a device

Cookies, device identifiers, or other information can be stored or accessed on your device for the purposes presented to you.

Personalised ads and content, ad and content measurement, audience insights and product development

Ads and content can be personalised based on a profile. More data can be added to better personalise ads and content. Ad and content performance can be measured. Insights about audiences who saw the ads and content can be derived. Data can be used to build or improve user experience, systems and software.

  • Select basic ads

Ads can be shown to you based on the content you’re viewing, the app you’re using, your approximate location, or your device type.

  • Create a personalised ads profile

A profile can be built about you and your interests to show you personalised ads that are relevant to you.

  • Select personalised ads

Personalised ads can be shown to you based on a profile about you.

  • Create a personalised content profile

A profile can be built about you and your interests to show you personalised content that is relevant to you.

  • Select personalised content

Personalised content can be shown to you based on a profile about you.

  • Measure ad performance

The performance and effectiveness of ads that you see or interact with can be measured.

  • Measure content performance

The performance and effectiveness of content that you see or interact with can be measured.

  • Apply market research to generate audience insights

Market research can be used to learn more about the audiences who visit sites/apps and view ads.

  • Develop and improve products

Your data can be used to improve existing systems and software, and to develop new products

Use precise geolocation data

Your precise geolocation data can be used in support of one or more purposes. This means your location can be accurate to within several meters.

Actively scan device characteristics for identification

Your device can be identified based on a scan of your device's unique combination of characteristics.

Ensure security, prevent fraud, and debug

Your data can be used to monitor for and prevent fraudulent activity, and ensure systems and processes work properly and securely.

Technically deliver ads or content

Your device can receive and send information that allows you to see and interact with ads and content.

Match and combine offline data sources

Data from offline data sources can be combined with your online activity in support of one or more purposes

Link different devices

Different devices can be determined as belonging to you or your household in support of one or more of purposes.

Receive and use automatically-sent device characteristics for identification

Your device might be distinguished from other devices based on information it automatically sends, such as IP address or browser type.

We keep this privacy notice under regular review.

This privacy notice was last updated on February 17, 2021.