Character Cube / Privacy Notice

1     Who I am

I am Kenneth Anderson, a sole trader operating under the trading name "Character Cube".

I am a controller for the purposes of the General Data Protection Regulation (Regulation (EU) 2016/679) and related data protection legislation.

2     How to contact me

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact me at

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues ( I would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact me in the first instance.

2     Privacy Information

I am committed to protecting your personal data and your privacy. This privacy notice aims to give you information on how I collect and process your personal data:

It is important that you read this privacy notice so you are fully aware of how and why I am using your personal data.

It is important that the personal data I hold about you is accurate and current. Please keep me informed if your personal data changes during our relationship.

This version of my privacy notice was last updated on 30.10.19.

4     To whom does this privacy notice apply?

This privacy notice applies to all individuals who visit the Website, or who contact me by post, telephone, e-mail or other means (including other electronic means), who have a contract in place with me (please note that separate terms and conditions may also be applicable here) or who have some other form of business relationship with me.

5     Information about the Website

The Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. I do not control these third-party websites and I am not responsible for their privacy statements. When you leave the Website, I encourage you to read the privacy notice of every website you visit.

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Website may become inaccessible or not function properly.

6     Children

The Website is not intended for children and I do not knowingly collect any personal data relating to children.

7     What personal data do I collect and process?

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

I may collect, use, store and transfer different kinds of personal data about you which I have grouped together as follows:

I do not collect any "special categories of personal data" about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do I collect any information about criminal convictions and offences.

8     How is your personal data obtained?

I use different methods to collect personal data from and about you including through:

9     Failure to provide personal data

Where I need to collect personal data by law, or under the terms of a contract I have with you and you fail to provide that data when requested, I may not be able to perform the contract I have or are trying to enter into with you (for example, to provide you with services). In this case, I may have to cancel a service you wish me to provide but I will notify you if this is the case at the time.

10     How will I use your personal data?

I will process your personal data where you consent to the processing or where that processing is necessary for 1) the performance of a contract with you; or 2) compliance with a legal obligation to which I am subject; or 3) the purposes of my legitimate interests (or those of a third party).

I have set out below, in a table format, a description of all the ways I plan to use your personal data, and which of the legal bases I rely on to do so. I have also identified what my legitimate interests are where appropriate.

Note that I may process your personal data for more than one lawful ground depending on the specific purpose for which I am using your personal data. Please contact me at if you need details about the specific legal ground I am relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To process and deliver services to you including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to me
(c) Deal with any client complaints
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for my legitimate interests (to recover debts due to me and to manage client relationships)
(c) Necessary to comply with a legal obligation
To manage my relationship with you
(a) Identity
(b) Contact
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for my legitimate interests (to manage third party relationships)
To administer and protect my business and the Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for my legitimate interests (for running my business, provision of administration and IT services, network security)
(b) Necessary to comply with a legal obligation
To use data analytics to improve the Website, marketing, client relationships and experiences
(a) Technical
(b) Usage
Necessary for my legitimate interests (to keep the Website updated and relevant, to develop my business and to inform my marketing strategy)
To establish, exercise and defend my legal rights
All data
Necessary for my legitimate interests (in protecting my legal rights)

I will only use your personal data for the purposes for which I collected it, unless I reasonably consider that I need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact me at

If I need to use your personal data for an unrelated purpose, I will notify you and I will explain the legal basis which allows me to do so.

11     Marketing

If you are a consumer, I will only provide you with direct marketing communications where you have consented to receive such communications. You can subscribe to such marketing communications, and you can adjust your marketing preferences at any time by contacting me at

You can also opt-out or unsubscribe from all or some of these marketing communications at any time by contacting me at or by clicking “unsubscribe” at the bottom of any marketing e-mail.

Where you opt out of receiving these marketing communications, this opt-out will not apply to personal data provided to me for any other purpose.

12     With whom do I share your personal data?

I may have to share your personal data with the parties set out below for the purposes set out in the table above.

I require all third parties to respect the security of your personal data and to treat it in accordance with the law. I do not allow my third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with my instructions.

Any sharing of your personal data will only take place either where I am legally obliged to do so, where it is necessary for the performance of a contract with you or where it is in my legitimate interests to do so, including as follows:

13     International transfers

I generally do not transfer your personal data out of the European Economic Area (EEA). However, whenever I am required to transfer your personal data out of the EEA (for example where a third party supplier is located outside of the EEA), I ensure a similar degree of protection is afforded to it by ensuring that appropriate safeguards are implemented, including any of the following:

14     Automated decision making and profiling

I do not use automated decision-making (including profiling) to make any decisions which would produce a legal effect or similarly significantly affect a data subject.

15     How long do I retain your personal data?

I will only retain your personal data for as long as necessary to fulfil the purposes I collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, I consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which I process your personal data and whether I can achieve those purposes through other means, and the applicable legal requirements.

For tax purposes, I retain basic information about my clients (including Contact, Identity, Financial and Transaction Data) for six years after they cease being clients.

16     Data security

I have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, I limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on my instructions and they are subject to a duty of confidentiality.

I have put in place procedures to deal with any suspected personal data breach and will notify you and the Information Commissioner's Office of a breach where I am legally required to do so.

17     Your rights

17.1 - Your personal data is protected by legal rights, which include your rights to:

17.2 - If you wish to exercise any of these rights, please contact me at

17.3 - I may need to request specific information from you to help me confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. I may also contact you to ask you for further information in relation to your request to speed up my response.

17.4 - You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, I may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, I may refuse to comply with your request in these circumstances.

17.5 - I try to respond to all legitimate requests within one month. Occasionally it may take longer than a month if your request is particularly complex or you have made a number of requests. In this case, I will notify you and keep you updated.

17.6 - 17.6 You also have the right to complain to the Information Commissioner's Office, which regulates the processing of personal data, about how I am processing your personal data.

Character Cube / last updated 30.10.2019 / Return to main site