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Podcast and interview editing · London

business@krokomontage.com

Kroko Montage Limited

Privacy Policy

Set out as a transcript, because most of what follows is a conversation between the two of us with the law sitting in. Who is speaking is on the left.

Who is speaking

Kroko Montage
Kroko Montage Limited, registered in England and Wales, company number 17457883, registered office 167-169 Great Portland Street, London, England, W1W 5PF. Written to at business@krokomontage.com.
You
Whoever is arranging for a recording to be edited, whether for yourself or for the organisation you work for.

Who is answerable for it

Kroko Montage

Kroko Montage Limited decides what happens to the information described on this page, which makes us the controller of it under the UK General Data Protection Regulation. Our company number is 17457883 and our registered office is 167-169 Great Portland Street, London, England, W1W 5PF.

Anything on this page can be asked about, argued with or acted on by writing to business@krokomontage.com. There is no separate privacy address to find: it is the same one the rest of the site uses.

What we end up holding

Kroko Montage

Four things, and they arrive in four different ways.

What you write to us
Your name, the address we reply to, the name of your show if you give it, and whatever you put in the body of the message. If you used the form on the Contact page, that is the text the form assembled out of your answers.
What you send us to work on
The recordings, the music and stings you supply, and any notes and instructions that come with them. These are dealt with separately below, because they are not ordinary business correspondence.
The record of an order
Quotations, order confirmations, invoices, receipts and the emails around them. Where an order is for a company, that includes the billing details of that company.
What the hosting writes down
Like any web server, the one serving these pages records requests: the address a request came from, the time, the page asked for and the browser that asked. Those records are the hosting provider's, are kept for a short period for security and for keeping the site running, and are not joined up with anything else on this list.

Kroko Montage

One of those four never reaches us at all unless you send it. What you type into the form on the Contact page does not travel anywhere on its own: there is nothing behind this site to receive it. The form assembles a piece of text, hands it to your own email program, and the text leaves your machine only when you press send there.

What it is used for

Kroko Montage

  • Answering what you asked, and asking what we still need to know.
  • Listening to the material so a quotation can be written for your recording.
  • Doing the work, and coming back to you about it.
  • Invoicing, taking payment, and keeping the accounting records the law requires.
  • Dealing with a complaint, a cancellation or a refund if one comes up.
  • Keeping the website itself working and not being attacked.

It is not used for anything else. We do not send marketing, we do not build a profile of you, and we do not sell, rent or pass on lists of people who have written to us.

What allows us to hold it

UK GDPR, Article 6

Processing has to rest on one of the grounds the Article sets out.

Kroko Montage

Three of them are what we rely on, and each one covers a different part of the work.

Article 6(1)(b)
The contract, and the steps taken before it. Quoting for your recording, agreeing the work, doing it and handing it over all sit here.
Article 6(1)(f)
Legitimate interests, where the interest is a real one and is named rather than implied: keeping the website secure and available, keeping a record of what was agreed in case it is disputed later, and being able to answer someone who writes to us without an order behind it. We have weighed each of those against what a reader would reasonably expect, and none of them involves doing anything with your information that you have not been told about on this page.
Article 6(1)(c)
Legal obligation. Invoices, receipts and the records behind them are kept because tax and company law require them to be, for as long as they require it.

Your recordings in particular

Kroko Montage

A recording is not the same as a line in an address book. It is somebody's voice, usually more than one person's, and quite often it contains things that were said before anybody decided what would be published.

So the rules we apply to recordings are tighter than the ones for correspondence.

  • They are used for your order and for nothing else.
  • They are not published, not shown to anybody, and not used as an example of our work. If we ever wanted to use a piece of one for that, we would ask you in writing first, and a refusal would cost you nothing.
  • The parts you tell us to cut are cut, and the cut material is not kept once the order closes.
  • They are removed on the schedule below, rather than sitting in a folder indefinitely because nobody thought to look.

Kroko Montage

Where a recording has other people on it, you are the one who arranged for it to be made and you are the one who decides it will be published. We are working on it for you, which in the language of the regulation makes you the controller of that material and us the processor of it. If somebody on a recording asks us directly about it, we will tell them to speak to you, and tell you that they asked.

Who else handles it

Kroko Montage

As few as the work allows, and each of them for one reason. None of them is allowed to use it for anything of their own.

The hosting provider
Serves these pages and keeps the request logs described above. The provider is named in the trading details we give on request.
The email provider
Carries the correspondence between us, as an email provider does for both of us.
Payment providers
Stripe and PayPal, where an invoice is paid through them. They take the card or account details on their own pages and hold them under their own terms. We never see a card number and never hold one.
Storage you chose
Where you send files on a link from your own storage, that service is yours rather than ours, and what it does with the files is governed by your arrangement with it.
An accountant
Sees the invoices and the records behind them, to prepare and file accounts.

We are also obliged to hand something over where a court, HMRC or another authority has the power to require it. That has to be a real requirement, not a request, and we do not treat it as one otherwise.

Whether any of it leaves the United Kingdom

Kroko Montage

Some of it does. Payment providers and, depending on the service, email and hosting providers, operate outside the United Kingdom or hold data there.

Where that happens, the transfer is made on a footing UK law allows: either the country has been found adequate by the United Kingdom, or the contract with the provider carries the International Data Transfer Agreement or the UK Addendum to the European Commission's standard contractual clauses. We do not use a provider that has neither, and we can tell you which applies to a given one if you ask.

How long it is kept

Kroko Montage

An enquiry that did not become an order
Kept for one year, then deleted, so that a returning enquiry has some context to it.
Your source files and the working session
Kept while the order is open and through the period for changes stated in the quotation, then deleted. Ask for them to go sooner and they go, once the order is closed.
The finished files
Kept for a short period after handover so a lost download can be reissued, then deleted. The master is yours, and keeping your own copy is not something to leave to us.
Correspondence about an order
Kept for six years from the end of the order, which is the period a contract claim can be brought in.
Invoices, receipts and accounting records
Kept for six years from the end of the accounting period they fall in, because tax law requires it.
Hosting request logs
Kept by the hosting provider for a short period for security, then rotated away.

What you can ask us to do

UK GDPR

A person whose data is held has rights over it, and a controller has to act on them within a month. Those rights are to:

  • be told what is held and be given a copy of it;
  • have what is wrong corrected, or what is half a picture completed;
  • have it erased, where the controller has no continuing reason to hold it;
  • have its use restricted while something about it is being sorted out;
  • object to its use under legitimate interests, in which case the controller stops unless it can show grounds that outweigh the objection;
  • have what the person supplied handed to them, or to somebody else, in a form a machine can read;
  • withdraw a consent, at any time, without that affecting anything done before it was withdrawn.

You

I want to see what you hold about me, or I want it corrected, erased or handed over.

Kroko Montage

Write to business@krokomontage.com and say which one. None of them costs anything, and asking for one is never treated as a reason to deal with you differently. If a request would mean deleting something we are obliged to keep, we will say which record and which obligation rather than refusing in general terms.

If you are not satisfied

Kroko Montage

Tell us first, at business@krokomontage.com, and we will look at it and answer in writing. It is the shortest route to an answer, because we are the only people who can look at what is actually held.

The Information Commissioner

You do not have to go to the company first, and you can complain to us whether or not you have.

Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Guidance and the complaints route are at ico.org.uk.

Whether you have to give us any of it

Kroko Montage

There is no statutory obligation to give us anything, and nothing here is a condition of using the website: you can read every page of it without telling us who you are.

What is required is required by the work rather than by law. Without an address to answer we cannot answer; without the recording we cannot quote for editing it; without billing details we cannot invoice. If you would rather not give something, say so and we will tell you whether the order can go ahead without it.

Decisions made by machine

Kroko Montage

There are none. Nothing here is decided automatically, nothing is scored, and no profile of you is built. A person listens to the material and a person writes the quotation, which is also why quoting takes as long as it does.

Cookies and browser storage

Kroko Montage

This website sets no cookies. It puts nothing in local storage, nothing in session storage and nothing in a browser database. There is no analytics, no tag manager, no advertising and no third-party script of any kind on these pages, and no consent banner either, because there is nothing to ask consent for.

The fonts and the images are served from this site rather than from somebody else's, so reading a page here does not tell anybody else that you did. The only thing written down when you visit is the request log described above, which the hosting keeps in order to serve the page at all.

PECR, regulation 6

Consent is needed for storing or gaining access to information on a user's device, except where it is strictly necessary for a service the user has asked for.

Kroko Montage

Nothing here is stored on your device, so the question does not arise and there is nothing for a banner to ask you about.

When this page changes

Kroko Montage

The date at the foot of this page is the day it last changed. Where a change affects what happens to information we already hold about you, we write and tell you rather than expecting you to notice a new date.