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Asking for consent ? We have checked that consent is the most appropriate lawful basis for processing. ? We have made the request for consent prominent and separate from our terms and conditions. ? We ask people to positively opt in. ? We don’t use pre-ticked boxes or any other type of default consent. ? We use clear, plain language that is easy to understand. ? We specify why we want the data and what we’re going to do with it. ? We give separate distinct (‘granular’) options to consent separately to different purposes and types of processing. ? We name our organization and any third party controllers who will be relying on the consent. ? We tell individuals they can withdraw their consent. ? We ensure that individuals can refuse to consent without detriment. ? We avoid making consent a precondition of a service. ? If we offer online services directly to children, we only seek consent if we have age-verification measures (and parental-consent measures for younger children) in place. Recording consent ? We keep a record of when and how we got consent from the individual. ? We keep a record of exactly what they were told at the time. Managing consent ? We regularly review consents to check that the relationship, the processing and the purposes have not changed. ? We have processes in place to refresh consent at appropriate intervals, including any parental consents. ? We consider using privacy dashboards or other preference-management tools as a matter of good practice. ? We make it easy for individuals to withdraw their consent at any time, and publicize how to do so. ? We act on withdrawals of consent as soon as we can. ? We don’t penalize individuals who wish to withdraw consent.
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