Privacy Policy

Last updated on 5 July 2023.

Off-Centre Productions Limited, a company registered in England and Wales under company number 07355966 (“us”, “our”, “we”, “Off-Centre Productions”) is the controller of your personal information collected through Iranwire.com (the “Website”). Off-Centre Productions is committed to protecting and respecting your privacy.

This privacy policy (the “Policy”), sets out what information is collected from you and for what purpose when you visit the Website and how we may use that data.

1. Introduction

This Policy explains who we are, why and how we process personal information collected through your use of the Website and, if you are the subject of any of the personal information concerned, what rights you have and how to get in touch with us if you need to.

When you give us permission to use your personal information, we have legal responsibilities to you to make it clear to you how we use this information. To make the text easier to read, this Policy is divided into the following sections:

Introduction
What is personal information and what information we collect
Special Category Data
How your personal information is collected
Why and how we use your information or share it with others
How long your information will stay with us
Security
International data transfers
Your rights
How to contact us.

It is important that you read this Policy, along with any other related policies or texts we have published (such as privacy notices or fair processing notices which we may display to you at the time you sign up to receive e-mail updates from us), so that you fully understand what information is collected from you when you use our Website.

This Policy complements our "Cookie Policy" and our “Terms of Use” and is not intended to override or replace them.

By visiting or otherwise using our Website, you agree to the terms of this Policy (including as amended from time to time). If for any reason you do not agree with the terms of this Policy, please stop using our Website.

We reserve the right to revise or amend this Policy at any time in the future to reflect changes to our business or changes in the law. Where these changes are significant, we will endeavour to inform the users about the updated version. However, it is your responsibility to check this Policy each time before using the Website in order to be aware of any possible changes. For your convenience, the date of the last update is included in the upper right corner of this Policy.

Please note that our Website is not intended for use by children under the age of 13 and we do not knowingly collect information from children. If you believe that your child's information is stored on our Website, you can contact us by email at [email protected] and request that your child's information be deleted.

2. What is personal information and what information we collect

What is personal information?

When personal information is mentioned in this Policy, it means information from which you could be identified, such as your name, date of birth, contact information and even your virtual address (IP Address).

By law, all institutions that collect your personal information are required to process your personal information in certain ways and fully inform you of how your information is used and why it is collected. You also have various rights and you can ask such institutions to share with you the way and reason for collecting your personal information and prevent institutions from processing your personal information unlawfully. For more information about these rights, please refer to the "Your Rights" section below.

Types of information collected from you when you visit the Website

The personal information we collect from you may include:

Identity Data which includes your name, date of birth and gender.
Contact Data which includes your e-mail address, billing address and delivery address.
Financial Data which includes your bank account and payment card details.
Transaction Data which includes details about donations and payments to and from you and other details or services you have purchased from us.
Technical Data which includes your IP address, your login data and browser type and version.
Account Data which includes your username and password, your interests, preferences, feedback and survey responses.
Usage Data which includes information about how you use the Website.
Marketing and Communications Data which includes your preferences in receiving marketing from us and our associated third parties.

3. Special Category Data

We may collect the following special categories of personal information about you:

Race
Ethnic origin
Religious or philosophical beliefs.

When processing special categories of personal information, we are obliged to have an additional lawful basis for processing this data. These are set out in the table in section 5 below - ‘Why and how we use your information or share it with others’.

4. How your personal information is collected

Voluntary transfer of information

In cases such as, but not limited to, the following, you voluntarily share your information with us:

When visiting the Website and filling out the "follow us" or "contact us" forms and uploading or downloading from the Website.
When you register for an account.
When you submit a legal question to our consultant.
When you subscribe to our newsletters.
When you follow us on social media or refer to our Website or pages from your personal page.
When communicating with us via online mail, phone, email, text message, and other similar communication methods.

In these cases, we may collect, store and use information that you have voluntarily shared with us.

Automatic collection of information

We may also collect some of your personal information when you use the Website, automatically and using technologies such as cookies. The following are examples of information collected in this category:

Information about your device (computer, phone, laptop, etc.), browser (Chrome, Safari, Mozilla, etc.) and operating system (Windows, Android, Mac, etc.).
Your virtual address.
Information about links you click and pages you visit.
The amount of time you spend on certain pages.
Topics you visit or search for.
Technical quality of the page when visiting.
Download information or uploads that have encountered problems or have invalid links.
How you interact with the page (number of mouse clicks, scrolling, etc.).
Methods used by users to enter the Website.
Complete list of links to and from this Website.

We use this information in various ways. We use such information to guarantee the correct and accurate functioning of the Website to provide you with the best service. We also use this information to monitor the Website's online performance and audience engagement. We undertake these activities because we have a legitimate interest in doing so.

Third-party sources

We also use the services of third-party companies in collecting your personal information, which enable us to have a better understanding of your interests. We do this so that we can bring you the most relevant content according to your interests on the Website and also so that we can show you the most relevant advertisements of other companies that may be of interest to you on the Website.

When we use cookies for this purpose, we inform you in advance that cookies need your permission to start working and that you can refuse to allow them to work. You can also delete the cookies on your computer at any time.

For more details about the cookies we use on the Website and how they work, as well as the privacy policy of third parties that have cookies on our Website, please refer to our Cookie Policy.

Please remember that although you can disable some cookies, with the exception of those cookies specified in the Cookie Policy, rejecting those cookies may mean the full functionality of the Website is not available and may have a detrimental impact on your experience of the Website.

Updating your information

If you want to update the information you have previously given to us you can contact us at [email protected].

5. Why and how we use your information or share it with others

Lawful basis for processing your information

We will only use your personal information when the law allows us to. Most commonly we will use your personal information in the following circumstances:

Where you have asked us to do so, or consented to us doing so (although consent is not necessarily required for us to process your personal information);
Where we need to do so in order to perform a contract we have entered into with you;
Where it is necessary for our legitimate interests (or those of a third party) and your fundamental rights do not override those interests; and
Where we need to comply with a legal or regulatory obligation.

Here are some examples about how we may use the information we collect about you and the lawful basis we rely on to do so.

Activity	Examples of the types of personal information we may collect	Lawful basis for processing
To make the Website available for you to visit and to deliver the content on the Website to you.	Usage information	We have a legitimate interest in doing so.
To allow you to interact with the Website, including filling out the "follow us" or "contact us" forms and uploading or downloading from the Website.	Usage, identity, contact information and marketing and communications preferences.	You have consented to us doing so.
To allow you to create an account with us.	Usage, identity, account and contact information	Performance of a contract with you.
To allow you to subscribe to our newsletters.	Identity and Contact information, and marketing and communications preferences.	You have consented to us doing so.
To allow you to donate to us.	Identity, usage, financial and contact information.	Performance of a contract with you.
To manage our relationship with you including notifying you of any changes to the Website or services provided on the Website.	Identity, contact, profile and marketing communications information.	Performance of a contract with you.
To administer and protect our business and this Website (including troubleshooting, data analysis and system testing.)	Identity, contact and technical information.	We have a legitimate interest in doing so.
To deliver relevant Website content and advertisements to you.	Identity, contact, profile, usage, marketing and communications and technical information.	We have a legitimate interest in doing so.
To use data analytics to improve the Website, services, marketing, customer relationships and experiences	Technical and usage information.	We have a legitimate interest in doing so.
To enable you to submit a legal question to our consultant.	Identity and contact information and, to the extent shared by you, special categories of personal information such as race, ethnic origin and religious or philosophical beliefs.	Performance of a contract with you. Where we also process special category data for this activity, our additional lawful basis is that you have consented to provide this information.
To allow you to contact us and communicate with us online mail, phone, email, text message, and other similar communication methods.	Identity and contact information and, to the extent shared by you, special categories of personal information such as race, ethnic origin and religious or philosophical beliefs.	Performance of a contract with you. Where we also process special category data for this activity, our additional lawful basis is that you have consented to provide this information.

Marketing and communications

We may use your personal information to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

We will get your express opt-in consent before we share your personal information with any third party for marketing purposes.

Opting out of marketing

To unsubscribe from marketing emails at any time, please click on the unsubscribe link at the bottom of any marketing email and update your account preferences. You may also contact us or the third party directly if you do not wish to receive any marketing materials from us or them.

Sharing your personal information

Depending on why and what kind of information you share with us, we may use it in the following ways:

We may share your information with any member of our company or subsidiaries, including the parent company, in accordance with section 1159 of the UK Companies Act 2006.
We may also share this information with some third-party companies that provide various services to our Website (such as the hosting of our photos by another company). For more information about these companies, see the "Service Providers" section below.
With search and analysis engines that help us improve the Website and manage its traffic.

We may also share your information with third parties under the following circumstances:

If we want to buy or sell a company or asset, in which case your personal information will be part of the assets transferred to that company and part of the sale.
If our company is completely acquired by another company, your information will be transferred to the acquiring company as part of the Website assets.
If we are legally required to cooperate with the authorities to share information about a specific user or users with relevant authorities for use in the investigation of a crime or disorder.
In order to implement and protect the Website’s Terms of Use, commercial rights, property, security, content and other users of the Website.

Our service providers help our company with a variety of administrative, statistical and technical services. We share the minimum amount of your personal information necessary for their work with them so that they can provide the services we want in the best way. We also explicitly remind them to protect this information in the best way and not to use it for any other purpose. We take such issues very seriously and have asked all our contractors to sign the relevant document and commit to protecting the information of our users before they help us in providing the best experience for you.

When links from other sites that are not a subsidiary of our parent company are used on the Website, the terms and conditions of using its contents are beyond our control and are not covered by this Policy. If you access other sites linked from our Website, be aware that that site may store your personal information and treat it in accordance with its privacy policy. Please read their policies before sharing or using these sites.

6. How long your information will stay with us

We will keep your personal information for as long as we need to provide the service requested by you, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation with respect to our relationship with you.

For example, when you sign up to receive promotional emails and newsletters, we save your email. Even when you request to be unsubscribed from newsletters or marketing emails, your email will remain on file so that we can comply with your request not to send any or certain types of emails.

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

By law we have to keep basic information about our customers (including contact, identity, financial and transaction Data) for six years after they cease being customers for compliance purposes.

In certain circumstances, you can ask us to remove all your information from our Website. See the "Your Rights" section below for more information.

In some circumstances, we may use your information anonymously for statistical or research purposes so that it is not traceable to you. In such cases, we can use this information forever and will not notify you again.

7. Security

Off-Centre Productions takes the security of its users very seriously. We have put in place technologically and organisationally appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

Where necessary, we encrypt your information and store all collected information on secure servers. These servers may be physically located in our company premises or in the databases of other trusted companies.

Where we have given you a password that enables you to access certain parts of the Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. International data transfers

Please note that some of our service providers may be located outside the UK. These service providers provide various services, including support services, to us or one of our subsidiaries. When we share your personal information with a contractor located outside the United Kingdom, we always take special security measures to protect your information to ensure that it remains secure. We do this by ensuring that the country we are transferring your personal information to has been deemed by the UK Information Commissioner’s Office (the ICO), the UK regulator for data protection issues, as having in place an ‘adequate’ level of protection for personal information.

In some circumstances, our service providers may be based in jurisdictions which are not deemed to have in place an adequate level of protection for personal information. When this is the case, we will always ensure that we have an International Data Transfer Agreement in place with that service provider. This International Data Transfer Agreement is approved by the ICO and ensures that that service provider is contractually obliged to provide the same level of protection for personal information as if they were a UK based company.

If you would like to receive more information about the manner and conditions of this international transfer of information, please contact [email protected].

9. Your rights

You have the right to make a complaint at any time to the ICO (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance using the contact details set out at the end of this Policy.

As a data subject, you have various rights regarding how your personal information is used. These rights and how to apply them are:

Your right to access your information. You have the right to request access to your personal information collected by us at any time. You may have heard this right described as the right to make a ‘subject access request’. Please note that this right enables you to request a copy of your information to review and verify its accuracy and to ensure that it is being used in accordance with this Policy. However, the law will not allow you to access other people's personal information or ask us for other information that is unrelated to your personal information. You can exercise this right at any time by contacting us through the communication channels listed at the end of this Policy. There is no need to fill out any special form for this request.

Your right to correct and delete your information. You can at any time ask us to correct any information about you that you think is incorrect or inaccurate. You can also ask us to delete all the information collected from you and not store any more information about you. You may have heard this right described as the "right to be forgotten”. Please note that we may ask you to confirm the accuracy of any new information provided or take steps to confirm it ourselves. Further, we are not always required to delete your personal information upon your request. If for any reason we believe there is a valid legal reason to retain and collect this information, we will share that reason with you when responding to your request.

At any time, you can use this right and request us to correct or delete your personal information through the communication channels listed at the end of this document and provide a reason. If your request is to replace old incorrect information with new information, you must clearly state the new information in your request. There is no need to fill out any special form for this request.

Your right to restrict the use of information. When we collect your personal information for a valid reason (see the section "Why and how we use your information"), you have the right to ask us to use stop this information if you believe that our work in any way infringes on your fundamental rights or freedoms or if you feel that the reasons we have provided to you are not justified. Please keep in mind that if for any reason we believe there is a legitimate legal reason to use this information, we will continue our work. We will share that reason with you after conducting the necessary investigation or when responding to the request. At any time, you can use this right and through the communication channels listed at the end of this document, write to us and request that we stop using your personal information. There is no need to fill out any special form for this request.
Your Right to Transfer Information. When you wish to transfer your personal information that we hold to another company, simply ask us to send this information to you in a computer language format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Your right to stop receiving communications from us. When you receive marketing emails or newsletters or any other such emails from us, you can unsubscribe from that email list at any time. To do this, just click on the word "unsubscribe". You can also email [email protected] and tell us what list you want to be removed from.
Your right to object to automatic decision-making about your information. You have the right to be informed about the existence of any automated decision making and profiling of your personal information, and where appropriate, be provided with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing that affects you.
Your right to withdraw consent, where consent is the lawful basis for processing. You have the right to withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Exercising these rights When you contact us and request to exercise any of these rights, we must make sure that you are who you claim to be. For this reason, we may ask you to provide identity documents to make us sure of your identity. It will be helpful if you mention exactly which right you want and why you want to use it. The more detailed and clear your request is, the faster and more efficiently we can respond to it. If the information provided in your request is not complete, we may delay the response to this request until you provide additional information. If so, we will let you know. You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. How to contact us

If you have any questions or concerns about this policy, if you want to exercise any of your rights, or if you feel that this policy has not been followed, please contact us through the options below:

Postal address:

Off-Centre Productions Ltd.
83 Cambridge Street
London
SW1V 4PS
United Kingdom

E-mail: [email protected]