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Privacy Policy

INTRODUCTION AND DEFINITIONS

This Privacy Policy sets out how Miss C S Carr trading as SG Marketing (“we“, “our” and “us“) collects, processes and protects your personal information.

In this Policy “data protection law” means all data protection legislation having effect in the United Kingdom from time to time including the Data Protection Act 2018 and, for such time as the UK remains in the EU, the General Data Protection Regulation (Regulation (EU) 2016/679).

OUR DETAILS

The data controller with conduct of your personal information is Miss C S Carr trading as SG Marketing of Efford Park, Milford Road, Lymington, Hampshire, SO41 0JD.

HOW WE USE YOUR INFORMATION

The following sections explain what information we hold about you, why we are processing that information, the legal bases we rely upon to process you information, the duration for which we keep your information and (if applicable) who your information will be shared with and where those recipients are based.

Which information do we process?

We process the following information from you:

  • Information you give us. This is information about you that you give us by filling in forms on our website, emailing us, writing to us or speaking to us by phone or in person. The information you give us may include your name, job title, work address, email address, phone number and a photograph. If you are a client or supplier of ours then you may also provide us with your bank details.
  • Information we collect about you. We collect technical information about your device and web browser when visiting out website. This includes your IP address and information about your visit, such as records of how you navigate the pages on our site and how you interact with the pages.
  • Information obtained from or provided by third party sources. This includes information made publicly available by you (e.g. on social media) or by your organisation (e.g. your public profile on your employer’s website). This also includes information compiled by reputable business database providers. The information we obtain from these sources typically includes your name, job title, email address and phone number.

What purposes do we process your information for?

We process this information about you for the following purposes:

  • if you are a client of ours (or an employee or representative of a client of ours), to supply you (or your organisation) with the goods and services you have purchased from us. This includes taking pre-contractual steps (e.g. providing you with a fee estimate) and administering your relationship with us (e.g. issuing you an invoice);
  • if you are a supplier or contractor of ours (or an employee or representative of the same), to request and obtain goods and/or services from you (or your organisation). This includes taking pre-contractual steps (e.g. requesting a fee estimate) and administering our relationship with you (e.g. keeping a record of the goods/services you have provided);
  • if you are a client or prospective client of ours, to send you marketing communications about our products and services which we think will be of interest to you;
  • if you are a customer or prospective customer of our client’s, to send you marketing communications about information about business opportunities relating to commercial property;
  • to undertake market research;
  • to produce and publish press releases and content marketing;
  • to comply with our regulatory and legal obligations to process and keep a record of your data; and
  • to ensure that content from our website is presented in the most effective manner for you and your device. For more information on how we use cookies, please refer to the ‘Cookies’ section below.

What are our legal grounds for processing your information?

We are processing your information on the following grounds under data protection law:

  • if you are a client or supplier of ours, because the processing is necessary for the performance of the contract between you and us, and the taking of pre-contractual steps;
  • if you are an employee or representative of a client or supplier of ours, because we have a legitimate interest in processing your information in order to perform the contract between your organisation and us, including taking pre-contractual steps;
  • in certain circumstances, the processing is necessary for us to comply with our legal obligations, for example relating to our accounting records;
  • the processing is necessary for achieving our legitimate interests of:
  • (i) maintaining accurate internal records of clients (and their customers insofar as they relate to the services we supply), suppliers, contractors, and their contacts for administrative and general business purposes. This includes where we keep a record of potential supplier details with a view to using their services or purchasing their products in the near future and where we keep a record of past commercial negotiations;
  • (ii) responding to your enquiry, whether submitted through our website, email, over the telephone, in person or otherwise;
  • (iii) producing and publishing press releases and other promotional content; or
  • (iv) sending you marketing communications where those activities do not require your prior consent. You can unsubscribe from these communications at any time by following the instructions contained in the communication or by contacting us using the details set out in the ‘Contact’ section below. In accordance with data protection law we operate a suppression list to ensure you do not receive communications from us once you have opted out,

and in accordance with data protection law we have carefully weighed your interests and fundamental rights and freedoms against our interest to process your information and are satisfied that we are justified in processing your information for these purposes; and

  • we are otherwise processing your data on the basis of your consent. This will typically be the case where you have opted into receiving marketing communications from us.

How long do we keep your information for?

We only keep your information for so long as it is reasonably necessary taking into account (amongst other things) our legal obligations and the need to efficiently operate our business.

The length of time we retain your information depends on the purpose for which we have collected it:

  • For potential clients who ultimately do not instruct us, we keep your information for ten years.
  • If you are a client of ours then we keep your information for fifteen years.
  • We keep records of attendees of events we host for ten years.
  • In all other circumstances, we keep professional contact and supplier details for ten years.
  • If your information is contained in one of our marketing databases then:
    • if your information has been supplied by a third party and we are processing it based on our legitimate interest then we will keep your information for the duration of the licence with our supplier (typically one year); and
    • if we are processing your information on the basis of your consent then we will keep your information for six years unless you refresh your consent, in which case the retention period will be reset.

If you are not certain which retention period applies to your information then please contact us using the details set out at the end of this Policy.

Who is your information shared with?

Your personal information is not shared with anyone except where we are required to do so to comply with the law, to protect our rights, to improve and expand our products and services or to effectively operate our business.

We may share your information with the following people or group of people:

  • Our outsourced service providers, who may have access to your personal information as part of the service they provide to us. Our service providers are subject to strict contractual obligations to treat your personal information with the utmost sensitivity, to keep it confidential and to comply with data protection law at all times.
  • Professional advisers, we may share personal information with our legal, financial and other professional advisers for the purpose of obtaining advice, such as legal advice. These transfers are protected by our advisers’ duties of confidentiality.
  • Potential purchasers, we may share personal information with potential purchasers of our business, to the extent permissible under data protection law, subject to those persons first entering into strict confidentiality obligations with us.
  • Our clients, we may share your personal information with our clients for the purpose of us providing our professional services to them. This occurs when, for example, we conduct marketing activities and market research.

To the best of our knowledge, understanding and belief, your information will not be transferred outside of the European Economic Area or to any country which is not approved by the European Commission. Except as a result of the UK leaving the EEA due to Brexit, we will let you know if this position changes.

Automated decision making

We do not make automated decisions about you based on your information. If this changes then we will let you know.

YOUR RIGHTS

Under data protection law you have the following rights:

  • if we are processing your personal information on the basis of your consent then you have the right to withdraw that consent at any time. Consent can be withdrawn by notifying us using the details set out in the ‘Contact’ section below. Please note that your withdrawal of consent will not have retrospective effect and so will not affect the lawfulness of our previous processing activities based on that consent;
  • the right to access a copy of your information which we hold. This is called a ‘subject access request’. Additional details on how to exercise this right are set out in the ‘Access to Information’ section below;
  • the right to prevent us processing your information for direct marketing purposes. You can exercise your right to prevent such processing by leaving unchecked certain boxes on the forms we use to collect your data or by contacting us using the details set out in the ‘Contact’ section below;
  • the right to object to decisions being made about you by automated means. We will inform you if your information is subject to automated processing;
  • the right to object to us processing your personal information in certain other situations;
  • the right, in certain circumstances, to have your information rectified, blocked, erased or destroyed if it is inaccurate;
  • the right, in certain circumstances, to claim compensation for damages caused by us breaching data protection law; and
  • the right, in certain circumstances, to request that we erase, rectify, cease processing and/or delete your information.

You also have the general right to complain to us (in the first instance) and to the Information Commissioner’s Office (if you are not satisfied by our response) if you have any concerns about how we hold and process your information. Our contact details are set out in the ‘Contact’ section, below. The Information Commissioner’s Office website is www.ico.org.uk.

For further information on your rights under data protection law and how to exercise them, you can contact Citizens Advice Bureau (www.citizensadvice.org.uk) or the Information Commissioner’s Office (www.ico.org.uk).

COOKIES

Our site uses cookies to distinguish you from other users of our site. This helps us to provide you with a good experience when you browse our site and also allows us to improve our site.

Visitors to our site who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using our site. This will mean that some features of our site may not function properly without the aid of cookies.

ACCESS TO INFORMATION

Under data protection law you can exercise your right of access by making a written request to receive copies of some of the information we hold on you. You must send us proof of your identity, or proof of authority if making the request on behalf of someone else, before we can supply the information to you. Requests should be sent to us using the contact details set out at the end of this Policy.

You do not need to pay a fee to exercise this right unless you are requesting copies of documents you already possess, in which case we may charge our reasonable administrative costs. We are also allowed to charge you for our reasonable administrative costs in collating and providing you with details of the requested information which we hold about you if your request is clearly unfounded or excessive. In very limited circumstances, we are entitled to refuse to comply with your request if it is particularly onerous.

DATA SECURITY

We will always store your digital information on secure servers. Unfortunately, however, the transmission of information via the internet is not completely secure. Although we will do our best to protect your information, we cannot guarantee the security of your information transmitted to our site or otherwise to our servers (such as by email). Any such transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

THIRD PARTY SITES

Our site may, from time to time, contain links to and from clients’, other third parties’ and social network sites. If you follow a link to any of these websites, please note that these sites have their own privacy policies and that we do not accept any responsibility or liability for those policies. Please check their privacy policies before you submit any personal information to those websites as they may not be on the same terms as ours.

CHANGES TO OUR PRIVACY POLICY

This Policy was last updated on 6 February 2019. Future changes we may make to our Privacy Policy will be uploaded to our website and if the change is significant we will notify you by email. Please check back frequently to see any updates or changes to our Privacy Policy.

CONTACT

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to info@sgmarketing.co.uk

 

February 2019