Privacy policy

We collect and process your information in the following ways:

Information you give us

• your name, personal and/or business contact details (including postal address, phone number(s), email address), credentials like passwords and any other information required to validate your identity;
• information about our products and services you use, have used or asked about, including billing and payment history and other account information;

Information we receive from third parties

• your name, personal and/or business contact details (including postal address, phone number(s), email address), credentials like passwords and any other information required to validate your identity.

To provide a requested service or carry out a contract with you

• If you are a client we need to update you on important information about your campaigns/projects

Where we have your consent

• We’d very much like to tell you about our products and services we offer, but we promise not to flood your inbox

Where we have a legitimate interest

• We’ll happily share the details of our Legitimate Interest Assessments with you if you find yourself unexpectedly contacted

We keep your information for the following periods:

• Customer order information: As long as is contractually necessary
• Client contact details: As long as an individual is a customer; limitation period for contractual claims

We share your personal information with trusted third parties where we have retained them to provide services that you or our clients have requested, such as incentive providers, data providers and consultants. These third parties comply with similar and equally stringent undertakings of privacy and confidentiality.

We share your personal information with third parties who perform functions on our behalf and who also provide services to us, such as professional advisors, IT consultants carrying out testing and development work on our business technology systems, research and mailing houses and function co-ordinators. These third parties comply with similar and equally stringent undertakings of privacy and confidentiality.

We share your personal information with our other Group companies for internal reasons, primarily for business and operational purposes. As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or merges with us your personal information will be disclosed to such entity. Also, if any bankruptcy or reorganisation proceeding is brought by or against us, all such information will be considered an asset of ours and as such it is possible they will be sold or transferred to third parties.

Where required we share your personal information with third parties to comply with a legal obligation; when we believe in good faith that an applicable law requires it; at the request of governmental authorities conducting an investigation; to verify or enforce our Terms of Use or other applicable policies; to detect and protect against fraud, or any technical or security vulnerabilities; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of third parties, visitors to the our website, our business or the public.

If you do not provide the personal information necessary, or withdraw your consent for the processing of your personal information, where this information is necessary for us to provide services to you, we will not be able to provide these services to you.

No, we do not carry out automated decision making.

To provide better service to you on our websites, we use cookies to collect your personal data when you browse. See our cookie policy for more details.

We may dependent on the circumstances transfer data outside the EEA where we do we will only do so if

• The data is transferred to a company in the United States which has signed up to the ‘Privacy Shield’ agreement
• The transfer is made under a contract which includes the model clauses adopted by the European Commission to ensure that there will be adequate safeguards for data transferred to a source outside the EEA.

If you have any questions about data being transferred, please contact the DPO via the details below.

By law, you have a number of rights when it comes to your personal information. Further information and advice about your rights can be obtained from the data protection regulator in your country.

1. The right to object to processing

You have the right to object to certain types of processing, including processing for direct marketing (i.e. if you no longer want to be contacted with potential opportunities).

2. The right to be informed

You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Policy.

3. The right of access

You have the right to obtain access to your information (if we’re processing it), and certain other information (similar to that provided in this Privacy Policy).

This is so you’re aware and can check that we’re using your information in accordance with data protection law.

4. The right to rectification

You are entitled to have your information corrected if it’s inaccurate or incomplete.

5. The right to erasure

This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.

6. The right to restrict processing

You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.

7. The right to data portability

You have rights to obtain and reuse your personal information for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability.

8. The right to lodge a complaint

You have the right to lodge a complaint about the way we handle or process your personal information with your national data protection regulator.

9. The right to withdraw consent

If you have given your consent to anything we do with your personal information, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal information with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal information for marketing purposes.

We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:

• baseless or excessive/repeated requests, or
• further copies of the same information.

Alternatively, we may be entitled to refuse to act on the request.

Please consider your request responsibly before submitting it. We’ll respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we’ll come back to you and let you know.

We may contact you by phone, email or social media. If you prefer a particular contact means over another please just let us know.

For details, see our data protection policy.