Polpeo Limited (“we” or “us” or “our”) is committed to protecting and respecting your privacy.
This policy (together with our terms of access and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. In this policy we cover:
- Our Website;
- Cookies; and
- Marketing Data
Please read it carefully to understand our approach to your personal data. Our aim is always to give you appropriate notice of any data we will collect about you and how it will be used. We will only process your data if we assess it is fair and lawful to do so.
For the purpose of the relevant data protection legislation (“relevant legislation”), the data controller of any personal data you provide to us is Polpeo Limited of Thomas House, 84 Ecclestone Square, London SW1V 1PX, United Kingdom. Our Data Protection Officer is responsible for ensuring compliance with the relevant legislation. That post is held by our Chief Product Officer who can be contacted at email@example.com.
Where we store your personal data
We take appropriate measures in accordance with the relevant legislation to maintain the security of personal data we collect.
We may from time to time share links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we cannot accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features with the aim of preventing unauthorised access.
Disclosure of your information
We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
We may disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of access and other agreements; or to protect the rights, property, or safety of Polpeo, our clients, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Retention of your data
We will retain your personal data only for time necessary to fulfil the purposes for which you provided it and in accordance with this policy. After this time we will take all reasonable steps to destroy or erase your personal data from our systems.
Sensitive personal data
We do not aim to collect sensitive personal data (by which we mean the types of data identified as “sensitive” in the relevant legislation including racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health or condition or sexual life, or about the commission of any offence or allegations or proceedings). If you do give us any sensitive personal data, you consent to us processing such data in accordance with the relevant legislation and this policy.
You have the right to ask us not to process your personal data for specific purposes (e.g. marketing). We will inform you (before collecting your data) if we intend to use your data for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at firstname.lastname@example.org.
Access to information
The Act gives you the right to access information held about you and to correct it if it is not up-to-date or accurate. Your right of access can be exercised in accordance with the Act by contacting us at email@example.com.
The purpose of our website is to enable you to find out more about us and so we can share information with you about our business and the industry. It is important to us that you feel secure when browsing our site or requesting information from us via our website. We are committed to protecting and respecting your privacy when you are using our website.
Information we may collect from you
There are two ways we collect information about you via our website: (1) directly where you submit information to us; and (2) indirectly via cookies and other aspects of the website’s technology.
We may collect and process the following data about you:
- Information that you provide by filling in a form on our site. This includes information provided when you request further materials such as a white paper or if you post comments, or subscribe to our blog.
- If you contact us, we may keep a record of that correspondence.
- We may ask you to complete surveys that we use for research purposes, although you may not choose to respond.
- Details of your visits to our website including, but not limited to, traffic data, location data, blogs and other communication data and the resources that you access. For more information on this see the section on Cookies below.
- Information collated by Google Analytics. For more information on this see the section on Marketing below.
When this data identifies you as an individual, we treat is as “personal data”.
Uses made of the information
We may use information we collect about you via the website to send you information you request, process online job applications and other purposes that will be described at the point of collection, including:
- To ensure that content from our site is presented in the most effective manner for you and for your computer.
- To provide you with information, products or services that you specifically request.
- To contact you for marketing purposes where you have consented to this.
- To allow you to participate in interactive features of our service, when you choose to do so.
- To notify you about changes to our service.
We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to aggregate information to help us better understand our website community. This is statistical data about browsing actions and patterns, and does not identify any individual. We do not treat this data as “personal data”. For more information on this see the section on Cookies below.
Like most businesses, we use some personal data for marketing purposes. This section of our policy describes what types of data we hold and how we use it.
Our website uses Google Analytics Advertising Features for remarketing. We use standard remarketing which means that once you have visited our website you may be shown ads when you browse other Display Network websites or use Display Network apps. More information on remarketing be found here: www.support.google.com/adwords/answer/2453998.
You may opt out of the Google Analytics Advertising Features you use, including through Ads Settings, Ad Settings for mobile apps or any other available means for example, the NAI’s consumer opt-out). See here for more information – www.policies.google.com/technologies/ads
If you prefer not to receive this remarketing after visiting this and other third party websites, Google Analytics’ currently available opt-outs for the web are set out here: www.tools.google.com/dlpage/gaoptout.
What marketing data do we hold?
Our marketing database includes data of:
- Staff members of our clients;
- Individuals who have requested us to send marketing information by completing a form on our website, sending us an email or via a phone call;
- Individuals we have met at events or via online public forums or social media who have asked us to send marketing information.
What uses do we make of marketing data?
We may send the following commercial communications by email to a targeted selection of individuals from our marketing database:
- Invitations to industry events we are hosting or attending;
- Industry updates;
- Updates about our agency and the services we offer;
- Other information that we reasonably think may be of interested to our contacts.
Customer Relationship Management database
As with many agencies and other businesses we use a Customer Relationship Management database (“CRM”) to manage and assess our contact with people who are interested in our services. Our CRM will include people to whom we already deliver services and people we believe we may deliver services to in the future. The personal data on the CRM will include information publicly available such as job title and name of company . It may also include information added by our team members based on their interactions with you. If you wish to be excluded from our CRM please contact firstname.lastname@example.org.
You have the right to ask us not to use your personal data for marketing by checking the relevant boxes on the forms where you submit your personal data or by clicking ‘unsubscribe’ in any of the marketing communications from us. Please note if you do unsubscribe we will retain the information necessary to ensure we do not contact you again.