Last Updated 6 July 2018
We respect the privacy of every person who visits www.tpf.london (the “Site”) and who uses the services that we promote on our Site (our “Services”) and we are committed to ensuring a safe online experience. We also respect the privacy of every person whose personal information we may process as a result of providing the Services to others or who applies to work at TPF London.
Purpose of this Policy
- Who are we?
The Site and our Services are operated by The Promotions Factory Limited (“we”, “us” or “our”).
The Promotions Factory Limited is the data controller responsible for your personal information.
The Promotions Factory Limited is an English company with registered company number: 03687321 and whose registered office is at 21 Bedford Square, London WC1B 3HH.
- How to contact us?
- sending an e-mail to firstname.lastname@example.org or
- calling us on: 0207 291 1528
What personal information do we collect and how do we use it?
Our primary goal in collecting personal information from you is to:
- verify your identity;
- help us deliver our Services;
- help us improve the Services and develop and market new services;
- send you marketing communications;
- carry out requests made by you on the Site;
- investigate or settle inquiries or disputes;
- comply with any applicable law, court order, other judicial process, or the requirements of a regulator;
- enforce our agreements with you;
- protect the rights, property or safety of us or third parties, including our other clients and users of the Site and visitors at our offices;
- provide support for the provision of our Services;
- recruitment purposes; and
- use as otherwise required or permitted by law.
In particular, we use your personal information for the following purposes:
Fulfilment of services.
We collect and maintain personal information that you voluntarily submit to us during your use of the Site and/or our Services. We use the contact details you have provided to us so that we can fulfil the supply of services you have engaged us to provide.
Who do we share your personal information with for this purpose?
We will share, where relevant, your personal information (e.g. name and job title, contact information including email address, other information relevant to provision of our Service, or any personal information that you provide to us as part of our providing the Services) with the following categories of third parties:
Web hosting, optimisation and management companies who assist us with the hosting, operation, optimisation and maintenance of our Site and the administration of your account with us.
Please note this list is non-exhaustive and there may be circumstances where we need to share personal information with other third parties in order to provide the products and services as effectively as we can.
What is our legal basis?
It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you or it is in our legitimate interest to use personal information in such a way to ensure that we provide the products and services you have requested in the most effective and efficient way that we can.
Site insight and analysis.
- an IP address to monitor Site traffic and volume;
- the type of browser and operating system you used;
- the date and time that you visited the Site;
- a session ID to track usage statistics on our Site;
- referring website addresses.
Our web pages and e-mails contain “cookies”, “web beacons” or “pixel tags” (“Tags”). Tags allow us to track receipt of an e-mail to you, to count users that have visited a web page or opened an e-mail and collect other types of aggregate information. Once you click on an e-mail that contains a Tag, your contact information may subsequently be cross-referenced to the source e-mail and the relevant Tag.
In some of our e-mail messages, we use a “click-through URL” linked to certain websites administered by us or on our behalf. We may track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications.
By using this information, we are able to measure the effectiveness of our content and how visitors use our Site and our Services. This allows us to learn what pages of our Site are most attractive to our visitors.
What is our legal basis?
Where your personal information is completely anonymised, we do not require a legal basis to use it as the information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required.
Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best products and services to you and our other clients.
We use information that we observe about you from your interactions with our Sites, our email communications to you and/or with our products and services (see the ‘Site Insight and Analysis’ section above for more details of the information collected and how it is collected) and/or your name and email address, to send you marketing communications by email, where you have consented to receive such marketing communications, or where we have another lawful basis to do so.
What is our legal basis?
Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.
We will only send you marketing communications via email where you have consented to receive such marketing communications, or where we have a lawful right to do so.
Business administration and legal compliance.
We use your personal information for the following business administration and legal compliance purposes:
- to obtain IT support;
- to comply with our legal obligations;
- to enforce our legal rights;
- protect rights of third parties; and
- in connection with a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets.
Who do we share your personal information with for these purposes?
We will share your personal information with professional advisers such as IT support providers, lawyers and accountants and/or governmental or regulatory authorities.
What is our legal basis?
Where we use your personal information in connection with IT support, to enforce our legal rights, to protect the rights of third parties or as part of a business transition, it is in our legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us such as a court order.
Where we share your sensitive personal information, we shall obtain your consent to do so.
How do we obtain your consent?
Where our use of your personal information requires your consent, you can provide such consent:
- at the time we collect your personal information following the instructions provided; or
Third Party Links and Services
Your browsing and interaction on any other websites, or your dealings with any other third party service provider, is subject to that website’s or third party service provider’s own rules and policies and you should contact the appropriate third party if you have any questions.
We do not monitor, control, or endorse the privacy practices of any third parties.
We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you deal with and to contact them if you have any questions about their respective privacy notices and practices.
This Privacy Notice applies solely to personal information collected by us through our Site and/or the supply of our products and services and does not apply to these third party websites and third party service providers.
Transfers outside the EEA
Where necessary in order to deliver our services, we will transfer personal information to countries outside the EEA. When doing so, we will comply with our legal and regulatory obligations in relation to the personal information including having a lawful basis for transferring personal information and putting appropriate safeguards in place to ensure an adequate level of protection for the personal information.
How long do we keep your personal information for?
Regarding personal information we have processed in connection with the supply of our products and services to any client, we will retain personal information relevant to that supply of products or services for one year from the date of supply and in compliance with our obligations under the EU General Data Protection Regulation (or similar legislation around the world). We may then destroy such files without further notice or liability.
Regarding any other personal information we have processed, we will retain relevant personal information for one year from the date of our last interaction with the relevant individual and in compliance with our obligations under the EU General Data Protection Regulation (or similar legislation around the world). We may then destroy such files without further notice or liability.
If any personal information is only useful for a short period (e.g. for a specific marketing campaign), we may delete it at the end of that period.
Confidentiality and security of your personal information
We are committed to keeping the personal information you provide to us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration.
We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:
- unauthorised access;
- improper use or disclosure;
- unauthorised modification; and
- unlawful destruction or accidental loss.
All of our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users of our Services.
How to access your information and your other rights?
You have the following rights in relation to the personal information we hold about you:
- Your right of access.
If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
- Your right to rectification.
If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
- Your right to erasure.
You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
- Your right to restrict processing.
You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or you object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
- Your right to data portability.
With effect from 25 May 2018, you have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.
- Your right to object.
You can ask us to stop processing your personal information, and we will do so, if we are:
- relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or
- processing your personal information for direct marketing.
- Your rights in relation to automated decision-making and profiling.
You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us.
- Your right to withdraw consent.
If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.
- Your right to lodge a complaint with the supervisory authority.
If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the UK Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.