1. POLICY STATEMENT
Absolute PR and Marketing Limited is a company registered in England and Wales (No: 09353664) of 10 The Barton Dunchideock Exeter EX2 9UA.
In some instances (for example for specific projects and/or services), we may collect further personal information about you. On those occasions we may provide you with a separate privacy notice which will provide you with further details about our use of your personal information in relation to that project/service and which is appropriate in those specific circumstances (where this is legally required). In such instances, that specific privacy notice will apply to the collection of that further personal information.
2. COOKIES AND WEBSITE USAGE INFORMATION
When you visit our Site we automatically collect a series of general data and information. This data is stored in server log files and may include:
- your browser types and versions used
- your operating system
- the website from which you or your system reached our Site
- the sub-websites visited
- the date, time and length of time our Site was accessed
- your internet protocol address (IP address)
- your internet service provider
- any other similar data and information that may be used in the event of attacks on our information technology systems.
This information is not used to profile or draw any conclusions about you but to:
- deliver the content of our Site correctly
- optimise the content of our Site and any related advertisements
- ensure the long-term viability of our Site
- provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack.
General data and information collected by our Site is collected and analysed anonymously for the purpose of increasing data protection and security.
Our Site is powered and published by the third party service, WordPress.com, which is run by Automattic Inc. We use a standard WordPress service to collect anonymous information about users’ activity on the Site, for example the number of users viewing pages on the Site, to monitor and report on the effectiveness of the Site and help us improve it. For more information about how WordPress processes data, please see Automattic’s privacy notice.
This privacy notice does not cover the links within this site linking to other websites. We encourage you to read the privacy statements on the other websites you visit. These include:
- Facebook to share posts from Absolute and to allow visitors to our Site to easily share our content to Facebook. Facebook users have a range of options available to them to protect their personal information. You can read about these tools and view Facebook’s Data Policy online.
Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. The table below explains the cookies we use and why.
|PHP session cookie||PHPSESSID||The PHP session cookie is a general purpose identifier used to maintain user session variables. It is a random generated number and will be deleted when you end your visitor session. It does not contain any user identification information.|
|We embed videos from our official YouTube channel using YouTube’s privacy-enhanced mode. This mode may set cookies on your computer once you click on the YouTube video player, but YouTube will not store personally-identifiable cookie information for playbacks of embedded videos using the privacy-enhanced mode.
* expires after eight months
* expires at the end of your session
Most web browsers allow users to delete already set cookies and to specify some control of future cookies through the browser settings. Find out how to manage cookies on popular browsers:
To find information relating to other browsers, visit the browser developer’s website.
3. WHAT TYPE OF PERSONAL INFORMATION DOES ABSOLUTE PR AND MARKETING COLLECT?
The Site allows you to interact with Absolute in a number of ways, such as using the ‘contact us’ form or providing you with our contact telephone number so that you can call us. If you do choose to contact us in any way, and, in doing so, provide us with your personal information, we will collect that information for our own use and for the purposes described in more detail below.
Where you choose to subscribe to receive our newsletters, or otherwise contact us (whether through the Site, or by using the contact information in the Site to do so), we will collect the following personal information from you:
i. your full name;
ii. contact telephone number(s);
iii. your e-mail address; and
iv. any other information you choose to share with us.
As part of our follow-up contact with you, depending on the nature of your enquiry, and only where you choose to provide it, we will collect the following additional personal information about you:
i. the name and address of the company you work for; and
ii. details of the sector in which you currently work.
The personal information which we collect from you is used to respond to any communication or enquiry which you have sent to us. Alternatively, where you have subscribed to receiving copies of our newsletter, we will use your personal information to provide that information to you.
The personal information which you provide to us is provided on a voluntary basis, and is information which we receive directly from you. Where lawful to do so, we may also collect personal information about you from public sources (such as social media feeds), third party service providers, individuals who you have indicated have agreed for you to provide their personal information, government, tax or law enforcement agencies and other third parties.
Absolute will never sell your personal information once it has been collected and is being processed.
4. HOW DOES ABSOLUTE USE INFORMATION ABOUT YOU?
Where Absolute has collected your personal information through this Site, or as a result of communications with you, that personal information will only be used in accordance with this Policy. In the event that you have provided personal information to us as part of a particular project or programme, or for services to be received from us, your personal information will be processed in accordance with this Policy, unless we provided an additional privacy notice to you relevant to that project or programme or services to be provided. In which case, that specific project or programme or services privacy notice will apply to our handling your personal information.
In terms of this Site, and our general communications with you, we will use your personal information for the following purposes:
- to respond and/or deal with your request or enquiry;
- to administer the Site;
- for internal record keeping;
- provide you with updates about us and anything we may publish from time to time (where you have subscribed to receive such updates only);
- to contact you by e-mail or phone for any of the above reasons;
- to provide you with information at your request;
- where necessary as part of any restructuring of Absolute;
- for compliance with legal, regulatory and good governance obligations;
- to anonymise your personal information so that we can use it (normally in an aggregated statistical format) for research purposes and analysis and improve Site performance;
- to provide you with updated versions of this privacy notice and/or to confirm that you are still happy to hear from us; and/or
- to provide your personal information to third parties (which is described in more detail below in Section 5).
Data Protection law requires that we have a legal basis for processing your personal information. In this regard, we rely on one or more of the following three lawful basis for processing personal information:
- where it is necessary in our legitimate interests, but only where those legitimate interests are not overridden by your fundamental rights and freedoms – this is used, for example, where we respond to your enquiries, or where we use information obtained from your usage of our Site to improve the Site to your and other users’ benefit, or where we engage with our third party service providers who assist us in our daily work (discussed further below), to manage our information and subscriptions, to handle any complaints in relation to the work that we undertake and to maintain accurate records;
- with your consent – this is used where you have subscribed to receive our newsletter or other information from us, or have otherwise provided your consent for our processing of your personal information; or
- where it is necessary for compliance with a legal obligation – this will include responding to legal requests from government agencies and other similar organisations which require us, by law, to provide personal information to them and where we are required to disclose information as part of any legal proceedings.
5. DOES ABSOLUTE SHARE PERSONAL INFORMATION WITH THIRD PARTIES?
Your personal information will only be made available for the purposes mentioned above (or as otherwise notified to you from time to time) to staff who properly need to know these details for their functions within Absolute.
1. Your personal information will be made available to third parties (within or outside Absolute) providing relevant services under contract to us. Our service providers can be divided into the following categories of third parties:
- Professional service providers – this would include our lawyers, accountants, auditors who we may rely on to provide specialist professional advice;
- Back office support – this includes service providers who provide IT services, communications (both electronic – such as website management companies and non-electronic – such as companies we use to assist with any paper mailing campaign) and support services, such as travel services, insurance brokers and advisers, building management company;
- Monitoring or evaluation of Absolute projects/activities to assess their effectiveness and impact, which will often include working with consultants or other agencies who are involved in our projects or programmes or service provision.
2. We will disclose specific information upon lawful request by government authorities, law enforcement and regulatory authorities where required by law. Only where necessary, we will disclose personal information to third parties in response to legal process (such as court action), or to enforce our agreements, to protect the rights, property or safety of Absolute, our employees, agents, and/or Site users; and
3. If you authorise or request us to do so, we will share your personal information with other parties specified in such authority or request but not otherwise.
6. WILL YOUR PERSONAL INFORMATION BE TRANSFERRED ABROAD?
Whilst we will not personally transfer your personal information outside the United Kingdom, which is part of the European Economic Area (“EEA”), you should be aware that your personal information may be transferred outside of the EEA by service providers (such as our IT service provider who may host our data outside of the EEA) to locations which may not have equivalent protection for personal information to that within the EEA. Where this happens, Absolute takes steps to protect your personal information. As such, where we are asked to allow data to be transferred outside of the EEA, we will ask for information about the safeguards in place regarding the systems where your personal information will be stored and ensure that appropriate mechanisms are in place to protect your personal information during and after the transfer, such as standard contractual clauses. We will not agree to the transfer of personal data until appropriate checks have been made.
Additionally, whenever we engage new service providers, we will carry out due diligence to find out from the outset whether the nature of their operations requires the transfer of personal information outside the EEA and, if so, based on what mechanism. If satisfactory data protection measures are not in place, we will not provide them with any personal information until such time as they are.
7. WHAT RIGHTS DO YOU HAVE TO REVIEW AND AMEND PERSONAL INFORMATION?
You have the right to request access to the personal information that we hold about you. In order for us to comply with such a request, we may require you to prove your identity before we are able to commence with any work associated with such a request, both for your security and to ensure our own compliance with data protection laws.
As well as the right to access the personal information that Absolute holds about you, you have a number of other rights in respect of your personal information under the data protection laws. These may include (as relevant):
- the right to rectification, including to require us to correct inaccurate personal information;
- the right to request restriction of processing concerning you or to object to processing of your personal information;
- the right to request the erasure of your personal information where it is no longer necessary for us to retain it;
- the right to data portability including to obtain personal information in a commonly used machine-readable format in certain circumstances such as where our processing of it is based on a consent;
- the right to object to automated decision making including profiling (if any) that has a legal or significant effect on you as an individual (however, please note, we don’t undertake such activities at Absolute at present); and
- the right to withdraw your consent to any processing for which you have previously given that consent.
Please be aware that some of these rights will only become relevant when changes to the data protection laws come into force on 25 May 2018.
If you wish to exercise any of the above rights, or if you would like to contact Absolute in respect of its data processing activities, please contact us using the contact information provided in Section 10 below.
8. HOW LONG WILL ABSOLUTE KEEP YOUR PERSONAL INFORMATION?
Your personal data will not be kept for longer than is necessary to fulfil the specific purposes outlined in this Policy and to allow us to comply with our legal requirements. The criteria which we use to determine personal information retention periods include:
- Personal information: where you are, and continue to be a client of Absolute, we will keep your details on record for so long as you remain a client. If you would like to cease to be a client in accordance with the contract terms we have in place with you, please email or write to us using the contact information provided in Section 10 below, following which, we will retain the personal information relevant to you for a reasonable period (up to twelve months) after the end of the contract, after which it will be deleted;
- Subscription to receive newsletters/information: where you have subscribed to receive newsletters/information from us, we will retain your personal information until you choose to inform us that you no longer wish to hear from us. Once you have advised us that you no longer wish to receive publications/information from us, we will remove your name from our subscription list as soon as possible, and in any event within 28 days;
- Your enquiries: where you have contacted us we may retain your personal data for a reasonable period (up to twelve months) after we have dealt with your enquiry, unless you subscribe to receive our newsletter and/or information from us; and
- Retention in accordance with legal and regulatory requirements: where necessary to comply with our legal or regulatory obligations, we may need to retain your personal information for longer than the periods set out above. Where this is the case, we will only retain that personal information for as long as necessary to comply with such legal or regulatory compliance purposes.
If you have any further questions regarding our holding of your personal information, please contact us using the contact information provided in Section 10 below.
9. CHANGES TO THIS POLICY
We keep this Policy under regular review. We may change this Policy from time to time in order to reflect changes in the law and/or our privacy practices. The date at the bottom of this Policy will be updated accordingly.
Where required by law, we will notify you of any modified versions of this Policy that affect the way we use or disclose your personal information.
This Policy only extends to your use of the Site and your communication with Absolute through the contact methods as set out on the Site. As noted above, in some instances we may provide you with additional privacy notices in relation to certain projects and/or services we provide to you. In such instances, the terms of those project/services specific privacy notices will apply to our processing of your personal information.
10. CONTACT/ADDRESS DETAILS
If you have any questions about this Policy, please contact us using the below contact methods:
By email to: firstname.lastname@example.org
By writing to us at our Registered Office:
Absolute PR and Marketing Limited
10 The Barton