Privacy policy

Big Marketing Ltd

Contents

• 1. Overview and consent
• 2. User Data
• 3. Security
• 4. Third party
• 5. Your rights
• 6. Compliance
• 7. Changes to our Privacy Policy
• 8. Copyright, credit and logo
• 9. Contact details

This is the privacy policy text published on Big Marketing’s live website. The live policy states that it is effective from 25 May 2018.

1. Overview

Big Marketing Ltd respect your privacy and are committed to maintaining the privacy and confidentiality of the personal information we collect. This Privacy Policy sets out how we, Big Marketing Ltd, collect, store and use information about you when you use our website, bigmarketing.co.uk, and where we otherwise obtain or collect information about you.

1.1 Consent

By contacting us by email, phone or by filling in a contact form on our website (www.bigmarketing.co.uk) or other sites owned by Big Marketing Ltd, you agree and accept that we may gather, process, store and/or use the personal data submitted in accordance with the rules set forth below. By giving your consent to us, you also retain the right to have any personal data rectified, to be forgotten and/or to be erased.

2. User Data

2.1 Data Big Marketing Ltd collects when you contact us

Website

If you are a visitor to the Big Marketing website we may obtain the following types of information from you or concerning your computer or device, which may include information that can itself be used to identify and/or contact you:

• Name
• Email address
• Phone number

Big Marketing may also receive certain information provided by your browser or mobile device, including time of visit, pages accessed, time of last visit, referring site/application/service and relevant search queries, browser information, operating system information, device information (including mobile operating system and screen size) and demographic information (including country, county, postcode and street address).

Web server log information

We use a third-party server to host our website, called Rackspace. Our website server automatically logs the IP address you use to access our website as well as other information about your visit, such as time of visit, pages accessed, referring site, browser, operating system, device and demographic information. We do not access log data unless investigating suspicious or potential criminal activity and do not attempt to identify you from information collected via server logs.

The live policy identifies compliance with a legal obligation (Article 6(1)(c) GDPR) and our and a third party’s legitimate interests (Article 6(1)(f) GDPR) as legal bases for this processing, including network and information security.

Contact form

When you contact us using our contact form, we may collect your name, email address and telephone number, together with any other information you provide. If you do not supply mandatory information required by the contact form, you will not be able to submit it and we will not receive your enquiry. The live policy identifies legitimate interests in responding to enquiries and keeping correspondence records, and taking steps at your request before entering into a contract, as legal bases.

Email, phone and post

When you email us, we collect your email address and any other information you provide. When you contact us by phone, we collect your phone number and information provided during the conversation. The live policy states: “WE DO NOT RECORD PHONE CALLS”. If you contact us by post, we collect the information provided in your postal communications. The live policy identifies responding to enquiries and taking steps at your request before entering into a contract as legal bases for processing.

2.2 Visitors to Big Marketing Ltd’s clients’ websites

Big Marketing Ltd obtains information regarding activities of visitors to clients’ websites, including pages accessed, time of visit, time of last visit, referring site and search queries, browser information, operating system information, device information and demographic information.

2.3 Cookies

A cookie is a small piece of information in the form of a text file, sent by a web server and stored on the computer of a visitor to a website. The live policy says that session cookies are used to retain user preferences, collect website usage information via Google Analytics and for user authentication. Preference cookies are described as not collecting personal information such as usernames or email addresses.

Google Analytics and managing cookies

The live policy says Google Analytics cookies collect website usage information, including visit duration, navigation path, computer type and approximate visitor location, and states that Google Analytics does not collect personal information such as a name or email address. It says data is stored in the United States and refers to Google’s Analytics terms. It also says visitors can choose not to accept cookies and still use the website, and can manage cookies through their browser.

2.4 How we use your data

The live policy says information collected may be used to:

• Provide use of and access to the website
• Analyse and enhance website usability
• Carry out administrative and business purposes
• Provide customer service or support, resolve disputes, collect fees and troubleshoot account problems
• Send emails to contact you about enquiries, requests or questions
• Process payment transactions
• Fulfil contractual obligations
• Comply with the law, enforce website policies, prevent and investigate fraud and security breaches, and protect rights, property or safety

2.5 Data retention periods

The live policy states that server log information is retained for 30 days; order information is retained for six years following the end of the financial year in which the order was placed; and correspondence and enquiries are retained for as long as needed to respond to and resolve the enquiry, plus a further three months. In other circumstances, information is retained no longer than necessary, taking account of the purpose and use of the information, legal obligations and the legal basis for processing.

2.6 Testimonials

Big Marketing Ltd publishes a list of customers and testimonials on its site with customers’ names and job titles. The live policy states that authorisation is obtained from every customer before publishing a testimonial.

3. Security

3.1 How we secure your information

The live policy says appropriate technical and organisational measures are taken to secure information against unauthorised or unlawful use and accidental loss or destruction. These include limiting access on a need-to-know basis, using secure servers with backup and security features, verifying the identity of people requesting access, using SSL software to encrypt information submitted through website forms, and transferring information only through closed systems or encrypted data transfers.

3.2 Access

Personal data is only accessible by those who need to access it in their work, for example IT and HR staff. The live policy states that all staff contracts have a confidentiality clause.

3.3 Data breach

The live policy states that, in the event of a security breach, Big Marketing Ltd will directly inform those affected without undue delay, no later than 72 hours after becoming aware of it.

3.4 External website links

The live policy says that links to third-party websites may be displayed, but Big Marketing Ltd cannot control or be held responsible for those websites’ privacy policies. Visitors should read the privacy policy of each website to understand how personal information is collected and processed.

3.5 Transmission of information to us by email

The live policy says transmission of information over the internet is not entirely secure and that information submitted over the internet, including by email or through the website, is submitted at the sender’s own risk. It disclaims responsibility for losses suffered as a result of the decision to transmit information by those means.

4. Third party

4.1 Information collected or obtained from third parties

Big Marketing Ltd may engage third-party companies, service providers or business partners to process data and support its business. The live policy says that information may be received from recruitment agencies, hosting providers, payment providers, clients and suppliers, and potentially from third parties with whom Big Marketing has had no prior contact. This information will generally include a person’s name and contact details, and any additional information supplied.

The live policy identifies contract-related necessity, consent and legitimate interests as possible legal bases, depending on why the third party shared the information. If information is received in error and there is no legal basis for processing it, the policy says it will be deleted.

The policy also says that, in certain circumstances, information may be obtained from publicly accessible sources such as the electoral register, Companies House, online customer databases, business directories, media publications, social media and websites, for example to verify information or obtain information needed to provide a service.

4.2 Automated decision-making and profiling

The live policy states: “We do not use automated decision-making and profiling”.

4.3 Disclosure and additional uses of your information

4.3.1 Disclosure to service providers

The live policy says information may be shared where necessary with service providers supporting the business, including telephone providers, email providers, IT service providers, web developers and hosting providers. It says provider identities are not displayed publicly for security and competitive reasons, but further information may be provided on request where there is a legitimate reason. The policy identifies legitimate interests and contractual necessity as legal bases.

4.3.2 Disclosure to other third parties

The live policy describes sharing information with Google through Google Analytics, on an aggregated and anonymised basis, and refers to Google’s privacy information and browser opt-out plugin. It also describes sharing information where necessary with third parties associated with running the business, including accountants, professional advisers, business partners, independent contractors and insurers. It says identities are not publicly listed for security and competitive reasons, but further information may be provided where there is a legitimate reason. The policy identifies legitimate interests as a legal basis.

4.3.3 Disclosure and use for legal reasons

The live policy says information may be used or disclosed where necessary to report suspected criminal conduct or threats to public security, enforce or protect legal rights, resolve legal disputes or proceedings, and comply with laws, regulations and other legal requirements. It identifies legitimate interests and compliance with legal obligations as possible legal bases.

5. Your rights

5.1 Your rights in relation to your information

The live policy says that, subject to certain limitations, individuals may exercise the following rights by writing to Big Marketing Ltd at C5 Sunningdale House, Caldecotte Lake Drive, Caldecotte, Milton Keynes, MK7 8LF or emailing data@bigmarketing.co.uk:

• Request access to personal information and information about its use and processing
• Request correction or deletion of information
• Request restriction of use of information
• Receive information supplied to Big Marketing in a structured, commonly used, machine-readable format and have it transferred to another controller
• Object to processing for certain purposes
• Withdraw consent where processing relies on consent; withdrawal does not affect processing carried out before withdrawal

The policy also refers to the right to complain to a supervisory authority under Article 77 GDPR, and identifies the UK Information Commissioner’s Office (ICO). It provides links to ICO guidance and the GDPR legislation.

Verifying identity

The live policy says Big Marketing Ltd must take reasonable measures to verify identity before providing access to personal information. It may use information already held or request original or certified copies of documents if needed.

5.2 Right to object to processing for certain purposes

The live policy says individuals may object to processing carried out in the public interest or on the basis of legitimate interests, including profiling, and may object to processing for direct marketing. It describes using the unsubscribe link in marketing emails or replying “NO” to marketing text messages as ways to object to direct marketing.

5.3 Sensitive personal information

The live policy defines sensitive personal information by reference to information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric information, health, or sex life or sexual orientation. It says Big Marketing Ltd does not knowingly or intentionally collect such information and asks individuals not to submit it. It states that inadvertently or intentionally transmitted sensitive information will be processed for the purpose of deleting it.

6. Compliance

6.1 EU General Data Protection Regulation

The live policy states that Big Marketing Ltd operates from within the EU and does its utmost to comply with the EU General Data Protection Regulation.

6.2 Children’s Privacy

The live policy refers to the Children’s Online Privacy Protection Act of 1998 (COPPA), states that the website is not intended to solicit information from people under 18, and says Big Marketing Ltd does not knowingly contact or collect information from people under 18. It describes steps to be taken if the company is notified that information about a person under 18 has been received.

6.3 California Do Not Track Disclosures

The live policy explains that browser Do Not Track signals request that websites do not track a user and states that Big Marketing Ltd does not currently respond to Do Not Track browser settings or signals.

7. Changes to our Privacy Policy

The live policy says it may be updated from time to time. For minor changes, the policy will be updated with a new effective date and the new version will apply from that date. For major changes or a new purpose for processing information, Big Marketing Ltd says it will notify individuals by email where possible or by posting a notice on the website, and provide relevant information before using information for the new purpose. Prior consent will be obtained where required.

8. Copyright, credit and logo

The live policy says it is based on a General Data Protection Regulation (Regulation (EU) 2016/679) compliant template provided by GDPR Privacy Policy. It states that copyright in the policy is owned by or licensed to Big Marketing Ltd, is protected by copyright laws, and that all intellectual property rights are reserved. Where the GDPR Privacy Policy logo is displayed, it indicates that the template was used as the basis for the policy.

9. Contact details

Big Marketing Ltd
C5 Sunningdale House
Caldecotte Lake Drive
Caldecotte
Milton Keynes
MK7 8LF

For data protection enquiries, the live policy also gives the email address data@bigmarketing.co.uk.

Source: Big Marketing’s previous Privacy Policy. The original policy includes legacy references and should be reviewed before republishing.