1. WHY THIS PRIVACY NOTICE IS IMPORTANT TO 'YOU', 'YOUR'.
This Privacy Notice is important because it explains to You how we may use the personal Information We collect and hold about You. Should you have any questions about this Privacy Notice please see the contact details at the bottom of the Notice.
2. UK DATA PROTECTION LAW.
Throughout this Privacy Notice we will talk about UK Data Protection Law, this predominantly means the Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003 as well as the EU GDPR regulations which came into force on 25th May 2018.
3. WHO WE ARE - 'WE', 'US', 'OUR'.
Sogar Marketing Ltd is a company registered in England & Wales under company number 12334652. Our registered office is: 27 Old Gloucester St, London, WC1N 3AX. Sogar Marketing Ltd are Data Controllers of the Personal Information held about You and accordingly are registered with the Office of the Information Commissioner (ICO) under the Data Protection Act 2018. Our registration number is ZA567714.
Our Data Protection Officer is Steven Holmes. He can be contacted by Email: email@example.com or Write to: The Data Protection Officer, Sogar Marketing Ltd, 27 Old Gloucester St, London, WC1N 3AX.
Sogar Marketing Ltd owns and operates a number of websites which include, but are not limited to: www.getya.co.uk / www.getyaoffers.co.uk / www.getyavouchers.co.uk / www.getyagifts.co.uk / www.getyainsurance.co.uk / www.getyaclaims.co.uk
4. OUR ETHOS
We want this Privacy Notice to be honest, open and transparent because We know that Your privacy, and the protection of Your Personal Information is important to You. We take every reasonable precaution to ensure compliance with UK Data Protection Law. Further information about Your rights under UK Data Protection Law is available from the Office of the Information Commissioners (ICO) Website. If You wish to find out more please visit: www.ico.org.uk We do not want to collect or hold any Personal Information about You that You do not wish or intend to give. That is why it is important that You read this Privacy Notice carefully.
5. WHAT INFORMATION DO YOU HOLD ABOUT ME?
We collect three categories of Personal Information about You; Identifiable Information, Anonymous Information and Lifestyle Information.
6. WHERE IS YOUR PERSONAL INFORMATION HELD?
The Personal Information We collect will be held by Us on Our database which is hosted on secure servers based in the European Economic Area ("EEA"). We use a variety of physical and network security technologies and procedures to help protect Your information from unauthorised access, use, or disclosure. We also operate stringent people processes which means that only a limited number of people in our organisation have access to the information contained in the database. We have established procedures to cope with events that happen that are beyond Our control. We are also certified as meeting the requirements of ISO 27001:2013 in the provision of data cleansing and the management of consumer lists.
7. HOW DO WE COLLECT YOUR PERSONAL INFORMATION?
We collect Personal Information about You in several ways including the following:
8. WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?
Data, like many other products and services can be sold or licensed. When We license data to third parties We call them Clients. We work hard to ensure that We only deal with reputable Clients who like Us operate in accordance with UK Data Protection Law. We enforce this through Our contractual relationships with Our Clients in which they undertake to operate in accordance with the UK Data Protection Law and continue to enforce the rights You have. More information about those rights is set out in this Privacy Notice. Sometimes Our Clients operate in countries outside of the European Economic Area (EEA) who operate under different data protection laws. Where this happens We enforce additional contractual provisions to ensure they provide an adequate level of protection as required by UK Data Protection Law.
Here is a list of business categories in which Our Clients operate. Depending on what personal information We hold about You Our Clients may contact You by post, telephone or email for direct marketing, debt collection and tracing.
For a more detailed list of the types of companies that fall into each business category please click on the category name.
|Category||Description and examples of the business types within each category|
|General & lifestyle||
9. WHAT DO WE USE YOUR PERSONAL INFORMATION FOR?(OUR PURPOSE FOR PROCESSING YOUR DATA)
We Use Your Personal Information to:
We will share your data with the Marketing Services Providers listed HERE. who will use it as an input to products and services to help organisations better understand the likely characteristics of their customers; communicate with them more effectively; and find others like them across a range of marketing channels. In sharing your data with them, we rely on a lawful ground called 'legitimate interest', as our business depends on our ability to partner with third parties who process personal data for marketing-related reasons. They will also share your data with their customers which may mean that you receive tailored advertising via direct mail or when you visit a website. To understand more, including how to exercise your data protection rights in relation to their use of your data, please click through to the websites of the companies LISTED.
We process data under the following lawful basis’:
Consent: where we have Your consent to receive marketing communications for compatible products and services through specified channels.
Legitimate Interest: there is a legitimate interest for ourselves and our clients in processing data to provide products and services to consumers through marketing campaigns. On a case by case basis, a balancing test is performed to ensure that we balance the potential impact of the campaign on the consumer and their rights of processing data, with the interests of ourselves and our clients.
Other business activities: We also rely on legitimate interest if we are processing your personal details in a business capacity, such as: conducting market research; unsubscribing you from our databases; adding you to our suppression file; sending you newsletters; or communicating with you about an enquiry you have made”
Legal Obligation: we may need to process data under this basis, for example where a Subject Access Request (SAR) is made to remove or amend details, this data will be processed under the lawful basis of Legal Obligation.
We will use the following legal basis for each activity listed:
|Purpose||For use by ourselves||For use by third parties|
|Marketing – by email||Consent||Consent where organisation is in named business category listed in section 8.|
|Marketing – by post and telephone marketing||Legitimate Interest||Legitimate Interest|
|Tracing, ID verification and credit reference||Legitimate Interest||Legitimate Interest|
|Profiling and analytics||Legitimate Interest||Legitimate Interest|
10. WHAT IF I DON'T WANT TO RECEIVE ANY MORE INFORMATION FROM YOU?
You can opt out anytime from Us holding Your Personal Information on Our database by unsubscribing HERE
We call this process suppression. This is standard marketing industry practice approved by the ICO and means that just enough information about You is retained to ensure that Your wishes are respected. Suppressing, rather than deleting, Your details has the objective of preventing Your records being reintroduced into Our database in the future. Following suppression of Your details, marketing communications should stop within a maximum period of twenty eight days for electronic communications and two months for postal communications.
11. WHAT OTHER RIGHTS DO I HAVE?
You have the right to withdraw consent to the processing of Your information at any time. This includes the right to withdraw processing based on legitimate interests.
You have the right to be forgotten / total erasure. This gives You the right to request Your information be removed completely. We would not recommend this but would strongly suggest the action referred to above in point 10 as complete erasure of Your data could lead to Us loading Your information again.
You have the right to know what Personal Information We hold about You on Our database. If You would like to know more about this process and what We need from You to meet Your request please follow the link HERE
You have the right to request that Your data be transmitted directly to another data controller (Known as right to data portability).
You have the right to lodge a complaint with a supervisory authority, if You are not satisfied with the way we have dealt with your complaint: The Information Commissioners Office
12. OUR GENERAL DISCLOSURE TO YOU.
Sogar Marketing Ltd will retain Your details for as long as they are required for the purposes for which they were collected. In addition only while Your data is valid, accurate and up to date or until such time that You choose to unsubscribe directly with Us or via one of our partners who are making use of Your details provided by Us.
As an absolute maximum we will only hold Your data which is used under the legal basis of ‘Legitimate Interests’ for a maximum of ten years. If Your data is held under the legal basis of ‘Consent’ it will also be held for a maximum of ten years. However, where We hold an email address for You We will maintain regular contact and will ensure that You have the opportunity to opt out at least once every six months.
You can opt out anytime from Us holding Your Personal Information on Our database by unsubscribing HERE
Our backup policy is to backup data daily, overwriting the previous days back up. One backup each month will then be held offsite for a period of six months before being securely deleted.
13. IP ADDRESSES AND COOKIES.
14. THE SALE OR ACQUISITION OF Sogar Marketing Ltd OR ITS ASSETS.
If Sogar Marketing Ltd or any of its assets are acquired by or merged with another entity, your Personal Information may be one of the transferred assets. If We choose to sell or transfer Our assets, We may choose to retain a copy of Your information post sale or merger.
15. CHANGES TO THIS PRIVACY NOTICE
We will occasionally update this Privacy Notice. We will tell You about these changes by posting a notification at the foot of Our websites. If the changes We make to the Privacy Notice in any way affect Your rights under UK Data Protection Law, especially in relation to how We collect and hold information about You We will contact You to explain the changes and obtain Your permission to do so.
16. CONTACT US.
REMOVE MY DETAILS If You have any comments or queries in connection with this Privacy Notice, please contact SOGAR MARKETING Ltd by: Email at firstname.lastname@example.org ; or Write to: The Data Protection Officer, Sogar Marketing Ltd, 27 Old Gloucester St, London, WC1N 3AX If you have any queries about data usage please email us at email@example.com
This Privacy notice was last updated on 01/05/2020
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