Our privacy promise

This is the general privacy policy for Circdata Ltd, and for the range of products and services we provide to our clients.

At Circdata we collect different types of information for six main reasons:

  1. To fulfil contracted services.
  2. To manage event registration services on behalf of our clients.
  3. To manage magazine subscription services on behalf of our clients.
  4. To keep our clients up-to-date with the products and services we offer
  5. Where we have an appropriate legal basis for processing, to market products and services to them.
  6. To maintain records of our current and past employees

Some of our services may have their own specific privacy policy because the services we provide in that instance may be on behalf of a client acting as a data processor. So please do check when you sign up or register just to be sure you know what is happening to your information.

To make it easier for you to read this policy, below are a number of links that will take you directly to particular sections.

  1. About us
  2. Children’s data
  3. Updating your personal information
  4. Who we share data with
  5. Use of Cookies
  6. Legal information and how to contact us
  7. Changes to this privacy policy

 

1. About us

The protection of your privacy and personal information is important to us. We make sure that not only do we have appropriate security measures in place, but that any other organisation we work with to provide a service also meets the same standard as us.

We will respect your privacy. You should receive marketing emails only from us. We will make sure that you always have a choice, and that the places where you can exercise this choice are presented clearly and at an appropriate time.

We will make it clear at the point when we request your information, what we are collecting it for and how we are going to use it.

We will collect and use your personal information only if we have your permission or we have sensible business reasons for doing so.

We will minimise the amount of information we collect from you to what we need to deliver the product and services you have requested.

We will be clear in our dealings with you as to what information about you we will collect and how we will use it.

We will use personal information only for the purposes for which it was originally collected and we will make sure we delete it securely.

Our websites are accessible via the internet. Please remember that if you post any comments or links on any of our sites that they can be read and accessed by anyone and everyone.

If we or our service providers transfer any information out of the European Economic Area (EEA), it will only be done with the relevant legal instruments or permissions being in place.

What information do we collect about you and how do we use it?

We collect information on you:

  • when you contact us for information
  • when you work with us in a commercial capacity
  • when you sign up for a newsletter
  • when you download an app
  • through cookies
  • if you choose to reveal information in postings
  • if you complete your details on research questionnaires

Certain services that we provide as data processors may involve us collecting data on behalf of a client in order to deliver contracted registration or subscription services. This may also apply to certain app solutions. In these cases, please refer to the individual privacy policy of the data controller for full details of how they treat your data.

What legal bases do we use for processing your data?

We use different legal bases depending upon the purpose for collecting your data in the first instance.

  • For all data collected to sign up for a product and service such as a newsletter we process the data using Legitimate Interest, i.e. you are able to access an extensive range of information in exchange for supplying your information, and we have a relationship where the balance of benefit is in your favour.
    You always have a choice in the management of your data in this manner and can opt out of processing under this basis at any time.
  • Where you provide data in the course of a contractual agreement we process your data under Contract, i.e. your data is necessary for the fulfilment of the service.
    Any additional contact, i.e. telling you about another product or service closely related to the product or service you have contracted is managed under legitimate interest.
  • Any secondary processing of your data, i.e. transfer to third countries, is managed under Consent.

Under the terms of currently Applicable Laws, we will always make it as easy as possible for you to opt out of unwanted processing, providing it does not restrict our ability to provide you with the service you have requested.

Profiling

From time to time we may use some elements of the data you supply to target the messages we send you.  For example we may use your company location to send you a relevant news story.

None of this information is collated by wholly automated means and the rights and freedoms of the data subject are safeguarded by suitable measures.

How long do you hold on to my data?

Where there is a statutory requirement to retain data for a specified period, we are obliged to comply with these regulations.

We keep client contact information for the duration of an engagement, plus an additional 24 months. Data collected to fulfil newsletter requests and other marketing activities is retained for 24 months beyond the last engagement.

After this, data is managed to ensure that it is either erased from our system, minimised and retained for legal reasons or pseudonymised and retained on a global suppression list to ensure that you do not receive unwanted messaging from us.

2. Children’s data

We do not knowingly target, collect or store any personal information about children under the age of 16.

3. Updating your personal information

Under current data privacy legislation, you have the right to rectify, erase or restrict the processing of your data without undue delay. You may also request access to the data we hold on you.

To do this or to update your personal information at any time please contact our Database Manager  by email databasemanager@circdata.com or telephone +44 (0) 1635 869868

4. Who we share data with

We do not sell or share your data at any time for marketing purposes.

Information collected on behalf of client organisations is governed by their own privacy policies.

We can access and release personal information to keep to relevant laws and government requests, to operate our systems properly and to protect both us and our users.

Any other organisations who access your information in the course of providing services on our behalf will be governed by strict contractual restrictions to make sure that they protect your information and keep to data-protection and privacy laws which apply. We may also independently audit these service providers to make sure that they meet our standards. We may use service providers to help us run these sites (or services available on the sites), some of whom may be based outside the EEA, in this instance any data transfer will only occur by one of the three legal instruments determined by the EDPB.

5. Use of Cookies

We use cookies for a number of reasons.

  1. For statistical purposes to track how many users we have and how often they visit our websites. We collect information listing which of our pages are most frequently visited, and by which types of users and from which countries.
  2. You can turn cookies off but if you do this, you may not be able to use all services on our websites.

For more information about cookies and managing them, including how to turn them off, please visit our page on Cookies

By using the sites you are agreeing to the use of cookies as described.

Google Analytics

We use Google Analytics on our sites for anonymous reporting of site usage. If you would like to opt-out of Google Analytics monitoring your behaviour on our sites please use this link https://tools.google.com/dlpage/gaoptout

6. Legal information and how to contact us

Under the currently Applicable Laws we have to say who the ‘data controller’ is for Circdata Ltd products and services provided via our products and services. The data controller is the organisation responsible for protecting information and, in our case, is Circdata Ltd, a company registered in England and Wales with registration number 04599812 and registered address Unit K, Venture House, Bone Lane, Newbury RG14 5SH.

We are registered with the Information Commissioner's Office as a Data Controller: Registration number Z8078953

If you would like access to or a copy of the personal information we hold about you, to request a correction, or have any questions about how we may use it or to make a complaint, please contact the Database Manager by email databasemanager@circdata.com or telephone 01635 869868.

Requests will be dealt with by the Database Manager, and will be responded to within a reasonable period, not longer than 30 days.

If you are not satisfied with the way your request was handled, you have the right to lodge a complaint with the supervisory authority – details of which are given below:
Information Commissioner’s Office
https://ico.org.uk/concerns/
Telephone: +44 303 123 1113

7. Changes to the privacy policy

If we make changes to our privacy policy we will show you what they are here. If these changes are significant, we may also choose to email relevant individuals with new details. If we are required by law, we will obtain your consent to make these changes.

Changes to this policy by date

February 2018 – New company privacy policy created.