Adtrak Media Ltd understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, adtrak.co.uk (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
1. Definitions and Interpretation
1. In this Policy, the following terms shall have the following meanings:
- “Account” means an account required to access and/or use certain areas and features of Our Site;
- “Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 13, below;
- “Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
- “Personal Data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and
- “We/Us/Our” means Adtrak Media Ltd of Level 3, Chapel Quarter, Maid Marian Way, Nottingham, NG1 6HQ.
2. Information About Us
1. Our Site is owned and operated by Adtrak Media Ltd of Level 3, Chapel Quarter, Maid Marian Way, Nottingham, NG1 6HQ.
3. What Does This Policy Cover?
4. Your Rights
1. As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
- The right to be informed about Our collection and use of personal data;
- The right of access to the personal data We hold about you (see section 12);
- The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);
- The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);
- The right to restrict (i.e. prevent) the processing of your personal data;
- The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
- The right to object to Us using your personal data for particular purposes; and
- Rights with respect to automated decision making and profiling.
2. If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
3. For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
5. What Data Do We Collect?
- Contact information such as email addresses and telephone numbers
- Demographic information such as postcode, preferences, and interests
- IP address
- Web browser type and version
- Operating System
- A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to
- Geographic Location
- We record calls to the telephone numbers on Our Site and any telephone numbers on our print literature.
6. How Do We Use Your Data?
1. All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.
2. Our use of your personal data will always have a lawful basis. If you are an individual, our lawful basis for using your personal data will generally be for the performance of Our performance of a contract with you. Where we do not have contract with you directly or we are using personal data relating to you for reasons outside of our contract with you, such as the development and promotion of our services, our legal basis will be the legitimate interests of our business and the legitimate interests of our customers and/or partners’ businesses. We will only uses personal data for our, or our customers or partners’, legitimate interests where your rights and interests do not override those legitimate interests. Where required or appropriate (e.g. for non-essential cookies and some email marketing – see below), we will also seek your consent to use personal data relating to you. Where we seek your consent we will always provide you with more information about why we are seeking your consent and what we intend to do with personal data relating to you. If we rely on your consent, you have the right to withdraw that consent at any time.
3. With your consent and/or where permitted by law (e.g. where you have bought a product or service from us), We may also use your data for marketing purposes which may include contacting you by email, telephone, and/or post with information, news and offers on Our services. We will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
4. More generally, we will use personal data relating to you for the administration, development and promotion of Our Site and the services we provide. Specifically, We may use personal data relating to you for the following purposes:
- Providing and managing your Account
- Providing and managing your access to Our Site
- Replying to emails from you and checking email *opens*
- Analysing your use of Our Site to enable Us to continually improve Our Site and your user experience;
5. We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected.
7. How and Where Do We Store Your Data?
We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
Some of our service providers are based outside of the UK and the European Economic Area. Where your personal data is transferred outside of the UK and/or EEA, we ensure that the country to which the data is transferred is recognised by the UK and European Union as providing an adequate level of data protection or we put in place standard contractual clauses to safeguard your personal data. Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
8. Do We Share Your Data?
To help provide, develop and promote Our Site, we share personal data with and receive personal data from the following types of service provider –
- Payment processors
- Fraud and credit risk service screening providers
- Advertising partners
- Analytics service providers
- Cloud providers
- Software providers
- IT providers
- Telephone call recording providers
- Professional services (for example, accountants and lawyers)
In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority.
9. What Happens If Our Business Changes Hands?
Personal data may also be shared with potential buyers, targets or partners as part of any transfer described under section 9.1 above.
In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.
10. How Can You Control Your Data?
In addition to your rights under the GDPR, set out in section 4, when you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and by managing your Account).
You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
11. Your Right to Withhold Information
You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
Please note that if you do withhold data from us we may not be able to complete the terms of our contract with you and/or provide any services you have asked for.
12. How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at firstname.lastname@example.org or using the contact details below in section 14.
You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
14. Contacting Us