Our pledge to you:
• Is to hold your data securely;
• Share only where you agree;
• Use your data to tailor the information we provide you and improve our services;
• Put you in control by allowing you to update, delete and access your data;
1. Who Are We?
This policy covers how we (dewinter Marketing) collect, use, disclose, transfer and store your data.
dewinter Marketing is a PR, Marketing, Social and Design Agency. Our main aim is to create high-end content marketing for clients and organisations, for their information/knowledge; communication; and promotional purposes.
‘We’ are De Winter Marketing Limited (“dewinter Marketing”) and we are the data controller for the purposes of the Data Protection Act 1998 and any amending and replacement legislation from time to time in force and the EU General Data Protection Regulation and any and all domestic legislation implementing the Regulation into English law.
Our corporate website www.dewinter.agency has details about who we are and what we do and details of how to contact us if you have any questions about privacy or data protection can be found below in the How to Contact Us section, below. The aim of the website is to ensure you experience what dewinter Marketing has to offer.
We must have a lawful basis to process your personal data, and this policy explains what our lawful basis is in respect of each purpose for which we keep and use information about you. Generally, we are allowed to process your personal data where it is necessary in connection with a contract between us (such as a contract to supply our products or services), where it is necessary in order for us to comply with our legal obligations, or where we have a legitimate interest to do so (but we will always consider whether your right to privacy overrides our interest).
2. What Personal Information Will dewinter Collect About Me?
• The information we collect (personal or not)
• Why we collect it
• How long we store it
• Our legal basis for processing your personal data
• Who if anyone we disclose your personal data to
• Your rights and how you can see, update or delete your personal data
• To make it easy to understand what data we collect about you we have grouped this policy into how you and others get information from us/ interact with us
• Our digital services. This includes our website and apps, managed by us.
• Services we use to communicate like social media
• Contact us directly, via email, phone, letter
• Meet us in person at events or in our offices
3. When You Use Our Digital Services Website Analytics
We use website log files, cookies, digital analytics (Google) and heat mapping software, to gather information about how people use this site
This section should be read in conjunction with section 9 “Joining Data And Profiling” below. Save as mention in section 9, we do not collect or store your personal information (e.g. your name or address) in our website analytics. However, we can recognise that behaviours belong to a single person. The information collected helps us investigate whether each website meets its users’ needs as well as to evaluate how each website can be improved. We store information about what pages you visit, how long you are on the site, how you got here and what you clicked on.
Website log files collect your IP address, when you visited the site and the pages you visited. IP address is a numeric code assigned to a device based on your geographical location. If for example you are in Manchester your IP address will be the same as other users accessing the internet from Manchester.
Digital analytics & doubleclick
Digital analytics tools such as Google Analytics and DoubleClick may be used to record anonymous user’s interaction with dewinter Marketing websites. This data may then be used to retarget users through advertising on other websites, therefore an individual’s behaviour on one of our websites may result in them being retargeted with advertising related to the pages they visited or actions they took on the site.
You may opt out of the DoubleClick cookie by visiting the Google advertising opt-out page or you may opt out of our use of Analytics by visiting the Google Analytics opt-out page.
Remarketing lists for search ads (rsla)
4. When You Provide Personal Data
When you make an enquiry with us, via the ‘Contact’ form on the website, an email is sent to one member of the dewinter Marketing Team. This email includes your email address, name and optional telephone number, along with the email contents. The email content is reviewed and responded to via email or telephone number, if provided.
We will only use the personal information we collect to process the enquiry.
By giving us your personal data we have a legitimate interest in processing it in order to pursue your enquiry. We retain personal data obtained from complaints for five years and then confidentially destroy it.
We have e-newsletters which are sent out on average, once a month. To provide these newsletters, we request contact details including but not limited to – your email address and first name.
We only send the newsletters to those who have opted in to receiving them so we only collect this data when we have your consent. It is retained on a secure database. We store this data for five years after your last communication with us, unless you withdraw consent. If you withdraw consent it will be deleted within a month.
Give us feedback (unprompted)
You do not need to include your name or contact details in order to provide us with general feedback or information about any technical problems on this site. You will however need to include an email address if you want us to reply to you. For some enquiries, contact details will be required.
We will only use any personal information provided to deal with your request and will not share it with other organisations. This data is stored for six months after we respond to your feedback, in case you ask for more detail or have other feedback you’d like to make.
We reserve, however the right to use non-personal information for business, research and marketing purposes. Uses include:
• An internal report listing technical problems on the website and solutions
• Marketing literature using quotes drawn from feedback about the site
Our legal basis for processing this data is our legitimate interests and in some circumstances, a legal obligation.
Give us feedback (when we ask you)
We may ask you for feedback whilst on the website. You only need to include an email address if you want us to reply to you or you would like to be included in future research.
If you consent to receive a response and/or participate in future research we will only store your email address and name in a secure database for five years after your last communication with us, unless you withdraw consent. If you withdraw consent, we will delete your data within a month.
5. When You Use Other Services (Like Facebook) To Interact With Us
When you use a social media platform, details about how your personal information is held, is described within the relevant social media policy, such as Facebook or Twitter.
Forms on social media
We manage our social media interactions ourselves and not with a third party.
If you send us a private or direct message via social media the message will be stored on that social media platform only. We will respond within 3 days and it will not be shared by any other organisations.
Our legal basis for processing this information is either contractual, in order to fulfil a service to you or in our legitimate interests in order to respond to your message or interaction.
6. When You Contact Us Directly
When you phone us
We do not collect caller line identification information when you call us. We will only collect personal information that you provide to us during the call.
When you email us
When you contact us via email, we will retain your email and our response to it for as long as the business issue remains.
When you write to us
When you contact us via post, we will retain your letter/postal address/personal information that you provide and our response to it for as long as the business issue remains. After this, the information will be confidentially destroyed.
In each of the cases set out in the section, the basis upon which collect and use the information will depend upon the nature of the your message to us, we may need collect and process your personal data in order to fulfil a contract and deliver a service to you, we may have a legitimate interest in collecting it in order to respond to your enquiry/complaint or you may have provided your consent in order for us to contact you for a specific purpose, for example to send you our newsletter.
7. When We Meet In Person
Provide feedback or make a complaint
If you want to provide feedback or make a complaint, you can so anonymously, or provide personal data so we can respond to you.
If you do provide personal data, we will request your full name and address. We will only use the personal information we collect to process the complaint and to check on the level of service we provide. We will process this data on the basis of our legitimate interests in order to respond to your complaint appropriately and where necessary take steps to address any concerns you have, depending upon the circumstance we may also have a legal obligation to retain the personal data concerned. We retain personal data obtained from complaints for five years and then confidentially destroy it.
Attend an event
When you attend an event we will only request your name and address in order to provide a service. You will be asked if you would like to join our database.
8. When We Contact You
We may email you regarding a contract or service or in response to a request, you have made. Your data will be stored for the purpose and time required to fulfil this.
We only send emails and post to you promoting dewinter Marketing where you have signed up to receive them. As such, if you subscribed to regular information via email before May 2018, and you have not asked us to stop and you have engaged with the content recently we will continue to contact you. We believe that it is in our legitimate interests to take this approach having regard to your rights to privacy. However, should you wish to stop receiving such marketing please click the unsubscribe link in the email or contact us using the contact information in the “How to Contact Us” section below.
We store this in a secure database for five years after your last communication with us, unless you withdraw consent. If you withdraw consent, we will delete your data within a month.
9. Joining Data And Profiling
We want to provide the best possible service to you. To achieve this we, where possible, join anonymous and personal data.
When you provide personal data via a form on the website, we collect a unique ID assigned to you by Google. We use this to combine your personal information with information from Google. The information we collect from Google includes how you reached our website and your behaviour whilst on the site. This applies to visits where you submit a form, previous and future visits, if available.
We may use this information to improve our service to you and to tailor the information we provide in future. We may also use it to understand the success of our marketing and make improvements to our services overall. Personal data is stored for as long as the purpose intended (see section: ‘When you provide personal data’).
Profiling is defined as under the General Data Protection Regulations as the automated processing of personal data to evaluate certain things about an individual. Profiling can be part of an automated decision-making-process. Automated decision-making is making a decision solely by automated means without any human involvement.
We may use these techniques to make the information in our emails, website or app more relevant to you. We therefore process this data for our legitimate interests. If you do not want us to use your data in this way, please email firstname.lastname@example.org. Likewise if you would like to see the data that we use for this purpose contact us.
10. Your Rights
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
You have the right to be informed
We have a legal obligation to provide you with concise, transparent, intelligible and easily accessible information about your personal information and our use of it. We have written this policy to do just that, but if you have any questions or require more specific information, you can get in touch using Contact Us section of the website.
You have the right to access your personal data
You have the right to ask us to confirm whether or not we hold any of your personal information. If we do, you have the right to have a copy of your information and to be informed of the following:
• Why we have been using your information
• What categories of information we were using
• Who we have shared the information with
• How long we envisage holding your information
In order to maintain the security of your information, we will have to verify your identity before we provide you with a copy of the information we hold.
The first copy of your information that you request from us will be provided free of charge, if you require further copies we may charge an administrative fee to cover our costs.
You have the right to correct any inaccurate or incomplete personal data
Where you have requested a copy of the information we hold about you, you may notice that there are inaccuracies in the records, or that certain parts are incomplete. If this is the case you can contact us so that we can correct our records.
You have the right to be forgotten
There may be times where it is no longer necessary for us to hold personal information about you. This could be if:
• The information is no longer needed for the original purpose that we collected it for
• You withdraw your consent for us to use the information (and we have no other legal reason to keep using it)
• You object to us using your information and we have no overriding reason to keep using it
• We have used your information unlawfully
• We are subject to a legal requirement to delete your information
In those situations you have the right to have your personal data deleted. If you believe one of these situations applies to you, please get in touch using our website.
You have the right to have a copy of your data transferred to you or a third party in a compatible format
Also known as data portability, you have the right to obtain a copy of your personal data for your own purposes. This right allows you to move, copy or transfer your personal data more easily from one IT system to another, in a safe and secure way.
If you would like us to transfer a copy of your data to you or another organisation in a structured, commonly use and machine-readable format, please contact us. There is no charge for you exercising this right.
You have the right to object to direct marketing
You can tell us at any time that you would prefer that we do not use your information for direct marketing purposes. If you would not like to receive any direct marketing from us, please contact us or use the links provided in any of our marketing communications, and we will stop sending direct marketing immediately.
You have the right to object to us using your information for our own legitimate interests
Sometimes, we use your personal information to achieve goals that will help us as well as you. This includes:
• When we tell you about services, products or events that are similar to ones that you have already engaged with, bought or attended
• When we use you information to help us make our business better
• When we contact you to interact, communicate or let you know about changes we are making
We aim to always ensure that your rights and information are properly protected. If you believe that the way we are using your data is not justified due to its impact on you or your rights, you have the right to object. Unless we have a compelling reason to continue, we must stop using your personal data for these purposes.
In order to exercise your right to object to our use of your data for the purposes above, please contact us.
You have the right to restrict how we use your personal data
You have the right to ask us to stop using your personal data in any way other than simply keeping a copy of it. This right is available where:
• You have informed us that the information we hold about you is inaccurate, and we have not yet been able to verify this
• You have objected to us using your information for our own legitimate interests and we are in the process of considering your objection
• We have used your information in an unlawful way, but you do not want us to delete your data
• We no longer need to use the information, but you need it for a legal claim
If you believe any of these situations apply, please contact us.
You have rights related to automated-decision making and profiling
Any automated decision-making or profiling we undertake is solely for the purpose of tailoring the information which we provide to you. Save as set out in section 9, we will not use automated decision-making or profiling to make any decisions which will have a legal effect upon you or otherwise significantly affect you, and you have the right not to be subject to such decisions. If you have any concerns or questions about this right, please contact us.
Read more about your individual rights on the Information Commissioner’s Office website.
11. Who do we share your personal information with?
Sharing your information within dewinter
We share the information that you provide to us with our staff so that we can provide our services to you.
There are certain exceptional circumstances in which we may disclose your information to third parties. This would be where we believe that the disclosure is:
• Required by the law, or in order to comply with judicial proceedings, court orders or legal or regulatory proceedings
• Necessary to protect the safety of our employees, our property or the public
• Necessary for the prevention or detection of crime, including exchanging information with other companies or organisations for the purposes of fraud protection and credit risk reduction.
• Proportionate as part of a merger, business or asset sale, in the event that this happens we will share your information with the prospective seller or buyer involved
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
12. Links To Other Websites
Please note that links from our website may take you to external websites which are not covered by this policy. We recommend that you check their privacy policies before submitting any personal information to such sites. We will not be responsible for the content, function or information collection policies of these external websites.
We keep our privacy notice under regular review. This privacy notice was last updated on 18 May 2018.
You can access this policy at any time through the link at the bottom of our websites and from any e-newsletters you are subscribed to.
14. How To Contact Us
dewinter Marketing tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.
This privacy notice was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of dewinter Marketing’s collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address below.
Email us email@example.com
Telephone: 01244 320667
Or write to:
Chester CH3 5TF
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