Marketing Privacy Policy

Marketing Privacy Policy

Trade Interchange Limited (“We”) are committed to protecting and respecting your privacy.

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practises regarding your personal data and how we will treat it.

1.Introduction
1.1We are committed to safeguarding the privacy of individual we conduct direct marketing to.
1.2This policy applies where we are acting as a data controller with respect to the personal data of direct marketing activities; in other words, where we determine the purposes and means of the processing of that personal data.
1.3In this policy, “we”, “us” and “our” refer to Trade Interchange Limited. For more information about us, see Section 8.
2.How we use your personal data
2.1In this Section 2 we have set out:
 
(a)the general categories of personal data that we may process;
(b)in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c)the purposes for which we may process personal data; and
(d)the legal bases of the processing.
2.2We may process data about your business contact details and job role for use of direct marketing activities (“usage data”). The usage data may include your email address, job title, name of employer, postal address of employer, business telephone number and LinkedIn profiles (where a business email address has been used). The source of the usage data is purchased data lists. The data lists have been purchased from by:
 
(i)Market Republic Ltd, Antifašističke borbe 6/13, 11070 New Belgrade, Serbia
(ii)Datamatics Business Solutions Limited, Plot No. B-5, Part B Cross Lane, MIDC, Andheri (E), Mumbai 400 093, India
(iii)Caterlyst Limited, Caterlyst Limited, Suite 14, Hercules Way, Leavesden Park, Watford, Herts WD25 7GS
 The source of the usage data is recorded against each individual record. You have the right to contact the data provider and request your removal and amendment from the data lists in addition to contacting us for the removal from our lists.
 This usage data may be processed for the purposes of direct marketing. The legal basis for this processing is our legitimate interests, namely electronic and direct mail marketing campaigns.
 We will process your data under the basis of legitimate interests as we believe those individuals in our database would reasonably expect to receive communications about our product and services given their job role and business activities.
 We will not engage in the use of automated profiling of individuals based on any other factors than whether they are currently in a role where the use of our products and services would add value in the organisation.
2.3We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.
2.4We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters, requesting information or demonstrations or via business card (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
2.5We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.6In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
2.7Please do not supply any other person’s personal data to us, unless we prompt you to do so.
3.Providing your personal data to others
3.1We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
3.2We may disclose contact details to our suppliers or subcontractors identified below insofar as reasonably necessary for the purposes of customer relationship management and direct electronic marketing campaigns.
 
(i)Salesforce.com EMEA Limited, Village 9, Floor 26 Salesforce Tower, 110 Bishopsgate, London, UK EC2N 4AY
(ii)Mailchimp, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta GA 30308 United States
3.3In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4.International transfers of your personal data
4.1In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
4.2Trade Interchange office facilities are situated in the European Economic Area (EEA).
4.3The hosting facilities for our website and your data are situated in the European Economic Area (EEA).
4.4Our CRM and direct email marketing sub-contractors are situated in the United States of America. The European Commission has made an “adequacy decision” with respect to the data protection laws of this country. Transfers to this country will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from https://ec.europa.eu/info/law/law-topic/data-protection_en.
4.5You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
5.Retaining and deleting personal data
5.1This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.3We will retain your personal data as follows:
 
(a)Contact details will be retained for a maximum period of two years following the initial collection before obtaining consent to keep the information.
5.4Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
6.Amendments
6.1We may update this policy from time to time by publishing a new version on our website.
6.2You should check this page occasionally to ensure you are happy with any changes to this policy.
6.3We may notify you of changes to this policy by email.
7.Your rights
7.1In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
7.2Your principal rights under data protection law are:
 
(a)the right to access;
(b)the right to rectification;
(c)the right to erasure;
(d)the right to restrict processing;
(e)the right to object to processing;
(f)the right to data portability;
(g)the right to complain to a supervisory authority; and
(h)the right to withdraw consent.
7.3You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
7.4You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
7.5In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
7.6In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
7.7You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
7.8You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
7.9You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
7.10To the extent that the legal basis for our processing of your personal data is:
 
(a)Legitimate interest; or
(b)that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
 and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
7.11If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
7.12To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
7.13You may exercise any of your rights in relation to your personal data by contacting us by email at dataprotection@stage.tradeinterchange.com
8.Our details
8.1This Web Application is owned and operated by Trade Interchange Limited.
8.2We are registered in England and Wales under registration number 04127915 and our registered office is at Kildale House, 2 Dukes Court, Teesside Industrial Estate, Stockton-on-Tees, TS17 9LR.
8.3Our principal place of business is the registered address in 8.2
8.4You can contact us:
 
(a)by post, to the postal address given above;
(b)by email, dataprotection@stage.tradeinterchange.com
9.Data protection officer
9.1

Our data protection officer’s contact details are: dataprotection@stage.tradeinterchange.com

 

 

Document Ref: ISMS

Version: 2.0

Date of issue: 22/05/18

1. Introduction

1.1 We are committed to safeguarding the privacy of individual we conduct direct marketing to.

1.2 This policy applies where we are acting as a data controller with respect to the personal data of direct marketing activities; in other words, where we determine the purposes and means of the processing of that personal data.

1.3 In this policy, “we”, “us” and “our” refer to Trade Interchange Limited. For more information about us, see Section 8.

2. How we use your personal data

2.1 In this Section 2 we have set out:

(a) the general categories of personal data that we may process;

(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;

(c) the purposes for which we may process personal data; and

(d) the legal bases of the processing.

2.2  We may process data about your business contact details and job role for use of direct marketing activities (“usage data”). The usage data may include your email address, job title, name of employer, postal address of employer, business telephone number and LinkedIn profiles (where a business email address has been used). The source of the usage data is purchased data lists. The data lists have been purchased from by:

(i) Market Republic Ltd, Antifašističke borbe 6/13, 11070 New Belgrade, Serbia

(ii) Datamatics Business Solutions Limited, Plot No. B-5, Part B Cross Lane, MIDC, Andheri (E), Mumbai 400 093, India

(iii) Caterlyst Limited, Caterlyst Limited, Suite 14, Hercules Way, Leavesden Park, Watford, Herts WD25 7GS

2.3 We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.

2.4  We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters, requesting information or demonstrations or via business card (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.

2.5 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

2.6  In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

2.7  Please do not supply any other person’s personal data to us, unless we prompt you to do so.

3. Providing your personal data to others

3.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

3.2 We may disclose contact details to our suppliers or subcontractors identified below insofar as reasonably necessary for the purposes of customer relationship management and direct electronic marketing campaigns.

(i) Salesforce.com EMEA Limited, Village 9, Floor 26 Salesforce Tower, 110 Bishopsgate, London, UK EC2N 4AY

(ii) Mailchimp, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta GA 30308 United States

3.3  In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4. International transfers of your personal data

4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

4.2 Trade Interchange office facilities are situated in the European Economic Area (EEA).

4.3 The hosting facilities for our website and your data are situated in the European Economic Area (EEA).

4.4 Our CRM and direct email marketing sub-contractors are situated in the United States of America. The European Commission has made an “adequacy decision” with respect to the data protection laws of this country. Transfers to this country will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from here

4.5  You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

5. Retaining and deleting personal data

5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

5.3 We will retain your personal data as follows:

(a) Contact details will be retained for a maximum period of two years following the initial collection before obtaining consent to keep the information. 

5.4  Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

6. Amendments 

6.1 We may update this policy from time to time by publishing a new version on our website.

6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

6.3 We may notify you of changes to this policy by email.

7. Your rights

7.1 In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

7.2 Your principal rights under data protection law are:

(a) the right to access;

(b) the right to rectification;

(c) the right to erasure;

(d) the right to restrict processing;

(e) the right to object to processing;

(f) the right to data portability;

(g) the right to complain to a supervisory authority; and

(h) the right to withdraw consent. 

7.3  You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

7.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

7.5  In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

7.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

7.7  You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

7.8  You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

7.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

7.10 To the extent that the legal basis for our processing of your personal data is:

(a) Legitimate interest; or

(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others. 

7.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

7.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

7.13 You may exercise any of your rights in relation to your personal data by contacting us by email at:

dataprotection@stage.tradeinterchange.com

8. Our details

8.1 This Web Application is owned and operated by Trade Interchange Limited.

8.2 We are registered in England and Wales under registration number 04127915 and our registered office is at Kildale House, 2 Dukes Court, Teesside Industrial Estate, Stockton-on-Tees, TS17 9LR.

8.3 Our principal place of business is the registered address in 8.2

8.4 You can contact us:

(a) by post, to the postal address given above;

(b) by email.

9. Data protection officer

Our data protection officer’s contact details are:

dataprotection@stage.tradeinterchange.com

 

 

Document Ref: ISMS

Version: 2.0

Date of issue: 22/05/18

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