This Privacy Policy sets out the data processing practices of Propellernet Ltd. Please note that all data thus captured will be used and held in accordance with the requirements of the Data Protection Act 2018.
Propellernet is a digital marketing agency offering a range of services including SEO, PR, content, creative and media buying, planning and strategy services to clients.
Propellernet is the controller and our Data Protection Officer is James Sanford. If you have any requests concerning your personal data or any queries with regard to how we handle your data you can contact the DPO by phone on 01273 760 950, email [email protected] or write to us at James Sandford, Propellernet, Castle Square House, 9 Castle Square, Brighton, BN1 1EG.
Purpose of processing your personal data:
Except where required by law, we only use the personal data you provide for the following purposes:
- To provide you with information or services you have enquired about
- Respond to your requests and feedback
Under data protection law we are required to advise you on the legal basis for processing your personal data. For the most part, the processing of your personal data is based either on a) your individual legitimate interests related to us providing you with the information or services you have requested, or b) your consent, where requested.
We set out further information about the purposes for which we use your personal data and the legal basis we rely on for its use below. Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.
Making an enquiry: In this instance, the purpose of processing is to either deal with your enquiries or requests or to provide you with information about our products and services. The legal basis that we use for data processing when you make an enquiry is legitimate interests. When dealing with your query, we will respond by email/phone and also ask if you would like to be kept up to date with information about Propellernet products and services, and also share a copy of our privacy policy.
Marketing and communications: In this instance, the purpose of processing is to update you about relevant marketing (such as events) and other information about Propellernet and our products and services. If you are a client of Propellernet, the legal basis we use for this is legitimate interest. We will never share your details with third parties.
If you are not a client of Propellerenet, the legal basis that we use for this data processing is consent. In this instance, we will always ask you if you are happy for us to keep you updated about Propellernet products and services, and not those of a third party. We will never share your details with third parties.
- Marketing
We would like to use your personal data to send you details of products or services that we offer that we have identified as likely to be of interest to you. We will only send you information in line with the preferences you indicated when you provided the personal data.
If at any point you would like to opt-out of receiving communications from us, or would like to change the channels (such as email or post) that we use to contact you, please contact [email protected] or write to us at Winnie Mann, Propellernet, Castle Square House, 9 Castle Square, Brighton, BN1 1EG .
- Recipients/categories of recipients
In carrying out our business including our obligations to you, we may use sub-contractors. These will be carefully selected partners necessary for carrying out our business and obligations to you. We will ensure that they respect your privacy and abide by all data protection laws.
- Retention periods
We will keep your personal data in connection with the services/products you have bought for as long as is necessary for the relevant service, in accordance with our legal obligations. We need to retain this data for our own accounting purposes and for legal and tax purposes. From the point of payment of the final invoice Propellernet will use client data solely in relation to the legitimate interest of communication about Propellernet products and services.
In terms of personal data we use for marketing, we will keep this data for as long as we are able to market to you and if you withdraw your consent or opt-out of marketing communications, we will keep your contact details only to ensure that we do not contact you again for marketing purposes.
- Data subject’s rights
You have rights in respect of your personal data. We will need to confirm your identity before we can consider your request so, if you wish to exercise any of these rights, we will official ID documents such as passport or driving licence. We will also require proof of address. Suitable forms of ID include bank statements/utility bills or other documentation that is dated within the last six months.
The right to be informed – you have the right to be told about the collection and use of the personal data you provide. This privacy policy sets out the purpose for which we process your personal data, how long we will keep your data, who we will share your data with. If you have any questions on how and why we process your data please contact the DPO. If you want to know more about this right, the ICO has more guidance on their website: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-be-informed/
Right of access – you have the right to know whether we are processing your personal data, and to a copy of that data. We would need as much information as possible to enable us to locate your data. We will respond to your request within 28 days of receipt of your request. If you want to exercise this right, please contact the DPO at the contact details above. If you want to know more about this right, the ICO has more guidance on their website: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-of-access/
Right to rectification – you have the right to have any incorrect personal data corrected or completed if it is incomplete. You can make this request verbally or in writing. We will need as much information as possible to enable us to locate your data. We will look at any request and inform you of our decision within 28 days of receiving the request. If you want to exercise this right, please contact the DPO at the contact details above. If you want to know more about this right, the ICO has more guidance on their website: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-rectification/
Right to erasure – this right, often referred to as the right to be forgotten allows you to ask us to erase personal data where there is no valid reason for us to keep it. We will look at any request and inform you of our decision within 28 days of receiving the request. If you want to exercise this right, please contact the DPO at the contact details above. If you want to know more about this right, the ICO has more guidance on their website: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-erasure/
Right to restrict processing – you have the right to ask us to restrict processing of your data. We will look at any request and inform you of our decision within 28 days of receiving the request. If you want to exercise this right, please contact the DP at the contact details above. If you want to know more about this right, the ICO has more guidance on their website: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-restrict-processing/
Right to data portability – you have the right to move, copy or transfer your personal data from one IT environment to another. This right applies to data that you have provided to us and that we are processing on the legal basis of consent or in the performance of a contract and that processing is by automated means. We will respond to your request within 28 days of receipt of your request. If you want to exercise this right, please contact the DPO at the contact details above. If you want to know more about this right, the ICO has more guidance on their website: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-data-portability/
Right to object – you have the right to object to our processing of your personal data based on (i) legitimate interests, or for the performance of a task in the public interests/exercise of official authority (including profiling); (ii) direct marketing (including profiling); and (iii) for purposes of scientific/historical research and statistics.
- Legitimate interests/legal task – your objection should be based on your particular situation. We can continue to process the data if we can demonstrate compelling legitimate grounds which override your interests.
- Direct marketing – you have an absolute right to ask us to stop processing for the purposes of direct marketing. We will action your request as soon as possible.
- Scientific/historical research and statistics – your objection should be based on your particular situation. If we are conducting research where the processing is necessary for the performance of a public task, we can refuse to comply with your objection.
If you want to exercise this right, please contact the DPO at the contact details above. If you want to know more about this right, the ICO has more guidance on their website: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-object/
Rights relating to automated decision making including profiling – you have the right in respect of automated decision making, including profiling. Where we carry out solely automated decision making, including profiling, which has legal or similarly significant effects on you, we can only do this if it is in connection with a contract with you, we have a right under law or you have provided your explicit consent. We will tell you if this happens and tell you how you can request human intervention or challenge the decision. If you want to exercise this right, please contact the DPO at the contact details above. If you want to know more about this right, the ICO has more guidance on their website: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/rights-related-to-automated-decision-making-including-profiling/
- Processing based on consent
Where we process your personal data based on your consent you have the right to withdraw that consent at any time without reason. You can opt-out by using the unsubscribe/opt-out in any marketing we send you and you can contact the DPO at the contact details above.
- The right to lodge a complaint to the supervisory authority
If you are unhappy with any aspect of our handling of your data you can make a complaint to the Information Commissioner’s Office – https://ico.org.uk/concerns/