Privacy Policy relating to Marketing
To support the marketing efforts of the firm, Folded Wing collects and processes personal data relating to your interests, preferences and interactions with the firm.
1. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
• Identity Data includes first name, maiden name, last name, username or similar identifier, title.
• Contact Data includes office address, email address and telephone numbers.
• Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
• Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.
2. How your personal data is collected and stored
We use different methods to collect data from and about you including through:
• Direct interactions. You may give us your Identity and contact data by filling in forms or by corresponding with us in person, by post, phone, email or otherwise. This includes personal data you provide when you:
– apply for our services;
– subscribe to our service or publications;
– request marketing to be sent to you;
– enter a competition, promotion or survey; or
– give us some feedback.
• Automated technologies or interactions. As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
– Technical Data from analytics providers; and
– Identity and Contact Data from publicly available sources such as LinkedIn and company websites.
3. How we use your personal data and the legal basis for doing so
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• where we need to perform the contract we are about to enter into or have entered into with you;
• where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests; and
• where we need to comply with a legal or regulatory obligation.
Please refer to the ICO website (www.ico.org.uk) or refer to the glossary to find out more about the types of lawful basis that we will rely on to process your personal data.
You have the right to withdraw consent for marketing purposes at any time by contacting us at [email protected], or by unsubscribing via the unsubscribe link in any of our newsletter emails.
4. Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal grounds we are relying on to process your personal data where more than one ground has been set out in the table below.
|
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
|
To manage our relationship with you which will include: (a) Notifying you about changes to our terms and privacy policy (b) Asking you to leave a review or take a survey |
(a) Identity |
(a) Performance of a contract with you (c) Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services. |
|
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity (b) Contact |
(a) Necessary for our legitimate interests, for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation restructuring exercise. (b) Necessary to comply with a legal obligation. |
|
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences |
(a) Technical (b) Usage |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
|
To make suggestions and recommendations to you about services that may be of interest to you |
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
|
|
|
|
5. Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
5.1. Third-party marketing
We do not currently engage with third parties to distribute marketing material. However, we will get your express opt-in consent before we share your personal data with any company outside of Folded Wing for marketing purposes.
5.2. Opting out
You can ask us or third parties to stop sending you marketing messages at any time by contacting us.
Where you opt out of receiving these marketing messages you may still receive communications from us in relation to a service purchase, service experience or other transaction that you have entered into with us.
5.3. Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.
6. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table above.
• Internal Third Parties as set out in the glossary.
• External Third Parties as set out in the glossary.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
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.
7. International transfers
We do not currently transfer your personal data outside the European Economic Area (EEA). Were we to do so, transfer would always be made subject to appropriate technical and legal measures.
8. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. How long we retain and use personal data of marketing contacts
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Data for marketing purposes is retained for as long as it is relevant unless consent is withdrawn as outlined above.
If consent is withdrawn records will be deleted with the exception of the email address which will be retained on an unsubscribed list to ensure we do not contact you further.
In some circumstances you can ask us to delete your data: see Request erasure in our glossary
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
