Last updated 23 February 2021
This privacy notice explains how we, Pubity Group Limited of 20 Dale Street, Manchester, M1 1EZ and our affiliated companies and other brands (collectively, “Pubity Group”, “we”, “us”, “our”) process your personal data (“you”, “your”) when you use our website, content or other services.
Individuals in the European Economic Area (EEA), Switzerland and the UK should also read our section about “Your EEA, Swiss & UK Rights”.
Who does this privacy notice apply to?
This notice applies to:
- Our service users who access our services such as our website or content anywhere on the web, such as, users who watch our content, submit content to us, participate in our surveys and focus group and other users;
- our clients, suppliers and business partners; and
- other persons who interact with us, when you call us or email us.
This notice applies to you whether you act in your personal capacity or as employee or agent of an organisation.
What types of information do we collect?
Generally, “personal information”, “personal data” or similar terms refer to any information that identifies you or relates to you. However, the exact meaning of personal information may be determined by the law of the country of your residence.
We will process the following personal data about you:
- Your contact details such as your email address when you sign up to our newsletter as a user or your name, role, employer details, telephone number, email address and similar information when you interact with us in your business capacity.
- When you contact or visit us, we may process your enquiry, communication, complaint and other details of your enquiry.
- If you are a prospective client, we will keep your personal and professional details and other opportunity records for sales purposes.
- If you engage with our focus groups or surveys, we will collect your input and other participation information.
- When we send you emails or other communications or if you interact with our content all over the Internet we may collect engagement information such as open rates, click rates, view rates, active time spent and similar information.
- When accessing our services, your device and browser will automatically provide unique information such as mobile device ID, internet protocol (IP) address, cookie ID or online identifiers, operating system, browser type, time zone setting, location and date and time of access.Our website may record website usage data about how you navigate and engage with our services, use our features, download materials, security logs will be kept, online activity data such as clickstream data with URLs visited previously, page interaction information (such as scrolling, clicks, and mouse-overs), your preferences (including country and language), and methods used to browse away from our website. We may collect data through our partners Altura Advertising and Google subject to your cookie consent settings.When you access our website or content, we collect information about your preferences and interests known, observed or inferred which we use for personalisation and direct marketing.
- Third party data about you such as information about your interaction with our posts and content and ‘likes’ on social media platforms, such as Facebook, Twitter, Snap, TikTok, or LinkedIn, profile information, preferences and interests received from our advertising and analytics partners and other third parties.
Much of the personal data is provided by you or automatically by your device. You can adjust your device privacy settings to limit disclosure of your personal data that is not necessary for our services. We would ask that you only provide the necessary personal data to us.
Some of the information will be necessary to assist you, to provide our services or to pursue our legitimate interests in data processing. In certain limited cases, some personal data may be mandatory for our compliance with the law.
Data accuracy
We will rely on the information provided by you as accurate, complete and up to date, so please keep us informed of any changes. For example, if you change your email address, please let us know so that we can continue sending you our newsletter.
What information do we collect and why?
Generally, we will use your personal data to (i) provide and enable you to use our website, content and other services, (ii) respond to your queries, (iii) develop and promote our organization and services; (iv) ensure the security and technical availability of our services; and (v) comply with the law.
| Purpose | Personal data | Legal ground for processing (for individuals in the EEA, Switzerland and UK only) |
|---|---|---|
| To assist and contact you in relation to your enquiry. | contact details details of your enquiry | Necessary for our legitimate interest in responding to queries, developing relationships and administering our business or to take necessary steps at your request prior to entering into a contract with you. |
| To provide our services to you, such as our website, content and other services. | device & browser data engagement information website usage data | Necessary for our legitimate interest in providing our website and content to you or, as the case may be, necessary for the performance of our contract with you. |
| To manage our business relationship with you using communications, management and engagement tools. | contact details opportunity records preferences and interests engagement information | Necessary for our legitimate interest in understanding and maintaining our business relationships and administering our business. |
| To send you information which you have requested about our services and service | contact details preferences and interests engagement information | Service communications are necessary for the performance of our contract with you. |
| communications about matters relevant to your use of our services and your engagement with us, such as changes in our terms, events, etc. | Other notifications are necessary for our legitimate interest in satisfying your requests, facilitating our services and organizing related business activities. | |
| To engage with you about surveys and focus groups. | contact details participation information engagement information | Necessary for our legitimate interest in developing our business and organizing related business activities. |
| To send you our newsletter and promotional information through email about our services and organization, reviewing and optimizing campaign performance and profiling information about your interests known, observed or inferred for direct marketing purposes. | contact details engagement information preferences and interests third party data | We may rely on soft opt-in to send marketing to our existing clients or will obtain your consent as required by law, for example, if you sign up for our newsletter. Some of our direct marketing activities are necessary for our legitimate interest in understanding your interests from the information available to us, information observed or inferred and third party information, in promoting our business and understanding campaign metrics. |
| To display advertisements relevant to you on websites and social media, reviewing and optimising campaign performance and profiling information about your interests known, observed or inferred for direct marketing purposes. For example, we use your contact details to display relevant ads through Twitter or LinkedIn or other social media platforms. Social media and advertising providers may use their own information about you to help us make our ads more relevant. Our partner Altura Advertising will collect your device & browser data and use digital fingerprinting techniques to recognise your device for online and cross-channel advertising purposes. It may be shared with our advertising partners and other third party advertising companies globally for the purpose of enabling interest-based content or targeted advertising throughout your online experience (e.g. web, email, connected devices, and in-app, etc). These third parties may in turn use this code to link demographic or interest- based information you have provided in your interactions with them. | contact details engagement information preferences and interests third party data | We will obtain your consent where required by law. For example, your consent will be required to place cookies or similar technologies on your device or to read information on your device. Some of our direct marketing activities are necessary for our legitimate interest in understanding your interests from the information available to us, information observed or inferred and third party information, in promoting our business and understanding campaign metrics. |
| To improve and develop our services, including to: obtain feedback; use Google Analytics to understand the demographics of our users and for audience measurement; conduct statistical analysis; make services and features more relevant; improve user experience; work with third parties and evaluate data to improve and develop our services. | Aggregated data based on your participation information, engagement information, device & browser data, website usage data and preferences and interests. | Necessary for our legitimate interest in delivering our services properly, efficiently and understanding our customer’s needs and expectations. We will use cookies and similar technologies if you provided your consent. |
| To ensure proper administration of our business, including to: keep appropriate records about how our services are used; resolve complaints; conduct troubleshooting; manage our business relationships and identify opportunities; register interactions with our communications, such as emails; enforce our terms; and debt collection. | all information as is necessary and proportionate for the administration of our business | Necessary for our legitimate interest in the proper administration of our business, dispute resolution, ensuring technical operation of our services and debt collection and necessary for compliance with a legal obligation to which we are subject. |
| To engage our third party service providers who may process your information on our behalf to facilitate the provision of our services and the fulfilment of essential service functions, such as web hosting, cloud storage, analytics, payments, plugins, communications, accounting, security and others. | all information as is necessary and proportionate to enable the relevant service | Some activities are necessary for the performance of our contract with you, others are necessary for our legitimate interest in ensuring the proper operation of our services. |
| To monitor our networks, website and systems for suspicious activities, test and audit our systems and deploy appropriate security measures. | website usage data device & browser data | Necessary for our legitimate interest to ensure the security of our organisation, people and services and necessary for compliance with a legal obligation to which we are subject. |
| To monitor interactions and operations for fraud prevention and crime detection purposes, including information from third parties who may help us verify your identity or alert us about suspicious activities. | contact details browser & device data website usage data third party data | Necessary for our legitimate interest in detecting and preventing fraud and illegal conduct and necessary for compliance with a legal obligation to which we are subject. |
| To process health information provided by you, inform you of government guidance and, where appropriate, inform third parties about the risk of infection or share information with relevant authorities. | health information provided by you | Where necessary and proportionate, in order to satisfy our legitimate interest in complying with best practice or applicable laws, and where necessary for compliance with a legal obligation to which we are subject, or to establish, exercise or defend legal claims or to fulfil our duty of care owed to third parties. |
| To share information with our affiliated companies. | all information as is necessary and proportionate | Necessary for our legitimate interest in using our group’s resources to organise, develop and deliver our services, run our organisation and decide on future strategies. |
| To share data with another organisation in accordance with the law for the purposes of a joint venture, collaboration, financing, sale, merger, reorganisation or similar event relating to our business. | all information as is necessary and proportionate in connection with the event | Necessary for our legitimate interest in acting in the best interest of our shareholders and investors and complying with our legal obligations. |
| To process information as is required for our compliance with the law or to establish, exercise or defend legal claims. To process and share information with other third parties where required by law, such as regulators, law enforcement agencies or where mandatory under a court order. | Any information subject to mandatory processing or disclosure, where this is necessary and proportionate | Where processing or sharing your data is necessary for compliance with a legal obligation to which we are subject, to establish, exercise or defend legal claims, or, where necessary and proportionate, in order to satisfy our legitimate interest in complying with best practice or applicable laws. |
We will update you about any new purposes of processing of your personal data from time to time, and we will obtain your prior consent for such new purposes where we are required to do so at law.
Your EEA, UK and Swiss Rights
This section provides further disclosures and describes the rights in relation to your personal data that you may have under the General Data Protection Regulation (“GDPR”) or other relevant law if you are an individual in the EEA, Switzerland or the UK.
Personal data
“Personal data” means any information relating to an identified or identifiable natural person; such person is known as a ‘data subject’. In practice, almost all information relating to you will be your personal data.
- How do we process your information and why?
- We will process your personal data as “controller” for the purposes and on the legal grounds for processing set out above.
- Data subject rights
Subject to certain exemptions, limitations and appropriate proof of identity, as a data subject, you will generally have numerous rights in relation to your personal data that you may exercise with the controller, including the following:
- Right to information about matters set out in this notice. You may also contact us for further details about our retention policy and international data transfers.
- Right to make an access request to receive copies of personal data.
- Right to rectification of any inaccurate or incomplete personal data.
- Right to withdraw consent previously provided.
- Right to object to our processing of personal data based on our legitimate interests, and any automated processing and profiling.
- Right to erasure of personal data, within limited circumstances.
- Restriction on the processing of personal data.
- Right to data portability from one service provider to another, where applicable.
- Right to lodge a complaint with your country’s supervisory authority, such as the Information Commissioner’s Office in the UK.
All requests will be processed in a timely manner, generally within one month. If we cannot process your request within this period, we shall explain why and process it as soon as possible thereafter.
Contact us
Please contact us at contactus@pubitygroup.com or at our registered office address above if you have any queries or concerns about how we use your personal data. We will try to resolve your query without undue delay.
Updates
If we make any changes to our notice you will be able to see them on this page. You should regularly check for updates, as indicated by the “Last updated” date at the top.
If you do not agree with the changes, please do not continue to use our website or services. Of course, if any such changes significantly affect you, we will ask for your prior consent where we are required to do so by law.