PRIVACY POLICY

GDPR: DATA PRIVACY NOTICE FOR CLIENTS AND SUPPLIERS

Introduction

Marketing Nest (“We”) are committed to protecting and respecting your privacy. This policy (together with our terms of use http://marketingnest.com/Terms_and_Conditions and any other documents referred to on it) 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 practices regarding your personal data and how we will treat it.

The rules on the processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).

1. Definitions

Data controller – A controller determines the purposes and means of processing personal data.

Data processor – A processor is responsible for processing personal data on behalf of a controller.

Data subject – Natural person

Categories of data: Personal data and special categories of personal data

Personal data – The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.

Special categories personal data – The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, and political opinions, religious or philosophical beliefs.

Processing – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Third party – means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

2. Who are we?

For all data matters contact Antonella Ragona the Proprietor of Marketing Nest. Marketing Nest is the data controller. This means we decide how your personal data is processed and for what purposes.

Our contact details are: New Bond House, 124 New Bond Street, London, W1S 1DX UNITED KINGDOM – 020 7183 0149 – info@marketingnest.com – www.marketingnest.com

3. The purpose(s) of processing your personal data

We use your personal data for the following purposes:

• Internal record keeping;

• Improvement of our services;

• Communication by email of promotional materials that may be of interest to you;

• Market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customise or update the Website;

4. The categories of personal data concerned

With reference to the categories of personal data described in the definitions section, we process the following categories of your data: Name, Job Title, Business Name, Email Address and Telephone Number.

HOW WE COLLECT YOUR PERSONAL DATA

• 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 and other similar technologies. Please see our cookie policy http://marketingnest.com/Policies for further details.

• Identity and Contact Data from publicly available sources [such as Companies House and the Electoral Register based inside the EU].

5. What is our legal basis for processing your personal data?

Personal data (article 6 of GDPR) – Our lawful basis for processing your general personal data:

1. We will collect your contact and financial details to register you as a new customer and process and deliver your order including:

(i) Manage payments, fees and charges

(ii) Collect and recover money owed to us

Lawful Basis: Performance of a contract with you – necessary for our legitimate interests (to recover debts due to us)

2. We will collect your contact details and marketing communications details to manage our relationship with you which will include:

(i) Notifying you about changes to our terms or privacy policy

(ii) Asking you to leave a review or take a survey:

Lawful Basis: (i) Performance of a contract with you Necessary to comply with a legal obligation

(ii) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

3. We will collect your contact details, marketing and communications, usage and technical information to administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Lawful Basis: Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

4. We will collect your contact details, usage and technical information to use data analytics to improve our website, products/services, marketing, customer relationships and experiences

Lawful Basis: 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)

5. We will collect your contact details, profile, marketing and communications, usage and technical information to make suggestions and recommendations to you about goods or services that may be of interest to you

Lawful Basis: Necessary for our legitimate interests (to develop our products/services and grow our business)

More information on lawful processing can be found on the ICO website.

6. Sharing your personal data

Your personal data will be treated as strictly confidential, and will not be shared with third parties.

7. How long do we keep your personal data?

We keep your personal data for no longer than reasonably necessary for a period of 12 months for safeguarding purposes.

8. Providing us with your personal data

You are under no statutory or contractual requirement or obligation to provide us with your personal data. But failure to do so may result in:

a) Marketing Nest will not be able to enter into a contract with you

b) Marketing Nest being unable to guarantee the performance of a contract with you

c) Marketing Nest being unable to share marketing material with you

9. Your rights and your personal data

Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:

• The right to request a copy of the personal data which we hold about you;

• The right to request that we correct any personal data if it is found to be inaccurate or out of date;

• The right to request your personal data is erased where it is no longer necessary to retain such data;

• The right to withdraw your consent to the processing at any time;

• The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability);

• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;

• The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).

10. Transfer of Data Abroad

We do not transfer personal data outside the EEA.

11. Automated Decision Making

We do not use any form of automated decision making in our business

12. Further processing

If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.

13. Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

14. How to make a complaint

To exercise all relevant rights, queries or complaints please in the first instance contact: Antonella Ragona Proprietor of Marketing Nest on info@marketingnest.com 0207 183 0149

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.

May 2018

COOKIES POLICY

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. [By continuing to browse the site, you are agreeing to our use of cookies.]

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

· Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.

· Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

· Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

· Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

[Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies]

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

Except for essential cookies, all cookies will expire after twelve months.