Privacy & Cookies Policy.

1. Within this Policy;

‘Company’ means Proper Marketing Limited, 59a Day’s Lane, Biddenham, Bedford, MK40 4AE

‘Personal Information’ means any information from which any individual can be personally identified, including online identifiers like email address and I.P address (a digital address which identifies the device you access the internet with).

‘Website’ means www.propermarketing.co.uk

2. The Company is a Data Controller under the General Data Protection Regulations and is committed to protecting and processing Personal Information in compliance with these Regulations.

3. This policy sets out how the Company may collect, process and store your Personal Information in compliance with our legal obligations and your legal rights.

4. In the course of its activities, the Company intends to only deal with individuals over the age of 16 in a business to business context.

5. The Company will update this policy in line with legal requirements which may result in changes. You may request a copy of this policy at any time from the address on the last page.

Website use

When visiting the website the Company may collect the following information;
• IP address
• country
• browser
• operating system
• screen resolution
• web pages visited
• forms submitted
• click and mouse movements
• searches conducted
• videos viewed

This information is collected by third-party processors who generate reports and statistics about the, which helps us to;
• monitor usage and performance of the website;
• maintain a website that is user-friendly and compatible with popular equipment and software;
• analyse and maintain the security of the website and trace inappropriate or malicious use.

The Company will not use automated processing of your Personal Information to form or make decisions.

The Company may permit third parties to advertise on the website. These third parties may use tracking features to enable them to record the number of views, clicks and the referral source. If you visit an advertiser’s website they will have their own Privacy Notice which you should read and accept.

Enquiries

If you make an enquiry about any of our services or request information via the website, you will be asked to provide your name, business name and an email address.

This Personal Information is processed;
• for a legitimate interest so that the Company can respond to your enquiry or provide the information requested;
• by consent to send commercial communications including the availability of new products, services, events, special offers and discounts, newsletters and notifications, where you request or permit such communications

Providing Services

If we agree to enter into a contract with you to provide Services we will use your Personal Information and process on the basis of legitimate interest;
• for the administration and performance of the contract.
• to deliver any services to you.
• for the recording of financial transactions.
• for internal records that we are legally obliged to keep.
• to deal with complaints, disputes and legal actions.
• where necessary to protect the vital interest of you or another person;
• to send commercial communications from us (including the availability of new products or Services, events, special offers and discounts, newsletters, notifications), where you give your consent to receiving such communications.
• to send commercial communications from selected partners, associates or affiliates, but only where you expressly request or consent to such communications.

Processing payments

When making payment of invoices for services provided, all payments are processed by your bank. The Company does not collect payments by credit or debit card.

Should the Company have cause to make a payment to you, this will either be by bank transfer or cheque. In the case of bank transfer your bank details will be stored securely and processed on the basis of legitimate interest.

Sharing your Personal Information

The Company may share your Personal Information with our employees, officers, agents, consultants, suppliers or subcontractors only insofar that it is reasonably necessary;
• in order to deal with an enquiry or to provide requested information;
• in order to consider whether to enter into a contract with you;
• for the performance of a contractual obligation between you and the Company;
• under a legitimate interest that is stated within this Privacy Notice;
• to meet a required by Law or order of a Court;
• necessary for the prevention of fraud or other criminal activity;
• for the purposes of establishing, exercising or defending legal rights;
• required to by a purchaser in the event of selling the Company;
• otherwise with your consent, request or instruction.

Data retention

Where an enquiry does not progress into a contract to provide services or you do not request or consent to commercial communications the Company shall not retain your Personal Information for more than 2 years.

If we engage in a contract to provide Services to you, the Company shall retain some records for a period not exceeding 2 years after the Services have ended where appropriate or required by law.

Your rights:-

To withdraw consent

Where processing of your Personal Information is based on your consent and not legitimate interest you may withdraw your consent at any time by informing the Data Controller or using the unsubscribe link on the email.

Upon receipt of a notice withdrawing your consent to process your Personal Information the Company shall stop processing the Personal Information and inform all third parties (if any) except:
• where there are 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.

To restrict processing

The Company shall restrict the processing of your Personal Information if the following circumstances arise;
• where you contest the accuracy of the Personal Information, the Company shall restrict the processing until the accuracy of the Personal Information has been verified.
• where you have objected to the processing where it was necessary for the performance of a public interest task or purpose of legitimate interests, and the Company is considering whether the legitimate interest grounds override your grounds.
• when processing is considered unlawful and you oppose erasure and you request restriction instead.
• if the Company no longer needs the Personal Information but you require the information to establish, exercise or defend a legal claim.

Where processing of your Personal Information is restricted, the information shall be stored but no further processing shall occur and the Company shall;
• inform any third party to whom your Personal Information has been disclosed or shared that the Information is restricted;
• inform you when any restricted period comes to an end.

Access to Personal Information

You may require the Company to provide you with;
• confirmation whether or not your Personal Information is being processed; and
• access to any Personal Information that the Company holds about you.

The Company shall provide the requested information within one month of receipt of the request, which may be provided in hard copy or electronically. This information will be provided free of charge except where a request is manifestly unfounded or excessive (for example it is a repetitive request, or where the Company needs to process large amounts of data) in which case the Company shall make a charge for reasonable administrative costs in dealing with the request or refuse to respond and provide a justifiable reason for refusing to respond. In the latter case you may complain to the Information Commissioners Office.

The Company reserves the right to require proof of identity before disclosing your Personal Information.

Updating of Personal Information

In order that the Company is able to provide you with an optimum service and to ensure that all obligations under UK Data Protection legislation are complied with, you must let the Company know if any Personal Information which you have provided changes or becomes inaccurate or out of date.

The right to rectify errors

Where any Personal Information that is processed is inaccurate or incorrect you have the right to instruct the company to correct the Personal Information.

The Company may, where the Company believes that the Personal Information is correct ask you for evidence to clarify or confirm that the Personal Information is wrong.

Right to erase Personal Information

You have the right in certain circumstances to instruct the Company to erase your Personal Information where;
• The Personal Information is no longer necessary in relation to the purpose for which it was originally collected or processed.
• The Personal Information was processed with your consent and you withdraw your consent.
• You object to the processing and there is no overriding legitimate interest for continuing the processing.
• The Personal Information was unlawfully processed or obtained.
• The Personal Information must be erased in order to comply with a legal obligation.
• The Personal Information is processed in relation to the offer of information of services to a child.

Where you have the right and you issue an instruction to erase your Personal Information the Company shall use all reasonable efforts to;
• Inform all third parties to whom the Company has disclosed or shared your Personal Information of the requirement to erase your Personal Information which they hold;
• In the event that your Personal Information has been published online the Company shall endeavour to ensure that any links or references are also removed;

The Company may refuse to erase your Information only;
• If the processing is necessary for the performance of a contract;
• to exercise the right of freedom of expression and information;
• to comply with a legal obligation;
• if the processing is for the performance of a public interest task or exercise of official authority;
• for archiving purposes in the public interest, scientific research historical research or statistical purposes; or
• for the exercise or defence of legal claims.

Third Party Processing

We may use third party processors, such as computer software, when processing your Personal Data. If any of our processors are based outside of the EEA, the Company shall take all reasonable steps to ensure that the third party meets standards in relation to the security of your Personal Data which are consistent with the General Data Protection Regulations. In addition, the processor will need to provide, or be subjected to suitable and appropriate contractual obligations and guarantees.

Security

The Company will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of Personal Information, including storing of data on a secure, password and firewall protected servers. All employees of the Company with access to Personal Information will be obliged to keep that Personal Information confidential. In the event of a breach of the security measures taken to protect your personal information the Company will inform you as soon as is reasonably practical.

Cookies – and how we use them

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes.

Overall, cookies help us provide you with a better website experience, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

You can 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 you may not be able to access all or parts of our web

Contact details

You can exercise any of your rights by contacting the Data Protection Officer at Proper Marketing Limited, 59a Day’s Lane, Biddenham, Bedford, MK40 4AE or email paul@propermarketing.co.uk.

Complaints

In the first instance if you have a complaint about the use of your personal data please write to Data Protection Officer at Proper Marketing Limited, 59a Day’s Lane, Biddenham, Bedford, MK40 4AE. We will address your concerns and attempt to solve the problem to your satisfaction.

If you are not happy with our response you can complain to the UK Information Commissioners Office which regulates and enforces data protection law in the UK. Details of how to do this can be found at www.ico.org.uk