LATITUDE PRIVACY NOTICE

Version: 2.0 Date adopted: 24th May 2018

This document provides information about how we use and share personal data relating to people who get in touch with us.

It covers the following topics:

  1. Who we are and how you can contact us
  2. What we use personal data for
  3. What kinds of personal data we use, and where we get it from
  4. What our legal grounds for handling personal data are
  5. Who we share the personal data with
  6. Where the personal data is stored and sent
  7. How long the personal data is kept for
  8. Whether the personal data is used to make decisions about you or to profile you
  9. Your rights in relation to the personal data we hold about you
  10. Who you can complain to if you are unhappy about the use of your personal data
  11. What cookies are used on our website

You have the right to object and withdraw your consent to our use of your personal data. Please see section 9 to find out more.





1. WHO WE ARE AND HOW YOU CAN CONTACT US

We are Latitude Digital Marketing, which is part of Callcredit Information Group. Our head office is at 700 Mandarin Court, Warrington WA1 1GG. We also have additional offices in London, Kaunas and Dubai.

If you need to contact us with a business enquiry, please visit our contact page at www.latitudegroup.com/contact, call us on 08450 212223, or write to us at the address above.

You can contact us about issues relating to personal data, including the contents of this notice, by any of the following methods:

Post: Customer Services Team, Callcredit Information Group, One Park Lane, Leeds, West Yorkshire LS3 1EP

Email: consumer@callcreditgroup.com

Telephone: 0330 024 7574




2. WHAT WE USE PERSONAL DATA FOR

This section explains the purposes for which we use personal data about you. More detail about the types of personal data that we might use for these purposes can be found in section 3 below.

Relationship management

We use personal data for relationship management purposes. Relationship management is the ongoing maintenance of our relationship with our clients, suppliers and their representatives. This could include activities such as letting you know about product changes or planned maintenance activity, contacting you with billing enquiries, inviting you to events and webinars, dealing with your enquiries, or asking you about what sorts of products you want us to develop.

Marketing

We use personal data for marketing purposes, typically in relation to current or potential clients and their representatives. This includes providing you with original insight, commentary and research on digital marketing, data and software, newsletters and blog posts, early notifications of exclusive events, webinars and updates on our products and services. These communications may relate to any current member of our Group (as set out in section 5) and any future members of our Group.

Some of our marketing activities may rely on consent – see section 4 below. If we have asked you for consent to contact you for marketing purposes we will only do so if you agree, and only through the channel (such as email, telephone or post) that you agree to.

Some of our other marketing-related activities do not rely on consent – again, see section 4. In these cases we will not make contact with you for marketing purposes through any particular channel (such as email, telephone or post) if you have told us that you don’t want to hear from us in that way.

Please note that if you ask us not to contact you for marketing purposes, you might still hear from us for other reasons – for example, as part of our ordinary relationship management activity.

Providing services

Monitoring and improving our websites

We use information such as how different people navigate around our websites, how long they spend on particular pages and whether they download any of our content in order to help customise and improve the user experience of our websites. It also allows us to tailor the website to match your interests and preferences better and helps us understand who has visited which pages to determine the most popular areas of the website.

Legal and regulatory purposes

We may use your personal data for legal and regulatory purposes. For example, this might include responding to complaints or enquiries from you or a regulator about how we have used your personal data.




3. WHAT KINDS OF DATA WE USE, AND WHERE WE GET IT FROM

We obtain and use information from various different sources. These are summarised in the following table.

Type of information

Description

Source

Name and contact details

This is basic personal data about you at your place of work, and how to get in touch with you.

This information is usually provided directly by the relevant individuals; it could for example be given over the telephone, in an email, through our websites, or in person at an event.

Organisation-related details

This is information about your organisation and your role within it, such as your job title and who your colleagues are.

Contact history

This is information about our dealings with you, such as what information we have sent you, who in our group knows you, and what meetings, events or webinars you have attended. It also includes your behaviour in response to our interactions with you, such as whether you have opened our emails, clicked on a link or watched a video.

We produce these records ourselves.

Device information

This is information about the device you are using to access our websites, such as the type of device, its operating system, browser, its IP address, and what cookies are on it.

We produce these records ourselves by monitoring your use of our websites – see more information on IP addresses and cookies below

Website usage

This is information about your use of our websites, such as what pages you have visited and what content you have downloaded.

You are free to choose whether or not you give us your personal data. However, if you are signing up to one of our products or services we might not be able to provide you with that product or service if you do not give us the information we need in order to do so.




4. WHAT OUR LEGAL GROUNDS FOR HANDLING PERSONAL DATA ARE

This section explains the basis on which we process your personal data in connection with the websites.

Legitimate interests

The UK’s data protection law allows the use of your personal data where necessary for legitimate purposes provided that this isn’t outweighed by the impact it has on you. The law calls this the “legitimate interests” condition for processing personal data. We rely on this condition for most of our processing activities.

The legitimate interests we are pursuing are:

Interest

Explanation

Maintaining and using our business relationships; understanding and keeping in touch with our customers and suppliers

We have an interest in maintaining and making use of our relationship with you. For example, if you work for one of our clients we may need to contact you in connection with one of the products that your employer has purchased from us. Or if you work for one of our suppliers we may need to contact you about a product that your employer supplies to us.

We also have an interest in understanding what kinds of people use our products and services and how they use them.

Marketing

We have an interest in promoting our products and services to our clients and potential clients.

Helping people learn about products and services that might be of use to them

Our clients and potential clients have an interest in learning about products and services that they might find useful.

Monitoring and securing our systems and data

Some of the ways we use personal data are justified by the need to ensure that our systems and the data we make available through the website are kept secure and only made available to the correct people.

Commercial interests

Like any commercial organisation, we seek to earn revenue through the services that we provide to our customers and clients.

Consent

We rely on your consent to make contact with you by email for marketing purposes. You can withdraw that consent and ask us to delete your information at any time – please see section 9.

Other grounds

In some circumstances, we may have other grounds to process personal data. These are set out in the following table, along with examples of the circumstances in which they might apply.

Grounds

Examples

Consent

We may in some circumstances rely on your consent. In those cases you will specifically be asked whether you agree to us using your data in specified ways. You can withdraw the consent and ask us to delete your information at any time – please see section 9.

Necessary in order to comply with a legal obligation.

Regulators, government bodies and courts have powers to order us to provide information and, like any other organisation, we sometimes have to comply with their requests.




5. WHO WE SHARE THE PERSONAL DATA WITH

Our group companies

We may share your personal data among the members of Callcredit Information Group. If we do so, then use of the data by those companies will be governed by this privacy notice. A list of Callcredit Information Group companies is set out below, although the list may be updated from time to time.

Group company

Main trading address

Registered office

Callcredit Information Group Limited

(company no. 4968328)

One Park Lane, Leeds, West Yorkshire LS3 1EP

One Park Lane, Leeds, West Yorkshire LS3 1EP

Callcredit Limited

(company no. 3961870)

Callcredit Marketing Limited

(company no. 2733070)

Callcredit Consumer Limited

(company no. 7891157)

Callcredit Data Solutions Limited

(company no. 5749125)

Callcredit Lead Generation Limited

(company no. 5373447)

DecisionMetrics Limited

(company no. 5202547)

Recipero Limited

(company no. 3794898)

Callcredit Public Sector Limited

(company no. 4152031)

3rd Floor, Red Lion Buildings, 12 Cock Lane Smithfield, London EC1A 9BU

Latitude Digital Marketing Limited

(company no. 7050923)

700 Mandarin Court, Warrington, Cheshire WA1 1GG

process benchmarking limited

(company no. 2944342)

1 Bromley Lane, Chislehurst, Kent, BR7 6LH

Smart Analytics Limited

(company no. 4127933)

Kingfisher Court, Yew Street, Stockport, Cheshire SK4 2HG

Callcredit Spain, S.L.

(tax ID number B87839510)

Paseo de la Castellana, 259C, 16th floor, 28046 Madrid, Spain

Confirma Sistemas de Información, S.L.

(tax ID number B86303757)

Av. de la Industria, 18, 28760 Tres Cantos, Madrid, Spain

Soluciones Confirma ASNEF-SIGNE, S.L.

(tax ID number B86016649)

Aspireview, Inc

(company no. 5953359)

The Corporation Trust Center, 1209 Orange Street, Wilmington, Delaware 19801, USA

Recipero, Inc

(company no. 5542430)

720 S. Colorado Boulevard, Penthouse North, Denver, Colorado 80246, USA

Callcredit Operations UAB

(company no. 302689020)

Zalgirio Arena, Karaliaus, Mindaugo pr. 50, Kaunas LT- 44333, Lithuania

Vilniaus m. sav . Vilniaus m. J. Jasinskio g. 16B, LT-01112, Lithuania

Service providers

We may provide your information to third parties who help us use it for the purposes described in section 2. For example:

  • We use a third party email broadcasting service in order to send you service emails or (if you have agreed to receive them) marketing emails.
  • We might use market research companies to help us better understand our customers.

These service providers will not be allowed to use your information for their own purposes or on behalf of other organisations, unless you agree otherwise.

Online advertising platforms

We may use third party advertising platform providers such as Google to serve advertisements to you. These third parties may use information about your visits to these and other websites in order to provide you with advertising about products and services that may be of interest to you.

Sometimes we may provide information associated with you to third parties who operate other websites (such as social media platforms) so that we can show you relevant advertisements while you are using those websites. This information will be protected so that you can only be identified if the third party already knows you – the information we provide only tells them that you are a user of our websites.

You can configure your advertising preferences on social media such as Facebook, Twitter, Instagram or Pinterest by accessing your settings or preference options on the relevant platform. If you no longer want to receive personalised advertising on any website you visit, you can usually opt out directly through the privacy policy of the particular website you are accessing. Please note that this will not block ads that are displayed on the websites you visit; it will simply stop you receiving advertising that has been tailored to your interests. This opt-out relies on a cookie, so if you wipe all your cookies then that website will no longer know that you have opted out. The same applies if you use a different internet browser, or use a new computer to access the internet. You can also opt out of such advertising by visiting the IAB opt-out platform at www.youronlinechoices.com, but please note that this and other platforms only allow you to opt out of interest-based advertising delivered by registered members.

Business transfers

If we sell our business to a third party, or go through a corporate reorganisation, we may transfer personal data to the company that acquires the business.

Regulators

We may sometimes need to pass personal data to a regulator such as the Information Commissioner’s Office.




6. WHERE THE PERSONAL DATA IS STORED AND SENT

Within Europe

We are based in the United Kingdom, and will access and use your information from here. However, we also have operations elsewhere in the European Union – currently Lithuania – and personal data may be accessed from there too. In this case, the use of the information in those locations is protected by European data protection standards.

Elsewhere

We also send information elsewhere in the world. For example:

  • When one of our overseas group companies or branch offices based overseas needs to use the information in accordance with this notice. Currently, these overseas offices are in Dubai and the United States.
  • Where we use cloud-based technology or a data centre or backup facility overseas. People in other countries may also need to access that database for purposes such as technical support or system development and testing.

While countries within the European Union all ensure a high standard of data protection law, some parts of the world may not provide the same level of legal protection in relation to personal data. As a result, when we do send personal data overseas, we will make sure that suitable safeguards are in place to protect the information. For example, these safeguards might include:

  • Putting in place a contract with the recipient containing terms which have been approved by the authorities as providing a suitable level of protection.
  • Sending the information to an organisation which is a member of a scheme which has been approved by the authorities as providing a suitable level of protection. One example is the “Privacy Shield” scheme that has been agreed between the European and US authorities.

If your information has been sent overseas like this, you can obtain further information about the safeguards used by contacting us using the details set out in section 1 above.




7. HOW LONG THE PERSONAL DATA IS KEPT FOR

We will not keep your personal data for longer than we need it.

If you are a representative of one of our clients or potential clients, this means that we will normally keep your personal data while you or your employer have an ongoing relationship with us or if you have demonstrated an interest in our products and services within the past two years. You can request us to delete it earlier as explained in section 9.




8. WHETHER THE PERSONAL DATA IS USED TO MAKE AUTOMATED DECISIONS ABOUT YOU OR TO PROFILE YOU

We use certain profiling techniques in order to help us to understand our clients and potential clients. This in turn helps us to understand which people might be interested in which of our products and services.

We do not use automated decision-making or profiling to make any decisions that will significantly affect you. For example, we do not use it to set the prices that we charge for our products and services.




9. YOUR RIGHTS IN RESPECT OF THE PERSONAL DATA THAT WE HOLD ABOUT YOU

You have several different rights in relation to the personal data that we hold about you. These are briefly described below. To enquire about exercising these rights, please use the contact details set out in section 1.

  • Access: You have a right to find out what personal data we hold about you, and certain other information such as how we are using it.
  • Withdrawal of consent: When we rely on your consent to use your data (see section 4 above), you have the right to withdraw that consent at any time. You can do this by contacting us, or through your account settings or (in the case of marketing emails) by clicking the “unsubscribe” link.
  • Objection to direct marketing: You have the right to object to us using your personal data for direct marketing purposes. If you do this we will stop using it for those purposes.
  • Rectification: If the information that we hold about you is inaccurate or out of date, you have a right to ask us to correct it.
  • Objection to legitimate interests: If you disagree with us relying on the legitimate interests grounds for using your personal data (see section 4 above), you can object to us doing so. We will then reassess the extent to which we can continue to use the data in light of your particular circumstances.
  • Erasure: In certain circumstances you can ask us to delete your personal data from our systems. However, this usually won’t apply to all of your data because we might have good reason for needing to keep some of it.
  • Restriction: In some circumstances you can ask us to restrict the ways in which we use your personal data.
  • Portability: You have the right to receive some limited kinds of information in a portable format.



10. WHO YOU CAN COMPLAIN TO IF YOU ARE UNHAPPY ABOUT THE USE OF YOUR PERSONAL DATA

We try to ensure that we deliver the best levels of customer service but if you are not happy with the way we have used your personal data you should make contact so that we can investigate your concerns. Please contact us using these details:

Post: Customer Relations Team, Callcredit Information Group, One Park Lane, Leeds, West Yorkshire LS3 1EP

Email: customer.relations@callcreditgroup.com

Telephone: 0330 024 7574

You can also contact our Data Protection Officer at dpo@callcreditgroup.com.

You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO), which is the body that regulates the handling of personal data in the United Kingdom. You can do this online through the ICO’s website at www.ico.org.uk, by telephone on 0303 123 1113, or by writing to them at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF.




11. WHAT COOKIES ARE USED ON OUR WEBSITE

We use cookies and similar technologies to distinguish you from other users of the website. This helps us to provide you with a good experience when you browse the website and also allows us to personalise and improve the website.

A cookie is a small file of letters and numbers that we put on your device. We use the following kinds of cookie:

  • Strictly necessary cookies. These are cookies that are required for the operation of the website. They include, for example, cookies that enable you to log into secure areas of the website.
  • Analytical/performance cookies. These cookies allow us to recognise and count the number of visitors and to see how visitors move around the 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. They also allow us to tell if you have reached our website from one of our advertising partners so that we can meet our contractual commitments to that partner.
  • 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.
  • 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.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below.

Name

Purpose

More Information

Google Analytics

These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they have visited.

Here

Yahoo Web Analytics

Yahoo Indextools analyses traffic to this web site. It does not create individual profiles for visitors. It only collects aggregate data.

Here

Google Adwords conversion tracking

This cookie is used to track when a visitor purchases a product advertised on our website.

Here

PHP Session Cookie

This is a cookie set by the web server that is required for the website to function, it does not store any personal data and is deleted when the visitor closes their browser.

Twitter Tweet Button

This cookie is set by Twitter to allow a visitor to tweet certain articles from our Website.

Here

Dart Doubleclick.net Cookie

This cookie is used by Doubleclick (a subsidiary of Google) for ad serving.

Here

LinkedIn Insight Tag

This cookie is used to allow us to gain insight into our website visitors.

Here

Facebook Conversion Tracking

This cookie allows us to track how many people utilise our ads and specifically which Facebook Ads led to a conversion. These can be placed on our website pages.

Here

Twitter Conversion Tracking

This cookie allows us to track what actions individuals take after engaging with our ads on twitter. We add this to site pages to allow us to analyse and optimise our campaigns.

Here

AdWords Remarketing Tag

This tag enables us to see who has visited our website, and allows us to remarket to them.

Here