Privacy Policy

Contents

1. Purpose
2. Who we are?
3. Policy
   1. General
   2. Information we collect
   3. How do we use your personal data
   4. How do we share your personal data
   5. How long we keep your personal data
   6. Your rights
4. Cookie Policy

1. Purpose

The purpose of this policy is to provide you with information about the following:

• What information we collect from you and why
• How we use the information; and
• How you can access and manage your information
• Support compliance with legal and regulator requirements, but not limited to General Data Protection Regulation (REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND THE COUNCIL of 27 April 2016) and the Directive on privacy and electronic communications (Directive 2002/58/EC) and the E-Privacy regulations when implemented; and
• Ensure the confidentiality and privacy of individuals is protected as required by relevant legislation, regulations, and, if applicable, contractual clauses.

We are committed to protecting and persevering your information, being transparent about what data we hold and how we use it.

This Privacy Policy replaces all other versions and was updated in May 2018.

2. Who we are?

Populate Social Limited. For the purposes of Data Protection, Populate is the ‘Controller’ of the information you provide to us. Our Head Office is located at 17 St Andrews Crescent, Cardiff CF10 3DB.

3. Policy

3.1 General

All personal and sensitive personal data processing across Populate will be conducted in a manner that is compliant with GDPR. Taking into account the following principles:

• Lawfulness, fairness and transparency;
• Purpose limitation;
• Data minimisation;
• Accuracy;
• Storage limitation;
• Integrity and confidentiality;
• Rights of individuals (including but not limited to the right to be informed, access, erasure, rectification, portability, restriction, objection and rights relating to automated decision making);

3.2 Information we collect

Information you give us

When you place an order with us for any of our services we will need certain information to process your order. This may be information such as your name, private business/email or postal address, telephone or mobile number and financial information to help us identify you and to provide a service to you. We may ask for other information that relates to the service you are using or ordering.

When you contact us to discuss your services, we may ask for certain information to be able to confirm your identity, check records and answer your question quickly and accurately.

If you complete any website enquiry or contact us form we may ask for information about you, which we will make clear to you at the time and for the purpose we will be using this information.

Information we collect automatically

When you visit our website or ‘Click’ on any marketing correspondence, we may collect and process information about your usage of these channels by using “cookies” (See Cookies Policy) to help us make improvements to the website and to the services we make available.

Information we receive from outside sources

We may receive personal information about you from third parties, such as companies contracted by us to provide services to you.

3.3 How do we use your personal data

The information we hold on you helps us to better understand what you need from us and to improve the provision of our services to you.

We use the information collected for example to:

• Verify your identity when you use our services or contact us;
• Process your enquiries and provision service orders; i.e:
• To provide the services to you;
• To communicate with you in relation to the provision of the contracted services
• To provide you with administrative support, responding to any issues and taking payments.
• Monitor, record, store and use any telephone, e-mail or other electronic communications with you for training purposes, so that we can check any instructions given to us and to improve our level of service.
• Carry out any marketing analysis, profiling or create statistical or testing information to help us personalise the services we offer you and to understand what our customers want;
• Recover any monies you may owe to us for using our services;
• Analyse our services with the aim of improving them;

Legitimate Interests: Where this is necessary for purposes of our own, or third party legitimate interest.

• Required by law to respond to request by government or law enforcement authorities, or for the prevention of crime or fraud.
• Advise customers of service delivery issues and provide advice
• Direct marketing – providing you with newsletters, surveys , information about events, offers and promotions which may be of interest to you
• Performing analytics on sales/marketing data, determining the effectiveness of marketing campaigns and using this data for feedback.

We may contact you by phone, email or postal mail, unless you have opted for us not to do so.

You have the right to opt out and unsubscribe from the processing of your personal data on the basis of legitimate interest and direct marketing, as set out below, under the heading Your Rights.

How do we share your personal data

We may share your personal data with trusted third parties including:

• Service providers contracted to us in connection with the provision of products and services
• Analytics and search engine providers that assist us in the improvement and optimisation of our website.
• Legal and other professional advisers, consultants and professional experts;

We will ensure there is a contract in place with the categories of recipients listed above which include obligations in relation to the confidentiality, security and lawful processing of any personal data shared with them.

Where a third part recipient is located outside the European Economic Area, we will ensure that the transfer of personal data will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission where the data protection authority does not believe that the third country has adequate data protection laws.

We will share personal data with law enforcement or other authorities if required by applicable law.

We will take reasonable steps to ensure that our staff protect your personal data and are aware of their information security obligations. Data protection and data handling training and guidance is provided to all employees when starting employment at Populate Social Limited and annually as refresher training. We also limit access to your personal data to those who have genuine business need to know it.

How long we keep your personal data

The time frame we keep information varies according to what it is used for. Unless there is a specific legal requirement for us to keep the information, we will retain your information for as long as it is relevant and useful for the purpose for which it was collected.

We will continue to hold information about you if you do not become our customer or after you have terminated your services with us. We will only hold such information for such periods as is necessary for the purpose of dealing with enquiries, offering Populate services you may be interested in, complying with legal obligation and for crime and fraud prevention and detection.

Your Rights

Right to Access

You have the right to request a copy of the personal data that we hold by contacting us at the email or postal address given below.

To help us to process your request you will need to provide the following information:

• Account Number(s)
• Telephone Number(s)
• Address

We will respond within 30 days of request. Please note that there are exceptions to this right. We may be unable to make all information available to you if, for example, making the information available to you would reveal personal data about another person, if we are legally prevented from disclosing such information, or if your request is manifestly unfounded or excessive.

Right to erasure

You have the right to request the deletion of your personal data where, for example, the personal data is no longer necessary for the purposes for which its collected, where you withdraw your consent to processing, where there is no overriding legitimate interest for us to continue to process your personal data, or your personal data has been unlawfully processed. If you would like to request that your personal data is erased, please contact us using the contact details provided below.

Right to restrict processing

In certain circumstances, you have the right to object to the processing of your personal data where, for example, your personal data is being processed on the basis of legitimate interests and there is no overriding legitimate interest for us to continue to process your personal data, or if your data is being processed for direct marketing purposes. If you would like to object to the processing of your personal data, please contact us using the contact details provided below.

4. Cookie policy

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

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