Privacy & COOKIE Policy
SNOWDEN MARKETING LIMITED
BACKGROUND:
Snowden Marketing Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, snowdenmarketing.com (Our Site) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
Please read this Privacy & Cookie Policy carefully and ensure that you understand it.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
2. Information About Us
Our Site is owned and operated by Snowden Marketing Limited, a company registered in England & Wales under company number 14110903, whose registered office address is at Francis House, 6 Humber Place, Hull, England, HU1 1UD. Our Data Protection Officer, Jennifer Snowden, can be contacted by email at jenn@snowdenmarketing.com.
3. What Does This Policy Cover?
This Privacy & Cookie Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
4. What Is Personal Data?
Personal data is defined by the Data Protection Legislation as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
5. What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
a) The right to be informed about our collection and use of your personal data. This Privacy & Cookie Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.
b) The right to access the personal data we hold about you. Part 13 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 15 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
h) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
i) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed.
If you have any cause for complaint about our use of your personal data, we would welcome an opportunity to resolve this with you: please contact us using the details in Part 15. If you are not happy with how we have attempted to resolve your complaint, you may contact the Information Commissioner’s Office.
6. What Data Do You Collect and How?
Depending upon your use of Our Site, we may collect and hold some or all of the personal data set out in the table below, using the methods also set out in the table. Please also see Part 14 for more information about our use of Cookies and similar technologies. We do not collect any ‘special category’ or ‘sensitive’ personal data or personal data relating to children, or data relating to criminal convictions and/or offences.
7. How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email with information, news, and offers on our products and/ or services. We collect, store and use this information this using a third-party marketing service provider. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and Cookie Law, and you will always have the opportunity to opt-out. We will obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.
Third parties whose content appears on Our Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling Cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.
We do not carry out automated decision making or any type of automated profiling.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
8. How Long Will You Keep My Personal Data?
Where we collect any personal data, it will be processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected (including for the purposes of satisfying any legal, accounting or reporting requirements).
When deciding what the correct time is to keep the data for, we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means, and the legal requirements.
For tax purposes, the law required us to keep basic information about our customers (including identity, contact and payment information as well as information on the contracts we enter into with our customers) for six years after they stop being customers.
In some circumstances, we may anonymise your personal data for research of statistical purposes in which case we may use this information indefinitely without further notice to you.
9. How and Where Do You Store or Transfer My Personal Data?
We may transfer your personal data outside the United Kingdom for storage and processing. By providing any information, including personal data to us, you consent to such transfer, storage and processing.
“Third countries” outside the EEA may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation. We do this by selecting only external third parties that require the same levels of personal data protection that would apply under the Data Protection Legislation, and ensuring these levels of protection are contained in the external third parties’ privacy policies. Further details of the third-party providers we use are set out below.
When you submit information in the website contact form or marketing pop-up form, and when you purchase services or products from us through Our Site, you will be asked to enter your personal data so that we can contact you and/ or fulfil your purchase. We share this information with Squarespace, our online store hosting provider, so that they can provide website services to us. For more details on how Squarespace stores and processes personal data, please see its Privacy Policy.
When you schedule a call or meeting with us through Our Site, we collect information from you (including your name, email address and any additional information you choose to provide in relation to your call or meeting) through Calendly, our scheduling service provider, so that they can provide online booking services to us. For more details on how Calendly stores and processes personal data, please see its Privacy Policy.
When you purchase products and/or services from us via Our Site, we use third-party services for payment processing. We will not store or collect your payment card details. That information is provided directly to our third-party payment processor, PayPal, and processed by PayPal in accordance with its Privacy Statement. PayPal adheres to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
We collect, store and use your personal data for marketing communication purposes using Flodesk, a third-party marketing service provider. Flodesk’s Privacy Policy is available here.
The security of your personal data is essential to us and to protect your data, we take a number of important measures, including the following:
· personal data entered by you on Our Site is secured by SSL (secure socket layer) technology in transit and at rest to improve security. SSL secures connections and prevents impersonation or stealing of visitors’ information;
· Squarespace’s Security Operations Centre (SOC) monitors for threats and vulnerabilities 24/7 to ensure Our Site and others are protected;
· the PayPal payment processor integration on Our Site is compliant with PCI-DSS. Sensitive card data is never handled by us or by Squarespace. It goes directly to the payment processor’s servers; Squarespace and we do not have access to this information;
· Our Site utilises Web Application Firewall (WAF) technology;
· we have put in place appropriate technical and organisational measures against unauthorised or unlawful access to or processing of personal data and against accidental loss, destruction or damage of that data, as specified by Cyber Essentials.
· access to your personal data is limited to those employees, agents, contractors, and other third parties with a legitimate need to know and they are subject to duties of confidentiality; and
· we have in place procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the relevant authorities where we are legally required to do so.
10. Do You Share My Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.
We may have to share your personal data with service providers who provide IT and system administration services (including but not limited to our website platform, Squarespace and our payment processor, PayPal) and on occasion with our professional advisers such as lawyers, auditors and insurers.
If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy & Cookie Policy.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.
If any personal data is transferred outside of the United Kingdom, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the United Kingdom and under the Data Protection Legislation, as explained above in Part 9.
11. How Can I Control My Personal Data?
In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Site, you will be given options to restrict our use of your personal data. We aim to give you control over our use of your data for direct marketing purposes (including the ability to opt out of receiving marketing emails from us), which you may do by unsubscribing using the links provided.
12. Can I Withhold Information?
You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
You may restrict our use of Cookies. For more information, see Part 14 below.
13. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email address shown in Part 15.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
14. How Do You Use Cookies?
Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve our services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.
By using Our Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us.
All Cookies used by and on Our Site are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a pop-up asking you to give your consent to set those Cookies. You will be able to choose whether to consent only to necessary cookies and/ or to non-essential Cookies. Necessary cookies help make Our Site more useable for users by enabling basic functions like page navigation and access to secure areas of Our Site. Our Site cannot function properly without these Cookies.
By consenting to the placing of Cookies you are enabling us to provide the best possible experience and service to you. However, the non-essential third-party Cookie son Our Site are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
A list of the first-party Cookies on Our Site is set out below:
A list of the third-party Cookies on Our Site is set out below:
Our Site uses Google and Squarespace website analytics services. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how Our Site is used. This, in turn, enables us to improve Our Site and the services offered through it. Google, Squarespace and other similar analytics service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business.
The above services used by Our Site use third party Cookies, as set out in the above table. You do not have to allow us to use these Cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable us to continually improve Our Site, making it a better and more useful experience for you.
The Data Privacy & Cookie Policies for our third-party Cookie providers, which set out how personal data obtained through Our Site is processed, are available via the following links:
You may opt out of Google Analytics’ services using the Opt-Out feature on their website. The Google Analytics service is provided by Google Inc. You can opt-out from Google Analytics service from using your information by installing the Google Analytics Opt-out Browser tool.
In addition to the controls that Google and we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device or follow the relevant link(s) below:
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently.
15. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please email us at jenn@snowdenmarketing.com, marking your email “Subject Access Request”.
16. Changes to this Privacy Policy
We may change this Privacy & Cookie Policy from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy & Cookie Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date. This Privacy & Cookie Policy was last updated on 31 December 2022.