About this policy
Campaign Circle Limited (Company Number: 09246037) of 130 Aztec West, Almondsbury, Bristol BS32 4UB (herein referred to as ‘we’, ‘us’ or ‘our’) are committed to protecting the privacy of your personal information in accordance with Data Protection Legislation (as defined below). You may contact us by email at firstname.lastname@example.org or by phone on +44 (0)117 248 2365.
Data Protection Legislation means:
- Until 25 May 2018, the Data Protection Act 1998; and
- Unless and until the General Data Protection Regulation ((EU) 2016/679) (GDPR) is no longer directly applicable in the UK, the GDPR and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK; and then
- Any successor legislation to the GDPR or the Data Protection Act 1998.
When you engage us to provide you with any goods or services, communicate with us through email, by telephone, in writing, participate in any of our promotional activities, or use any of our other services, including our websites, you agree to the use and disclosure of your personal information in the manner described in this policy. This policy is also relevant and applies to other individuals we deal with in connection with commercial credit we provide, such as guarantors and directors.
Types of personal information we collect
The kinds of personal information we may collect from you will depend on what type of interaction you have with us. Personal information we may collect from you includes, among other things:
- identity particulars - such as your name, address, date of birth, occupation, telephone numbers and e-mail address;
- personal information we collect from you when assessing, processing and managing an application by you for commercial credit;
- personal information you provide to us when you participate in a promotion, competition, promotional activity, survey, market research, subscribe to our mailing list;
- your bank, credit or debit account details when you make a purchase;
- your records of communication with us; and
- if you visit our website, your website use information such as your IP address.
The purpose for collecting your personal information
We will generally only collect and use your personal information for the primary purposes of:
- our general business operations;
- effectively providing you with our services;
- where applicable, assessing and processing an application for commercial credit, and for administrative purposes in relation to the ongoing management of your commercial credit arrangement;
- communicating with you;
- responding to your inquires or complaints;
- meeting our legal and regulatory obligations;
- conducting, improving and developing a relationship with you;
- direct marketing (such as providing you with information about our products and promotional notices and offers); and
- improving our websites.
Your personal information is only collected by lawful and fair means and where practicable, only from you or from a person acting or authorised to act on your behalf. Where you have applied for commercial credit account with us, we may also make enquiries in respect of commercial credit with third parties with your consent. This could include persons nominated by you as trade references, credit reference agencies (“CRAs”) and your bankers.
We will take reasonable steps to ensure that you are aware of:
- the likely use of the information;
- the right of access to the information;
- the identity and contact details of our employee/representative collecting your personal information;
- any law requiring collection of the information; and
- the main consequences of failure to provide your personal information.
How we may use and disclose your personal information
We may use your personal information for:
- the primary purposes for which it was collected, such as those described above;
- assessing and processing an application for, or administrative and management of, and commercial credit account with us;
- administering and responding to your enquiry or feedback about our products and/or services;
- conducting, and allowing you to participate in, a promotion, competition, promotional activity, survey, market research or customer behavioural activity;
- promoting and marketing our current and future products and services to you, informing you of upcoming events and special promotions and offers and analysing our products and services so as to improve and develop new products and services (but giving you the opportunity to opt out of such direct marketing); and
- improving the operation of our websites.
We may disclose personal information we collect from you:
- to our related companies, suppliers, consultants, contractors or agents for the primary proposes for which it was collected or for other purposes directly related to the purpose for which the personal information is collected. For example, your name and telephone number may be disclosed to our supplier to enable that supplier to respond to your request for information about a particular product;
- for direct marketing, but we shall give you the opportunity to opt out of such direct marketing at the time your personal information is collected. We will include our contact details in any direct marketing and you may opt out of direct marketing at any time;
- to relevant state authorities (as required);
- where the law requires or authorises us to do so;
- to others that you have been informed of at the time any personal information is collected from you; and
- with your consent (express or implied), to others.
Where Data Protection Legislation permits us to do so, we may also disclose your credit related information (in respect of commercial credit) to CRAs.
Where we collect information that we are likely to disclose to a CRA, please note:
- the CRAs may include that information in reports provided to us to assist it to assess your creditworthiness;
- if you fail to meet payment obligations in relation to commercial credit or commit a serious credit infringement, we may be entitled to disclose this to the CRA;
We do not disclose your personal information for any secondary purposes unless your consent has been given or we are required to do so by law, and we will not sell or license any personal information that we collect from you.
How your personal information is stored and secured
We take reasonable steps to protect your personal information from loss, misuse or unauthorised access by restricting access to the information in electronic format and by appropriate physical and communications security.
If a substantial data breach has or may have occurred (for example, your personal information was shared with unauthorised persons) we will notify you as soon as is practicable.
Using our Website and Cookies
As with most websites, when you visit our website or use an application on our website, we may record anonymous information such as IP address, time, date, referring URL, pages accessed and documents downloaded type of browser and operating system.
We also use “cookies”. A cookie is a small file that stays on your computer until, depending on whether it is a sessional or persistent cookie, you turn your computer off or it expires. Cookies may collect and store your personal information. You may adjust your internet browser to disable cookies. If cookies are disabled you may still use our website, but the website may be limited in the use of some of the features.
Marketing and Opting-Out
We may use your personal information for:
- promoting and marketing of our current and future products and services;
- informing you of upcoming events and special promotions and offers; and
- analysing our products and services so as to improve and develop new products and services.
We may exchange your personal information between our related entities and so they can also assist in the marketing of our products and services to you.
We will only offer you products or services, where we reasonably believe that they could be of interest or benefit to you.
At the point we collect information from you, you may be asked to “opt in” to consent to us using or disclosing your personal information. You will be given the opportunity to “opt out” from receiving marketing communications from us at the time your personal data is collected. You may “opt out” from receiving these communications by clicking on an unsubscribe link at the end of an email or by contacting us with this request at any time.
Cross border disclosure
Your personal information may also be processed by, or disclosed to employees, representatives, or other third parties operating outside of the European Economic Area (“EEA”) who work for, or are engaged by us in other countries. For example, we may use a server hosted overseas to store data, which may include your personal information.
You may refuse consent for your personal information to be disclosed to third parties operating outside of the EEA or withdraw any consent you have previously provided at any time by contacting us. We will notify you as soon as is practicable if this will affect our ability to provide you with products or services.
If you consent to the disclosure of your personal information to an overseas recipient, the overseas recipient may not be accountable under Data Protection Legislation, and you will not be able to seek redress for breaches under Data Protection Legislation.
Accurate and up-to-date information
We take reasonable steps to ensure your personal information is accurate, up-to-date and not misleading by updating its records whenever true and correct changes to the data come to its attention.
If you believe your information is incorrect, incomplete or not current, you can request that we update this information by contacting us.
We will correct information we hold about you if we discover, or you are able to show to a reasonable standard, the information is incorrect. If you seek correction and we disagree that the information is incorrect, we will provide you with our reasons for taking that view.
We disregard information that seems likely to be inaccurate or out-of-date by reason of the time that has elapsed since it was collected or by reason of any other information in our possession.
We acknowledge that you have a general right of access to information concerning you, the right to have inaccurate information corrected and the right to request that your personal information is erased. You are able to access the personal information we hold about you by contacting us.
You have the right to refuse consent, or withdraw consent previously provided, to the disclosure of your personal information at any time by contacting us. If this will affect our ability to provide you with goods or services we will notify you as soon as is practicable.
You have the right to object to the processing of your personal information and to restrict the processing of it. You may request that your personal information is made available to you in a structured, commonly used and machine readable form and we will provide this to you within one month of any such request. This period may be extended to two months where the request is complex or we have received a number of requests but we will notify you if any such extension is necessary.
To contact us please see the relevant contact details set out below at paragraph 14. If you make an access request, we may ask you to verify your identity and put your request in writing for security reasons. We may charge a reasonable administration fee to cover the costs of meeting your request. We will reply to your request for access within one month days of notification by you unless your request is particularly complicated when we may extend this period for a reasonable amount of time and will inform you of the proposed extension.
Dealing with unsolicited information
We take all reasonable steps to ensure that all unsolicited information is destroyed or de-identified immediately.
Anonymity when dealing with us
Only where it practicable to do so, we may allow you the option not to identify yourself when dealing with us.
Collecting sensitive information
Complaints and disputes
We will ensure your compliant is handled in an appropriate and reasonable manner. Were necessary we may consult with our related entities and partners in order to deal with your complaint. A written notice of our decision regarding your complaint will be provided to you. If you are not satisfied with the outcome, then you may contact the Information Commissioner’s Office:
Information Commissioner’s Office
Phone: 0303 123 1113