Privacy Policy

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Anderlea Butters Marketing Consultancy Limited takes your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use, and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

 

We collect, use, and are responsible for certain personal information about you. When we do so we are subject to the UK Data Protection Act 2018 and the General Data Protection Regulation, which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.

 

Key Terms

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It would be helpful to start by explaining some key terms used in this policy:

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• We, us, our - Anderlea Butters Marketing Consultancy Limited

• Our data protection officer - Anderlea Butters, anderlea@anderleabutters.com

• Personal information - Any information relating to an identified or identifiable individual

• Special category personal information - Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership, genetic and biometric data, data concerning health, sex life or sexual orientation

 

Personal Information We Collect About You

 

We may collect and use the following personal information about you:

 

• Your name and contact information, including email address and telephone number (and company details)

• Information to enable us to check and verify your identity, EG your date of birth

• Your gender information (if you choose to supply this)

• Location data (if you choose to supply this)

• Your billing information, transaction, and payment card information

• Your personal or professional interests

• Your professional online presence EG LinkedIn profile

• Your contact history, purchase history, and saved items

• Information from accounts you link to us EG Facebook

• Information to enable us to undertake credit or other financial checks on you

• Information about how you use our website, IT, communication, and other systems

• Your responses to surveys, competitions, and promotions

 

This personal information is required to provide you with marketing consultancy services. If you do not provide the personal information we ask for, it may delay or prevent us from providing this service to you.

 

How Your Personal Information Is Collected

 

We collect most of this personal information directly from you—in person, by telephone, text, or email, and/or via our website. However, we may also collect information: 

 

• From publicly accessible sources EG Companies House or HM Land Registry

• Directly from a third party EG sanctions screening providers, credit reference agencies, customer due diligence providers 

• From a third party with your consent 

• From cookies on our website—for more information on our use of cookies, please see our cookies policy

• Via our IT systems EG automated monitoring of our websites and other technical systems, such as our computer networks and connections, communications systems, email, and instant messaging systems

 

How And Why We Use Your Personal Information

 

Under data protection law, we can only use your personal information if we have a proper reason for doing so:

 

• To comply with our legal and regulatory obligations

• For the performance of our contract with you or to take steps at your request before entering into a contract

• For our legitimate interests or those of a third party; or

• Where you have given consent

 

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

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The information below explains what we use (process) your personal information for and our reasons for doing so:

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To provide marketing consultancy services to you

For the performance of our contract with you or to take steps at your request before entering into a contract

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To prevent and detect fraud against you or Anderlea Butters Marketing Consultancy Limited

For our legitimate interests or those of a third-party IE to minimise fraud that could be damaging for us and for you

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Conducting checks to identify our customers and verify their identity

To comply with our legal and regulatory obligations

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Screening for financial and other sanctions or embargoes

To comply with our legal and regulatory obligations

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Other processing necessary to comply with professional, legal, and regulatory obligations that apply to our business EG under health and safety regulation or rules issued by our professional regulator

To comply with our legal and regulatory obligations

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Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies

To comply with our legal and regulatory obligations

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Ensuring business policies are adhered to EG policies covering security and internet use

For our legitimate interests or those of a third party IE to make sure we are following our own internal procedures so we can deliver the best service to you

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Operational reasons, such as improving efficiency, training, and quality control

For our legitimate interests or those of a third party IE to be as efficient as we can so we can deliver the best service for you at the best price

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Ensuring the confidentiality of commercially sensitive information

For our legitimate interests or those of a third party IE to protect trade secrets and other commercially valuable information and to comply with our legal and regulatory obligations

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Statistical analysis to help us manage our business EG in relation to our financial performance, customer base, product range, or other efficiency measures

For our legitimate interests or those of a third party IE to be as efficient as we can so we can deliver the best service for you at the best price

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Preventing unauthorised access and modifications to systems

For our legitimate interests or those of a third party IE to prevent and detect criminal activity that could be damaging for us and for you and to comply with our legal and regulatory obligations

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Updating (and enhancing) customer records

For the performance of our contract with you or to take steps at your request before entering into a contract, to comply with our legal and regulatory obligations, and for our legitimate interests or those of a third party 

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Ensuring safe working practices, staff administration and assessments

For our legitimate interests or those of a third party EG to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you and to comply with our legal and regulatory obligations

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Marketing our services (and those of selected third parties where we have consented) to existing and former customers

For our legitimate interests or those of a third party IE to promote our business to existing and former customers

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Credit reference checks via external credit reference agencies

For our legitimate interests or those of a third party IE to ensure our customers are likely to be able to pay for our products and services

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External audits and quality checks EG for the audit of our accounts

For our legitimate interests or those of a third party IE to maintain our accreditations so we can demonstrate we operate at the highest standards and to comply with our legal and regulatory obligations

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The above table does not apply to special category personal information, which we will only process with your explicit consent.

 

We have determined, acting reasonably and considering the circumstances, that we are able to rely on legitimate interests as the lawful basis on which to process your personal information in certain circumstances (we have stated this above and set out our legitimate interests). We have reached this decision by carrying out a balancing exercise to make sure our legitimate interest does not override your privacy rights as an individual. 

 

We consider that it is reasonable for us to process your information for the purposes of our legitimate interests outlined above as: (a) we process your information only so far as is necessary for such purpose, and (b) it can be reasonably expected for us to process your information in this way.  

 

Promotional Communications

 

We may use your personal information to send you updates (by email, text message, telephone, or post) about our products AND/OR services, including exclusive offers, promotions, or new products AND/OR services.

 

We have a legitimate interest in processing your personal information for promotional purposes (see above ‘How and why we use your personal information’). However, where consent is needed, we will ask for this consent separately and clearly.

 

We will always treat your personal information with the utmost respect and never [sell OR share] it with other organisations for marketing purposes.

 

You have the right to opt out of receiving promotional communications at any time by:

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• Contacting us directly

• Using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts

 

We may ask you to confirm or update your marketing preferences if you instruct us to provide further [products AND/OR services] in the future, or if there are changes in the law, regulation, or the structure of our business.

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Who We Share Your Personal Information With

 

We routinely share personal information with:

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• Third parties we use to help deliver our products AND/OR services to you EG payment service providers

• Other third parties we use to help us run our business EG marketing agencies or website hosts

• Third parties approved by you EG social media sites you choose to link your account to or third party payment providers, credit reference agencies, our insurers and brokers, our bank and accountant

 

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors EG in relation to the audit of our accounts.

 

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations. 

 

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a restructuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

 

We will not share your personal information with any other third party.

 

Where Your Personal Information Is Held

 

Information may be held at our offices, third-party agencies, service providers, representatives, and agents as described above (see above: ‘Who we share your personal information with’).

 

Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: 

 

‘Transferring your personal information out of the EEA’.

 

How Long Your Personal Information Will Be Kept

 

We will keep your personal information while you have an account with us or we are providing [products AND/OR services] to you. Thereafter, we will keep your personal information for as long as is necessary:

 

• To respond to any questions, complaints, or claims made by you or on your behalf

• To show that we treated you fairly

• To keep records required by law

 

Retention Of Your Personal Information

 

We will not retain your personal information for longer than necessary for the purposes set out in this policy below. Different retention periods apply for different types of personal information. 

 

When it is no longer necessary to retain your personal information, we will delete or anonymise it.

 

Transferring your personal information out of the EEA

To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA) EG

 

• With your and our service providers located outside the EEA

• If you are based outside the EEA

• Where there is an international dimension to the services we are providing to you.

 

These transfers are subject to special rules under European and UK data protection laws.

 

Non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission. 

 

Your Rights

 

You have the following rights, which you can exercise free of charge:

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Access

The right to be provided with a copy of your personal information (the right of access)

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Rectification

The right to require us to correct any mistakes in your personal information

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To be forgotten

The right to require us to delete your personal information – in certain situations

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Restriction of processing

The right to require us to restrict processing of your personal information – in certain circumstances EG if you contest the accuracy of the data

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Data portability

The right to receive the personal information you provided to us, in a structured, commonly used, and machine-readable format and/or transmit that data to a third party – in certain situations

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To object

The right to object: at any time to your personal information being processed for direct marketing (including profiling) or in certain other situations to our continued processing of your personal information EG processing carried out for the purpose of our legitimate interests

 

Not to be subject to automated individual decision-making

The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

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Withdraw consent

You can withdraw your consent although this does not impact the processing up to the point of withdrawal

 For further information on each of those rights, including the circumstances in which they apply, please contact us - see below 'How to contact us'.

 

If you would like to exercise any of those rights, please:

 

• email, call or write to us OR our Data Protection Officer – see below: ‘How to contact us’

• Let us have enough information to identify you EG your full name and address

• Let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and

• Let us know what right you want to exercise and the information to which your request relates.

 

Keeping Your Personal Information Secure

 

We have appropriate security measures to prevent personal information from being accidentally lost, used, or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. 

 

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

 

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses, and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

 

How To Complain

 

We hope that (we OR our Data Protection Officer) can resolve any query or concern you may raise about our use of your information. The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner.

 

Changes To This Privacy Policy

 

We may change this privacy notice from time to time – when we do we will inform you.

 

How To Contact Us

 

Please contact us [and/or our Data Protection Officer] by post, email, or telephone if you have any questions about this privacy policy or the information we hold about you.

 

Our contact details are shown below:

 

Anderlea Butters Marketing Consultancy Limited

 

Address:

McCue House, 70 Wilton Road, Humberston, DN36 4AW

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Email Address:

anderlea@anderleabutters.com