Data Protection Policy
Background
SR Marketing 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 all our brand ambassadors, staff, and customers, and will only collect and use personal data in ways that are described here, in a manner consistent with our obligations and your rights under the law.
1. Information About Us
SR Marketing, registered in England under company number 12807529.
Registered address: 1st Floor Courtlets House, 38 Kings Street West, M3 2WZ
Data Protection Lead:
Shaun
Email address:
shaun@srmarketing.org
2. What Does This Notice Cover?
This Privacy Notice explains how we use your personal data, how it is collected, held, and processed. It also outlines your rights under the law regarding your personal data.
3. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified by reference to an identifier’.
In simpler terms, personal data is any information about you that enables your identification. This includes obvious information like your name and contact details, as well as less apparent information such as identification numbers, electronic location data, and other online identifiers.
The personal data we use is outlined in Part 5 below.
4. What Are My Rights?
Under Data Protection Legislation, you have the following rights, which we will always strive to uphold:
- The right to be informed about our collection and use of your personal data. This Privacy Notice should provide all necessary information, but you can always reach out to us for further inquiries using the details in Part 11.
- The right to access the personal data we hold about you. Details on how to do this can be found in Part 10.
- The right to have your personal data rectified if any information we hold about you is inaccurate or incomplete. Please contact us using the details in Part 11 for assistance.
- The right to be forgotten, meaning you can request us to delete any personal data we hold about you. For more information, please refer to Part 11.
- The right to restrict the processing of your personal data.
- The right to object to our use of your personal data for specific purposes.
- The right to withdraw consent. If we rely on your consent to use your personal data, you can withdraw that consent at any time.
- The right to data portability. If you provided personal data to us directly, and we process it with your consent or for the performance of a contract, you can request a copy of that data for reuse with another service or business.
- Rights related to automated decision-making and profiling. Certain personal data may be used on an aggregated basis for territory management purposes. This profiling helps us allocate resources effectively for customer acquisition but does not involve profiling individual data subjects.
For more information about our use of your personal data or your rights, please contact us using the details in Part 11.
It’s important to keep your personal data accurate and up-to-date. If any of your personal data changes, please inform us.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any complaints about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. However, we encourage you to contact us first using the details in Part 11.
5. What Personal Data Do You Collect and How?
Depending on your use of our site, we may collect and hold some or all of the personal and non-personal data listed below. We do not collect any ‘special category’ or ‘sensitive’ personal data.
6. How Do You Use My Personal Data?
Under Data Protection Legislation, we must have a lawful basis for using personal data. The following table outlines how we use your personal data and our lawful bases for doing so:
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 the original. If we do use your data in this manner and you want us to explain how the new purpose aligns with the original, please contact us using the details in Part 11.
If we need to use your personal data for a purpose unrelated to the original, we will inform you and explain the legal basis for doing so.
In certain circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent, strictly adhering to Data Protection Legislation and your legal rights.
7. How Long Will You Keep My Personal Data?
We will not retain your personal data longer than necessary for the reasons it was initially collected. Your personal data will be kept for the following periods (or, where there is no fixed period, the following factors will determine the retention period):
8. How and Where Do You Store or Transfer My Personal Data?
We will only store or transfer your personal data within the UK and the European Economic Area (EEA), ensuring full protection under Data Protection Legislation.
The security of your personal data is paramount. To protect your data, we implement several important measures, including:
- Limiting access to your personal data to employees, agents, contractors, and third parties with a legitimate need to know, all of whom are subject to confidentiality obligations.
- Procedures for managing data breaches, including notifying you and/or the Information Commissioner’s Office when legally required.
9. Do You Share My Personal Data?
We will not share your personal data with any third parties for any purposes, except for the following circumstances:
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 may continue to use your personal data as specified in this Privacy Policy.
In limited circumstances, we may be legally obligated 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 government authority instructions.
If your personal data is shared with a third party as described above, we will ensure it is handled safely and securely, in accordance with your rights, our obligations, and the third party’s obligations under the law, as detailed in Part 8.
10. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can request details and a copy of it (where applicable). This is known as a “subject access request.”
All subject access requests should be made in writing and sent to the email provided in Part 11.
There is usually no charge for a subject access request. However, if your request is deemed ‘manifestly unfounded or excessive’ (e.g., repetitive requests), a fee may be charged to cover our administrative costs.
We will respond to your subject access request within one month of receiving it. We aim to provide a complete response, including a copy of your personal data. However, if your request is complex, we may require up to three months to respond fully. You will be kept informed of our progress.
11. How Do I Contact You?
To contact us regarding your personal data and data protection, including making a subject access request, please use the following details:
Data Protection Lead:
Shaun
Email address:
shaun@srmarketing.org
12. Changes to this Privacy Notice
We may update this Privacy Notice from time to time. Changes may be necessary if the law changes or if we modify our business in ways that affect personal data protection.
Any updates will be made available on our website. This Privacy Notice was last updated on 15th October 2024.