NB: This policy document is (C) Copyright Digital Lawyer Suzanne Dibble and has Intellectual Property protection.
DO NOT copy it. She is a lawyer after all!
[ Click here to purchase your own GDPR pack http://clickjustclick.com/gdprsusan ]
It has been (badly) re-worded by us, to match our own business, Copyright 2018 by this websites owner.
Alongside GDPR compliance and EU Privacy laws, we have changed our legal status.
Any and all of my sole trader companies have been sold to my master limited company;
Marketing Avengers Ltd
UK registration number 11328671
International House, 12 Constance Street, London E16 2DQ, UK.
This includes (non exhaustively); K2k Group, BLT Group, Buick AI, By Buick and all other brand and product names, that I have previously used.
These legal status changes provides me with a centralised and efficient way to deal with future governance and cross border regulation.
Any legacy businesses or domain names, are now TRADING NAMES of the master limited company.
There are some exceptions, but if you don't know them, then they do not affect you as you are not trading with them.
These include (non exhaustively);
SaaS Frameworks Global Limited. A global SaaS empire including GDPR compliance and the AnyTime Webinars platforms.
Sixth Sense Media Group Ltd. A global video advertising network and portal, using AI & Big-Data shopping intelligence)
Dream Interactive Limited. A media company. Including PomodoroTV.
This privacy notice provides you with details of how we collect and process your personal data through your use of our website, including any information you may provide through our site when you purchase a product or service, sign up to our newsletter or take part in a prize draw or competition.
By providing us with your data, you warrant to us that you are over 13 years of age.
Marketing Avengers Lts is the data controller and we are responsible for your personal data (referred to as "we", "us" or "our" in this privacy notice).
If you have any questions regarding your privacy and data rights, please raise a support ticket on our helpdesk (click the graphic at top of page) and our privacy officer will help you.
Our full details are;
Full name of legal entity: Marketing Avengers Ltd is a UK limited company, registration number 11328671
Postal address: International House, 12 Constance Street, London, E16 2DQ, United Kingdom.
Please use the helpdesk to contact us, as email spam filtering makes it too unreliable.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by using our HELPDESK.
Personal data means any information capable of identifying an individual. It does not include anonymised data.
We may process certain types of personal data about you as follows:
Identity Data may include your first name, maiden name, last name, username, marital status, title, date of birth and gender.
Contact Data may include your billing address, delivery address, email address and telephone numbers.
Financial Data may include your bank account and payment card details.
Transaction Data may include details about payments between us and other details of purchases made by you.
Technical Data may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.
Profile Data may include your username and password, purchases or orders, your interests, preferences, feedback and survey responses.
Usage Data may include information about how you use our website, products and services.
Marketing and Communications Data may include your preferences in receiving marketing communications from us and our third parties and your communication preferences.
We may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your Usage Data to work out the percentage of website users using a specific feature of our site. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.
We do not knowingly collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.
Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.
We collect data about you through a variety of different methods including:
Direct interactions: You may provide data by filling in forms on our site (or otherwise) or by communicating with us by post, phone, email or otherwise, including when you:
order our products or services;
create an account on our site;
subscribe to our service or publications;
request resources or marketing be sent to you;
enter a competition, prize draw, promotion or survey; or
give us feedback.
As you use our site, we may automatically collect Technical Data about your equipment, browsing actions and usage patterns. We collect this data by using cookies, server logs and similar technologies. We may also receive Technical Data about you if you visit other websites that use our cookies.
We may receive personal data about you from various third parties and public sources as set out below.
Technical Data from the following parties, some of which may be based outside of the EU:
Analytics providers such as Google.
Advertising and Remarketing networks such as Facebook.
Help agents, chat bots and messengers.
Interactivity tracking such as from Intercom, Convertfox & our own in-house systems.
Video playback analytics from YouTube, Vimeo, Wistia and others.
Contact, Financial and Transaction Data from providers of technical, payment and delivery services, such as Paypal & Stripe.
Identity and Contact Data from data brokers or aggregators such as Albacross & Visitor Queue.
Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register.
Fraud prevention services.
We will only use your personal data when legally permitted. The most common uses of your personal data are:
Where we need to perform the contract between us.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message.
You have the right to withdraw consent to marketing at any time by contacting us via the HELPDESK, or simply clicking the unsubscribe link at the bottom of every email we send.
Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.
We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please contact us via our HELPDESK if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the list below;
Purpose/Activity | Type of data | Lawful basis for processing:
To register you as a new customer.
Performance of a contract with you
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests to recover debts owed to us
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services
To enable you to partake in a prize draw, competition or complete a survey
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests to study how customers use our products/services, to develop them and grow our business
To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise
(b) Necessary to comply with a legal obligation
To deliver relevant content and advertisements to you and measure and understand the effectiveness of our advertising
(e) Marketing and Communications
Necessary for our legitimate interests to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Necessary for our legitimate interests to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy
To make suggestions and recommendations to you about goods or services that may be of interest to you
Necessary for our legitimate interests to develop our products/services and grow our business
You will receive marketing communications from us if you have:
requested information from us or purchased goods or services from us; or
if you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications; and
in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time [by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences] OR [by following the opt-out links on any marketing message sent to you or] OR by emailing us at [INSERT EMAIL ADDRESS] at any time].[AMEND AS APPROPRIATE]
Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please contact us via our HELPDESK.
If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:
Other companies in our group who provide IT and system administration services and undertake leadership reporting.
Service providers who provide IT and system administration services.
Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
We may also use third parties for market research, fraud prevention, price comparison, onboarding and support.
Third parties to whom we sell, transfer, or merge parts of our business or our assets.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
Some of the companies that help us to run our business, may be based outside of the EAA, such as the United States of AMerica.
We share your personal data within our group of companies which involves transferring your data outside the European Economic Area (EEA).
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
Please contcat us via our HELPDESK if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.
You can see more about these rights on the official UK ICO website:
If you wish to exercise any of the rights set out above, please contact us via our HELPDESK.
You will not normally have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances;
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies.
Our website address is shown in the url above.
When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.
If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.
We use various contact forms including contact7.
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.
Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.
For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.
If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.
Visitor comments may be checked through an automated spam detection service.
Please click the graphic at the top of this page to connect with our helpdesk.
You will need to register and confirm your email, to prove your identity.
Just because it is on the net, does NOT mean it is free.
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