This notice is layered, so you can easily find the information that is applicable to you. Please click the through to the headings or subheadings of the specific areas set out below to read the full text.
There is a Glossary of terms at the end of this document to help you understand the meaning of some of the terms used in this privacy notice.
Please read this Privacy Notice and any other privacy notice or fair processing notice we may provide on specific occasions carefully, as it is meant to help you understand what information we collect, why we collect it, and how you can update, manage, export and delete your information.
This Privacy Notice supplements the other notices and is not intended to override them.
We do not and will not sell your data to third parties.
We are the Marketing Lounge Partnership Limited (MLP) and are the parent company of different legal entities, details of which can be found on Companies House.
This privacy notice is issued on behalf of the MLP Group so when we mention “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the MLP Group responsible for processing your personal data.
MLP Group
Parent Company
The Marketing Lounge Partnership Limited (MLP), a company incorporated and registered in England and Wales with company number 06467245, whose registered office is at the Cow Shed, Walnut Tree Farm, Lower Stretton, Cheshire, United Kingdom, WA4 4PG.
ICO Reference number: Z1417385
Subsidiary Organisations
- MLP Fulfilment Services Limited, a company incorporated and registered in England and Wales with company number 08293983, whose registered office is at the Cow Shed, Walnut Tree Farm, Lower Stretton, Cheshire, United Kingdom, WA4 4PGICO Reference number: Z3440243
- Mottcombe Lowndes Limited, a company incorporated and registered in England and Wales with company number 12812641, whose registered office is at the Cow Shed, Walnut Tree Farm, Lower Stretton, Cheshire, United Kingdom, WA4 4PGICO Reference number: Z2931132
Websites
The following websites are in scope of this privacy notice:
Controller
The Marketing Lounge Partnership Limited acts as the Controller ( for all the organisations within the group that are covered by the scope of this privacy notice. This means that The Marketing Lounge Partnership (MLP) determines what data is collected by each organisation within the group, how this data is going to be used and how this data is protected.
MLP do host and manage campaigns on behalf clients. We host and manage those campaigns as a Processor acting on behalf of those clients, who are the Controller of the personal data we collect, process, share and transfer on those Controllers’ behalf. We recommended you refer to the privacy notice on each campaign website directly.
Our commitment to you
We respect your right to privacy and are committed to protecting it and complying with Data Protection Law. We will always keep your Personal Data safe. We will be clear and open with you about why we collect your Personal Data and how we use it. Where you have choices or rights, we will explain them to you and respect your wishes.
If you have questions about this Privacy Notice or the processing of your Personal Data, please contact us at:
Postal address
The Cow Shed, Walnut Tree Farm, Lower Stretton, Cheshire WA4 4PG United Kingdom.
We have appointed IT Governance Europe Ltd to act as our EU representative. If you wish to exercise your rights under the EU General Data Protection Regulation (EU GDPR), or have any queries in relation to your rights or general privacy matters, please email our representative at eurep@itgovernance.eu.
Please ensure you include our company name in any correspondence you send to our representative.
We may collect, use, store and transfer different kinds of Personal Data about you depending on our relationship with you
Identity data
Includes title, first name, last name, other names, date of birth, age or email address.
Other Identifiers
Telephone number, or Passport .
Contact data
Includes your contact address, billing address, email address or telephone number(s).
Location data
We may collect your location data from your IP address or telephone area codes.
We may collect proof of purchase, invoice number, personal and company billing addresses or trade account numbers.
Transaction data
Includes details about payments to and from you and other details of services you have purchased from us.
Payment data
Payments are made to customers as a reward incentive by BACS payment or cheques using the data subject’s information contained within other identifiers. Any supplier payments are made in the same way using information held within MLP Account Software.
Technical data
Includes IP address, your login information, time zone setting and location, browser plugin types and versions, operating system and platform, and other technology on the devices you use to access our website or our Apps
Profile data
Includes your email and password, the services you have used on our website [or our Apps], your use of social media functions on our Website [or our Apps] for [authentication, feedback, survey responses and such information as you provide to us].
Usage data
Includes information about how you use our Website ,the resources you access, pages you visit, the time and date of your visit or an email opened, the time spent on those pages, unique device identifiers, the URL (Uniform Resource Locator) clickstream to, through and from our website and other diagnostic data.
Further information will be required for successful candidates, such as, National Insurance Number, reference details, passport or driver’s license for DBS checks and rights to work within the UK.
Marketing and communications data
Includes your preferences in receiving marketing from us and our third parties and your communication preferences and records of our correspondence with you.
We may use technologies, such as tracking pixels (also called 1×1 pixels or pixel tags), to collect the above information from your interaction with emails we send you. This enables us to focus our marketing, leading to more relevant emails to our subscribers. It also helps us to identify subscribers that are not engaged with our marketing emails, enabling us to remove them from our send lists. For more information about the tracking pixels please see our
Chat sessions
This information includes online chat sessions and the chat history of previous sessions. For customer queries via chat sessions and verbal communications will need to undergo a two-step verification
Special Category Personal Data
No special category data is collected by MLP under this privacy notice.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific Website feature.
However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data, which will be used in accordance with this Privacy Notice.
We may use different methods to collect data from and about you through our websites, website live chat, by telephone, and through any , including LinkedIn, Facebook and Twitter.
Personal Data provided directly by you
You may give us your Personal Data by filling in forms, surveys, questionnaires or assessments on our Website, by applying to work for or with us or by corresponding with us by post, phone, email, chat or otherwise. This includes Personal Data you provide when you:
- Register to use our Apps, Website or services, or to receive general, marketing or commercial information;
- Submitting contact / enquiry forms
Data we collect when you use our Websites and Apps
Each time you interact with our Website, we will automatically collect Personal Data, including technical data about your device, your browsing actions and patterns, content and usage data. We collect this data using Cookies, server logs and other similar technologies like pixels, tags and other identifiers in order to remember your preferences, to understand how our Website and Apps are used, and to customise our marketing offerings and to continually improve customer journeys.
Please see our Cookie Notice for further details.
Information we receive from third parties
We may receive Personal Data about you from various third parties, such as:
- Device data from the following parties:
- Analytics providers such as Google.
- https://fingerprintjs.com/ and https://www.transunion.com/
- Contact, financial and transaction data from providers of technical, payment and delivery services.
- Technical data and device data from the following parties:
- Information about our candidates from referees, recruitment agencies and social media such as LinkedIn;
- Fraud prevention tool https://fingerprintjs.com/ and https://www.transunion.com/
- Address lookups, sending the 3rd party a postcode only. https://api.getaddress.io
- Latitude and Longitude lookups, sending the 3rd party a postcode only. https://api.postcodes.io
- Car Registration / made and model lookups, sending the 3rd party a Car Registration only. https://uk1.ukvehicledata.co.uk
- Google Translate / Used to translate informational text within a customer query submitted on campaign-related websites from one language into another. https://cloud.google.com/translate/data-usage
Information we receive from public sources
Identity and contact data from publicly available sources such as the UK Companies House and the electoral register inside the UK .Publicly available data sources are used for Postcode and address or vehicle registration lookups.
Unique application numbers
When you want to install or uninstall a service containing a unique application number or when such a service searches for automatic updates, that number and information about your installation, for example the type of operating system, may be sent to us.
General
We need your Personal Data to conduct our business and provide you with our services. Most commonly we will use your Personal Data in the following circumstances:
- Where you have consented before the processing.
- Where we need to perform a contract, we are about to enter or have entered with you.
- 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.
UK GDPR/EU GDPR Lawful Basis table
The table below describes the ways we plan to use your Personal Data, and which Lawful Basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.
For more information on the Lawful Basis we use to process your data under the UK GDPR and EU GDPR, see our Lawful Basis table below or contact us.
| LAWFUL BASIS | PURPOSE EXAMPLES |
| Contractual We use your Personal Data on the basis that it is necessary for us to provide our services and products to you. When you sell or purchase a service and/or use our Apps and Website or register with us, you are entering into a contract with us. | OnboardingWhen you register as a new client, supplier, claim an incentive or benefit or join one of our loyalty programs. We may use your personal, contact, technical, profile and marketing and communication data. Service deliveryIn order to be able to deliver our services or receive services in physical or digital form. To provide you with information, products or services that you requested from MLP and to notify you about changes to our service. The fulfilment and distribution of physical and digital products to our users. When we manage and store your chat sessions. We use your personal, contact, technical, profile and marketing and communication data to deliver our services to you. Account administration
We use Identity Data, Contact Data, Loyalty Data, Payment Data, Transaction Data to administer accounts Relationship managementTo manage our relationship with you, which may include:
We use Identity Data, Other Identifiers, Contact Data, Location Data, Transaction Data, Profile Data, Marketing and Communications Data, Chat Sessions to manage our relationship with you. CommunicationTo be able to contact you regarding updates or informative communications related to the functionalities, products, or contracted services, including security updates, when necessary or reasonable for their implementation. Handling the information, you submit to us enables us to respond effectively. We may also keep a record of these queries to inform any future communications between us and to demonstrate how we communicated with you throughout our contractual relationship. We use Identity Data, Contact Data, Transaction Data, Profile Data, Marketing and Communications Data and Chat Sessions to help us to communicate with you. |
| Legitimate interest When we rely on this, we will carry out a Legitimate Interests Assessment to ensure we consider and balance any potential impact on you (both positive and negative), and your rights under Data Protection Law. Our legitimate business interests do not automatically override your interests – we will not use your Personal Data for activities where our interests are overridden by the impact on you unless we have your consent or are otherwise required or permitted to by law. | Managing our businessWe hold Personal Data for our own legitimate business interest. This relates to us managing our business to enable us securely to provide our service/products:
and in the context of a business reorganisation or group restructuring exercise. We may use your personal, contact, technical, profile and marketing and communication data. It is necessary to process this personal data 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. Provide and maintain Websites and Apps.It is in our legitimate interests to process personal data for our legitimate interests for running our business, provision of administration and IT services, network security and
The personal data we use to provide and maintain Websites and Apps includes Identity Data, Other Identifiers, Contact Data, Location Data, Technical Data, Transaction Data, Profile Data, Chat Sessions, Usage Data, Loyalty Data, Candidate Data, Marketing and communications data, and Aggregated data. Recommendations and marketingIt is in our legitimate interests to use marketing to grow our business and ensure commercia viability by marketing to and we use personal data to:
We use personal data from existing clients for these purposes and this data includes Identity Data, Other Identifiers, Contact Data, Location Data, Technical Data, Transaction Data, Profile Data, Chat Sessions, Usage Data, Loyalty Data, Candidate Data, Marketing and communications data, and Aggregated data. SecurityIt is in our legitimate interests to process personal securely to maintain network security and:
Recruitment of candidates (contractors, employees and providers)We will use the personal information we collect about you to assess your skills, qualifications and suitability for the work. It is in our legitimate interests to decide whether to appoint you to work with us since it would be beneficial to our business to appoint someone with the correct qualifications and experience to be able to do their job efficiently and beneficially to our company. We use Identity Data, Contact Data, Location Data and Candidate Data to assess your suitability for a position and to communicate with candidates. ReviewsWhen we capture your service reviews, for example when you buy goods and services from us, we may follow it up with an enquiry about your experience of the service to help us gauge customer satisfaction. It is in our legitimate interests to ensure our survival in a competitive market by ensuring that our services and goods are market appropriate and delivered satisfactorily to our clients and users. We use Identity Data, Contact Data, Transaction, Marketing and Communications Data, Chat Sessions to be able to properly communicate and respond to reviews. Research and analysisFor statistical analysis, so that we can monitor and improve services, Websites and Apps, or develop new ones and we may also aggregate personal data for these purposes. It is necessary to us and in our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy). We use Identity Data, Other Identifiers, Contact Data, Location Data, Loyalty Data, Technical Data, Payment Data, Transaction Data, Profile Data, Candidate Data, Marketing and Communications Data, Chat Sessions, Aggregated Data and Usage Data for research and statistical analysis the type of personal data we use depends on the nature of the research and analysis. Data analyticsWe use data analytics to improve our Website, products/services, marketing, customer relationships and experiences. our products/services so we are able to develop our products and services and keep our website and services updated and relevant. We need this information to develop our business and to inform our marketing strategy to ensure the growth of our business. We may use Location Data, Technical Data, Payment Data, Transaction Data, Profile Data, Chat Sessions, Aggregated Data and Usage Data for data analytics. Rights and claimsIt is in our legitimate interests to use personal data, where it is necessary,
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud. We may use Identity Data, Other Identifiers, Contact Data, Location Data, Loyalty Data, Technical Data, Payment Data, Transaction Data, Profile Data, Candidate Data, Marketing and Communications Data, Chat Sessions, Aggregated Data, Usage Data for these purposes. |
| Legal obligations We may use your Personal Data to comply with laws (for example, if we are required to co-operate with a police investigation after a court order orders us to). | Legal requirementThe processing is necessary for compliance with our legal obligations, such as but not limited to healthcare requirements, security requirements and accounting requirements. To comply with applicable law, for example in response to a request from a court or regulatory body, where such request is made in accordance with the law. We may use Identity Data, Other Identifiers, Contact Data, Location Data, Loyalty Data, Technical Data, Payment Data, Transaction Data, Profile Data, Candidate Data, Marketing and Communications Data, Chat Sessions, Aggregated Data, Usage Data for these purposes. Data subject rightsVerifying your identity when you exercise your data subject rights. Fulfilling data subject rights requests. We may use Identity Data, Other Identifiers, Contact Data, Location Data, Loyalty Data, Technical Data, Payment Data, Transaction Data, Profile Data, Candidate Data, Marketing and Communications Data, Chat Sessions, Aggregated Data, Usage Data for these purposes, dependent on the Data Subject request itself. Criminal activityTo detect fraudulent or criminal activity, we may share information with forces such as the police. We may use Identity Data, Other Identifiers, Contact Data, Location Data, Loyalty Data, Technical Data, Payment Data, Transaction Data, Profile Data, Candidate Data, Marketing and Communications Data, Chat Sessions, Aggregated Data, Usage Data for these purposes. |
| Consent We may have to get your consent to use your Personal Data, such as when we collect and use Special Category Personal Data about you or when we have a Legitimate interest to email you for marketing purposes etc. We will get your consent before sending third-party direct marketing communications to you via email or text message or before processing any Personal Data relating to your health. You have the right to withdraw consent to marketing at any time by contacting us. Wherever consent is the only reason for using your Personal Data, you have the right to change your mind and/or withdraw your consent at any time by clicking the Unsubscribe button at the bottom of an applicable email or our contact us form. | Marketing
We may use Identity Data, Contact Data, Location Data, Technical Data, Marketing and Communications Data, Chat Sessions, for these purposes. Special Category Personal Data
InstallationTo install an App and register you as a new App user. We may use Identity Data, Contact Data, Location Data, Loyalty Data, Technical Data, Marketing and Communications Data, Chat Sessions and Usage Data for these purposes LocationWhen you download our mobile Apps or use our website, you may allow us to obtain your precise location from your device. We use this information to deliver personalised content and for analytics. We may use Location Data, Technical Data, Payment Data, and Usage Data for these purposes. Push notificationsWe may also offer automatic (‘push’) notifications. We will provide push notifications only if you opt-in to receive them. You do not have to provide location information or enable push notifications to use our mobile Apps. We may use Location Data, Technical Data, Payment Data, Profile Data, and Usage Data for these purposes. |
Reason for processing Special Category Personal Data:
Where we are processing your Special Category Personal Data, we must, in addition to the Lawful Basis in the Lawful Basis table, process your Special Category Personal Data because of an additional condition, including:
- You have given us your explicit consent to process that data;
- We are required by law to process that data in order to ensure we meet our ‘know your client’ and ‘anti-money laundering’ obligations (or other legal obligations imposed on us);
- The processing is necessary to carry out our obligations under employment, social security, or social protection law;
- The processing is necessary for the establishment, exercise, or defence of legal claims;
- You have made the data manifestly public; or
- Processing is necessary for archiving purposes in the public interest, scientific or historical research purposes.
Commonly we will process that data:
- On your express consent; or
- On the basis of scientific research in the public interest.
For more information about us using your Special Category Personal Data, please see the Special Category Personal Data table below or contact us. The ICO has some useful information here.
We will only use your personal information 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 we need to use your personal information for an unrelated purpose, we will notify you and we will explain the Lawful Basis that allows us to do so.
Using Personal Data for marketing purposes
We may use your information to provide you with details about services.
Where we are legally required to obtain your consent to provide you with certain marketing materials, we will only provide you with such marketing materials where we have obtained such consent from you.
You can opt out of us using your personal information for marketing purposes by following the included in each marketing email or by contacting MLP via our ‘contact us’ forms.
Sharing your Personal Data safely
We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law.
We do not allow our third-party service providers to use your Personal Data for their own purposes. We only permit them to process your Personal Data for specified purposes and in accordance with our instructions.
We ensure that the personal data being supplied is also limited with the minimum being used for each of the services provided by the third-party service providers.
We may share your personal information with the following organisations that help us manage our business and deliver our products, applications, or services, or where we are legally obliged to share information, including with:
Twilio
IVR voice to API calls – Sending only the limited input requests. Twilio storing the phone number only.
More information can be found here https://www.twilio.com/gdpr
Get Address
Used to get a list of addresses within a postcode to allow automated form updated. Sending the 3rd party, a postcode only.
More information can be found here https://ideal-postcodes.co.uk/privacy_policy
Ideal Postcodes
Used for Latitude and Longitude, for example find an offer near me. Sending the 3rd party a postcode only.
More information can be found here https://ideal-postcodes.co.uk/privacy_policy
UK Vehicle Data
Car Registration Lookup to get full car details, Sending the 3rd party a Car Registration only.
More information can be found here https://ukvehicledata.co.uk/policies/GDPR-Privacy-Policy
TransUnion
Fraud prevention tool sending IP and various device information.
More information can be found https://www.transunion.co.uk/legal/privacy-centre
Fingerprints
Fraud prevention tool sending IP and various device information.
More information can be found here https://dev.fingerprintjs.com/v2/docs/privacy-policy
Location
https://www.transunion.com Fraud prevention tool sending IP and various device information.
More information can be found here https://www.transunion.com/privacypolicy/main?policy=main
Stripe
- https://stripe.com/
- Online payment gateway we use for payment processing;
Sending Customer Names, Banks details, Address
More information can be found here https://stripe.com/gb/privacy
Crunch payments
- https://crunchpayments.com
Used to create a Mastercard and load required goodwill funds. Sending the 3rd party first name, last name, DOB, proof of identification information.
More information can be found here https://crunchaccount.com/policies/Crunch%20Cardholder%20Privacy%20Policy.pdf
Google Translate
Used to translate informational text within a customer query submitted on the campaign delivery website from one language into another. Sending the 3rd party any information contained within the customer query submission. Google does not use any of your content for any purposes except to provide you with the translated text service.
More information can be found here https://cloud.google.com/translate/data-usage
Ideal Postcodes
Used for Latitude and Longitude, for example find an offer near me. Sending the 3rd party a postcode only.
More information can be found here https://ideal-postcodes.co.uk/privacy_policy
Text local
- https://www.textlocal.com/
Used to send SMS messages. Sending the 3rd party first name, last name, phone number.
More information can be found here https://www.textlocal.com/legal/privacy/
Mail Services and Couriers
- https://www.royalmail.com/
Used to fulfil incentives to customers. . Sending the 3rd party a first name, last name and full mailing address.
More information can be found here https://www.royalmail.com/privacy-notice
DPD
- https://www.dpd.co.uk/
Used to fulfil incentives to customers. . Sending the 3rd party a first name, last name and full mailing address.
More information can be found here https://www.dpd.co.uk/privacy_policy.jsp
Parcel Force
- https://www.parcelforce.com
Used to fulfil incentives to customers. . Sending the 3rd party a first name, last name and full mailing address.
More information can be found here https://www.parcelforce.com/privacy
- https://www.google.com
Google Analytics is a third-party service provider to assist us with client insight analytics
Used to tracking page views. Sending the 3rd party Page Information (URL, Title), Browser Information (Browser name, Viewport or Viewing pane, Screen resolution, Java enabled, Flash version), User Information (Location – IP address, Language).
More information can be found here https://policies.google.com/privacy?hl=en-US
- Third parties to which we outsource certain services such as couriers, IT systems or software providers, IT support service providers, and document and data storage providers;
- Third-party platforms to manage and deliver customer relationship management (CRM);
- Third parties for the purposes of App development;
- Third parties in the event of any merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our assets (including without limitation in connection with any bankruptcy or similar proceedings);
- Other organisations for the purposes of fraud/crime protection and investigation;
- Courts of law and government, regulatory authorities or third parties to the extent required by law, court order or a decision rendered by a competent public authority and for the purpose of law enforcement.
- We use IT systems or software providers, IT support service providers, document and data storage providers.
- We use third-party platforms to manage and deliver customer relationship management (CRM).
- Third parties for the purposes of App
Business Services
Third parties in the event of any merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our assets (including without limitation in connection with any bankruptcy or similar proceedings);
Law and Investigations
- Other organisations for the purposes of fraud/crime protection and investigation;
- Courts of law and government, regulatory authorities or third parties to the extent required by law, court order or a decision rendered by a competent public authority and for the purpose of law enforcement.
Why we share your Personal Data
As a general principle, we share data in order to facilitate or improve our services or offers. We will get your express opt-in consent before we share your Personal Data with any third party for marketing purposes.
You can opt out of us using your personal information for marketing purposes by following the unsubscribe link included in each marketing email or by contacting us via our contact us form.
From time to time, we may share Personal Data and other information that we have collected about you:
- To get help in running our business, and delivering our products, Apps and services;
- Where we are legally required to do so, such as in response to court orders or legal process, or to establish, protect or exercise our legal rights or to defend against legal claims or demands;
- Where we are acquired by or merged with another entity (in which case we will require such entity to assume our obligations under this Privacy Notice or inform you that you are covered by a new privacy notice);
- If we believe it is necessary in order to investigate, prevent or act regarding illegal activities, fraud, or situations involving potential threats to the rights, property or personal safety of any person, or other exigent circumstances; or
- If we believe it is necessary to investigate, prevent or act regarding situations that involve abuse of our infrastructure or the Internet in general (such as voluminous spamming, denial-of-service attacks, or attempts to compromise the security of the Website infrastructure), or to otherwise protect our assets or rights.
Sharing your Personal Data overseas
Please note that we may send personal information outside of the country generally for, but not limited to, reasons relating to processing and storage by our service providers. For example, we may have
When we do this, we will ensure it has an appropriate level of protection and the transfer is made in line with Data Protection Law. Often, this protection is set out under a contract with the organisation that receives that information. You can find more details of the protection given to your information when it is transferred overseas by contacting us.
Example services include:
Twilio
IVR voice to API calls – Sending only the limited input requests. Twilio storing the phone number only.
More information can be found here https://www.twilio.com/gdpr
Iovation
https://www.transunion.com Fraud prevention tool sending IP and various device information.
More information can be found here https://www.transunion.com/privacypolicy/main?policy=main
Stripe
- https://stripe.com/
- Online payment gateway we use for payment processing;
Sending Customer Names, Banks details, Address
More information can be found here https://stripe.com/gb/privacy
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 that have a business need to know. They will only process your Personal Data on our instructions, and they are subject to a duty of confidentiality.
We periodically test the security of our systems to check for vulnerabilities.
Risk
Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your Personal Data, we do not have any control over what happens between your device and the boundary of our information infrastructure. You should be aware of the many Information Security Risks that exist and take appropriate steps to safeguard your own information.
Breaches
We 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.
You should be aware that information about your use of the website (including your IP address) may be retained by your ISP (Internet Service Provider) , the hosting provider and any third party that has access to your Internet traffic.
Our Website and Apps may contain links to third-party websites and plugins, for instance a social media login plugin. If you choose to use these websites, plugins, or services, you may disclose your information to those third parties.
We are not responsible for the content or practices of those websites, plugins, or services. The collection use and disclosure of your Personal Data will be subject to the privacy notices of these third parties and not this Privacy Notice. We urge you to read the privacy and cookie notices of the relevant third parties.
We do not target children, and our Website, Services and Apps are not intended to attract children. Accordingly, our online services that collect Personal Data are not directed at and and we request that such individuals do not provide any Personal Data to us, including via Cookies, please see our for further information.
Minors must obtain express consent from parents or legal guardians before accessing or providing any Personal Data. If notified by a parent or guardian, or discovered by other means, that a minor under the age of 18 has provided their Personal Data to us, we will delete the minor’s Data that is in our possession.
We will keep your Personal Data in line with our data retention policy for no longer than is 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 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.
We use Cookies and similar technologies like pixels, tags, and other identifiers to remember your preferences, to understand how our Website and our Apps are used, and to customise our marketing offerings.
Further details can be found in our Cookie Notice.
You have several rights under Data Protection Law. The rights available to you depend on our reason for processing your information and are set out in the Table of your rights of Rights. Information on your rights under Data Protection Law can also be found at https://ico.org.uk/for-the-public/.
| YOUR RIGHT | DETAILS |
| Right to be informed | We have a legal obligation to provide you with concise, transparent, intelligible, and easily accessible information about your personal information and our use of it. We have written this notice to do just that, but if you have any questions or require more specific information, you can contact us. |
| Right of access | You have the right to ask us for copies of your personal information. This right always applies. There are some exemptions, which means you may not always receive all the information. When you request this data, this is known as making a data subject access request (DSAR). In most cases, this will be free of charge; however, in some limited circumstances, for example repeated requests for further copies, we may apply an administration fee. Please contact us for more information. |
| Right to rectification | You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies. Please contact us for more information. |
| Right to erasure | You have the right to ask us to erase your personal information in certain circumstances. We have the right to refuse to comply with a request for erasure if we are processing the Personal Data for one of the following reasons:
Please contact us for more information to exercise this right. |
| Right to restriction of processing | You may ask us to stop processing your Personal Data. We will still hold the data but will not process it any further. This right is an alternative to the right to erasure. If one of the following conditions applies, you may exercise the right to restrict processing:
Please contact us for more information to exercise this right. |
| Right to object to processing | You have the right to object to processing in certain circumstances. You can also object if the processing is for a task carried out in the public interest, the exercise of official authority vested in you, or your legitimate interests (or those of a third party). Please contact us for more information to exercise this right. |
| Right to data portability
| This right only applies if we are processing information based on your consent or for the performance of a contract and the processing is automated. Please contact us for more information to exercise this right. |
How to exercise your rights
In most circumstances, you do not need to pay any charge for exercising your rights. We have one month to respond to you.
To exercise your rights or get more information about exercising them, please contact us, giving us enough information to identify you.
We hope that we can resolve any query or concern you raise about our use of your information. Please first and title your email “Complaint”. All complaints will be treated in a confidential manner and we will try our best to deal with your concerns. The Marketing Lounge Partnership is committed to manage complaints promptly, effectively and fairly.
You have the right to lodge a complaint with a supervisory authority in the EEA member state where you work or normally live, or where any alleged infringement of Data Protection Law occurred.
The supervisory authority in the UK is the ICO, which may be contacted at https://ico.org.uk/concerns or by telephone on 0303 123 1113.
Glossary
| Aggregated Data | means data that can be compiled from numeric or non-numeric data. The data is collected and summarised for the purpose of statistical analysis or reporting. It is limited to recognising general trends due to the non-specific nature of the information. It could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. |
| Anonymisation | means a type of information sanitisation whose intent is privacy protection. It is the process of removing personally identifiable information from data sets, so that the people whom the data describe remain anonymous. In order to be truly anonymised under the UK GDPR and EU GDPR, the personal data must be stripped of sufficient elements that mean the individual can no longer be identified. However, if you could at any point use any reasonably available means to re-identify the individuals to which the data refers, that data will not have been effectively anonymised but will have merely been pseudonymised and subject to data protection law. |
| App(s) | means an application that is a computer program or piece of software designed for a particular purpose that you can download onto a mobile phone or other mobile device.AppsCurrently no publicly published apps are available. |
| Consent | The UK GDPR. and EU GDPR. sets a high standard for consent , consent should be given by a clear affirmative act establishing a freely given, specific, informed, and unambiguous indication of the data subject’s agreement to the processing of personal data relating to him or her, such as by a written statement, including by electronic means, or an oral statement. |
| Controller | means the natural or legal person, public authority, agency or any other entity or person who alone or jointly with others determines the purposes and means of the processing of personal data. Our entry as a Controller on the ICO’s Data protection register can be found on the ICO website. MLP Fulfilment Services Limited The Cow Shed, Walnut Tree Farm, Lower Stretton, Cheshire, United Kingdom, WA4 4PG Reference: Z3440243 MOTTCOMBE LOWNDES LIMITED The Cow Shed, Walnut Tree Farm, Lower Stretton, Cheshire, United Kingdom, WA4 4PG Reference: Z2931132 The Marketing Lounge Partnership Limited The Cow Shed, Walnut Tree Farm, Lower Stretton, Cheshire, United Kingdom, WA4 4PG Reference: Z1417385 |
| Cookies | means a small file of letters and numbers that is stored on a browser or the hard drive of a computer. Cookies contain information that is transferred to a computer’s hard drive. Controllers must have users’ informed consent before storing cookies on a user’s device and/or tracking them. For more information, please read our The ICO provides information about cookies here. |
| DPA 2018 | UK Data Protection Act 2018 |
| Data Protection Law | means all applicable data protection and privacy legislation in force from time to time including the UK GDPR and the EU GDPR, the Electronic Communications Directive 2002/58/EC (as updated by Directive 2009/136/EC) and the Privacy and Electronic Communications Regulations 2003 (SI 2003 No. 2426) as amended, and any other legislation relating to personal data and all other legislation and regulatory requirements in force from time to time that apply to the use of personal data. |
| Encryption | is the process that scrambles readable text so it can only be read by the person who has the secret code, or decryption key. It helps provide data security for sensitive information. For more information see the Encryption | ICO and the GDPR’s requirements for encryption. |
| EU Representative | the GDPR requires organisations not established in the EU to appoint a representative in an EU member state (or the EEA), if (i) it is apparent that the organisation intends to offer goods or services to individuals in the EU or (ii) it monitors the behaviour of individuals in the EU (or the EEA). For more information see the ICO information here |
| EU GDPR | means the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing the Directive. General Data Protection Regulation (GDPR) – Official Legal Text (gdpr-info.eu) |
| ICO | means the Information Commissioner’s Office, the UK’s independent authority set up to uphold information rights in the public interest, promoting openness by public bodies and data privacy for individuals. |
| Information Security Risks | comprises the impacts on individuals or organisations that could occur due to the threats and vulnerabilities associated with the operation and use of information systems and the environments in which those systems operate. |
| Lawful Basis | under the EU GDPR and the UK GDPR, you must have a valid lawful basis to process personal data.Lawful Basis of processing personal dataThere are six lawful bases for processing personal data available: (a) Consent: the individual has given clear consent to the processing of their personal data for a specific purpose. (b) Contract: the processing is necessary for a contract, or because specific steps have been taken before entering into a contract. (c) Legal obligation: the processing is necessary for compliance with the law (not including contractual obligations). (d) Vital interests: the processing is necessary to protect someone’s life. (e) Public task: the processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law. (f) Legitimate interests: the processing is necessary for an organisation’s legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect the individual’s personal data that overrides those legitimate interests. (This cannot apply if an organisation is a public authority processing data to perform its official tasks.) For more informationLawful basis for processing | ICO Art. 6 GDPR – Lawfulness of processing GDPR: lawful bases for processing, with examples – IT Governance UK Blog Special category dataSpecial category data is personal data that needs more protection because it is sensitive. In order to lawfully process special category data, you must identify both a lawful basis under Article 6 of the UK GDPR and EU GDPR and a separate condition for processing under Article 9. These do not have to be linked. |
| Legitimate Interests Assessment (LIA) | is a form of risk assessment and should be conducted by an organisation when your personal data processing is based on legitimate interest. The LIA is split into three steps:
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| Net Promoter Score (NPS) | is a rating tool. The main purpose of the Net Promoter Score (NPS) question is to calculate a score so we can determine the level of customer loyalty and satisfaction to our business. |
| Personal Data | this is also referred to as “personal information” and it means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. |
| Personal Data Breach
| means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored, or otherwise processed. |
| Privacy Notice | (also sometimes called a privacy policy or fair processing notice) is a public document from an organisation that explains how that organisation processes personal data and how it applies data protection principles under Articles 12, 13 and 14 of the EU GDPR and the UK GDPR. |
| Processor | means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller. Processors act on behalf of the relevant controller and under their authority. In doing so, they serve the controller’s interests rather than their own. |
| Special Category Personal Data | some of the personal data that organisations process is more sensitive and needs higher protection. Under the GDPR, this is known as ‘special categories of personal data’, and includes information about a person’s:
In order to lawfully process special category personal data, we must identify both a lawful basis under Article 6 of the UK GDPR and EU GDPR and a separate condition for processing under Article 9. These do not have to be linked. There are ten conditions for processing special category data in Article 9 of the UK GDPR. Five of these require us to meet additional conditions and safeguards set out in UK law, in Schedule 1 of the DPA 2018. |
| Special Category Personal Data Conditions for Processing | the conditions for processing special category data: (a) Explicit consent |
| Supervisory Authorities | means the data protection authority tasked with supervising GDPR compliance in each member state of the European Union. What are Data Protection Authorities (DPAs)? | European Commission (europa.eu) |
| Tracking Pixels | a tracking pixel is an HTML code snippet which is loaded when a user visits a website or opens an email. It is useful for gathering information about visitors on a website—how they browse, what type of ads they click on, etc. |
| UK GDPR | means the GDPR as transposed into United Kingdom national law by operation of section 3 of the European Union (Withdrawal) Act 2018, together with the DPA 2018, the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019, and other data protection or privacy legislation in force from time to time in the United Kingdom. |
| Website
| mlp.agency, taketime.co.uk and including all subdomains thereof, present and future. |