Contents

This Privacy Notice explains in detail the types of personal data we (Captivate Plus Ltd. also known as Captivate+) may collect about you when you interact with us. It also explains how we’ll store and handle that data and keep it safe.

 

1. Legal Processing

Data protection law states there are several legal reasons why a company may collect and process personal data. Captivate+ work on the following bases for certain situations:

Contract – We will process your personal data to fulfill an order, deliver a service, essentially comply with our contractual obligations. An example might be, if you order a service for email delivery, we’ll collect your email address to deliver your purchase or pass them to the delivery company.

Legal Compliance – If the law or government requires us to, we may need to collect and process your data. An example might be passing on details of fraud to law enforcement.

Legitimate Interest – In cases, we required personal data to pursue our legitimate interests in a way that might reasonably be expected as part of running our business. This does not impact your freedom or rights. Examples might be using postal or email details to send direct marketing information by post telling you about products and services that we think might interest you. We may also use your purchase history to send you or make available personalised offers.

 

2. When do we collect personal data?

  • When you visit any of our websites or speak to an account manager on the phone.
  • When you create a credit account with us.
  • When you purchase a product or service by phone but don’t have (or don’t use) an account.
  • When you engage with us on social media.
  • When you contact us by any means with queries, complaints etc.
  • When you enter prize draws or competitions.
  • When you book any kind of appointment with us or book to attend an event, for example, a meeting to discuss an opportunity.
  • When you choose to complete any surveys, we send you.
  • When you comment on or review our products and services.
  • Any individual may access personal data related to them, including opinions. So if your comment or review includes information about the Partner who provided that service, it may be passed on to them if requested.
  • When you’ve given a third-party permission to share with us the information they hold about you.
  • We may collect data from publicly available sources (such as Land Registry) when you have given your consent to share information or where the information is made public as a matter of law.

 

3. What sort of personal data do we collect?

  • Details of your interactions with us through phone contact, email or online. An example might be notes from conversations with you, complaint details, comments, purchase details and web visits.
  • Copies of documents you provide to prove marketing compliance. This will include details of your full name, work address, telephone number, ICO number, data protection contact name.
  • Details of your visits to our websites, and which site you came from to ours.
  • Information gathered by the use of cookies in your web browser.
  • Payment card information. This is not stored for longer than it takes to transact
  • Your comments and product reviews.
  • To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed during your visit, the advertisements you clicked on, and any search terms you entered.
  • Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.

 

4. How and why do we use your personal data?

We want to give you the best possible customer experience. One way to achieve that is to get the richest picture we can of who you are by combining the data we have about you. We then use this to offer you promotions, products and services that are most likely to interest you. The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service. Of course, if you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ which can be found in section 8. Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for. Here’s how we’ll use your personal data and why:

  • To process any orders that you make by using our sales team. If we don’t collect your personal data during ordering, we won’t be able to process your order and comply with our legal obligations. An example may be that your details are passed to a third party so they can deliver your purchased product or service that you ordered. We would then keep those details for a reasonable period afterwards in order to fulfill obligations such as refunds, guarantees etc.
  • To respond to your queries, refund requests and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
  • To protect our business and your account from fraud and other illegal activities. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We’ll do all of this as part of our legitimate interest.
  • To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.
  • To keep you informed by email, web, telephone, post about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on.

    Of course, you are free to opt out of hearing from us by any of these channels at any time.

      Part of our service is recommending data sets to be used for direct marketing. All of our clients sign documentation to say they understand this and that they have appropriate data handling and security processes in place around processing personal data and it’s use – e.g. direct marketing. There may be instances where Captivate+ processes personal data as part of this service in securely delivering a licensed dataset to a client, procured from a Data Controller. In this instance, we are processing the personal data under Legitimate Interest. Anyone can inform us not to process their personal data by emailing compliance@captivateplus.com.

       

      5. How is personal data protected?

      We will treat your data with the utmost care and take all appropriate steps to protect it. We secure access to our websites and apps using ‘https’ technology. Access to your personal data is password-protected, and sensitive data is secured by SSL encryption. We regularly monitor our system to identify ways to further strengthen security.

       

      6. Website

      What specific information is obtained?

      Our website does not collect specific, detailed information about you as a visitor to our site. Where information is gathered, we will inform you of this along with the explanation of why it is required. This information will be for purposes such as responding to an enquiry made and we will ask for this information in order for us to get in touch and provide the relevant information which has been requested from you.

      Are any payment details stored?

      Payment card details are not stored by Databroker Ltd and are used solely for individual transactions to which they have been provided for. Additionally, customer details are not shared with any 3rd parties.

      What information is retained?

      Cookies and tracking software are used on a temporary basis and expire when the site has been left. These are used for purposes such as website improvement. Google Analytics is also used for the same reason of website improvement and understanding how you use it. This information is not shared with anyone. By using the website, you are consenting to the use of cookies to retain session information for the purposes listed above. This information is held in your web browser and is removed at the end of your session. The personal information we collect and hold via Tracking software is the following: –

      – Browser used (Bing, Chrome, Internet Explorer etc.)
      – Location (based on IP address)
      – Gender
      – Age group
      – Site searches
      – Device(s) used
      – Frequency on Site
      – Session duration (time spent on the site)
      – Page(s) visited
      – Page session duration (time spent on specific page)
      – Web Surfing Behaviours

      We currently use the following companies that may process your personal data through website usage. Facebook, Twitter, LinkedIn, Google, Bing, Zoho.

       

      7. Customers / Enquirers

      We hold information about customers/ enquirers as it is necessary for us to conduct our business activities.

      What personal information is held?

      The personal information we collect and hold is the following:

      – Full Name
      – Company Name
      – Company Address
      – Company Website Address
      – Email Address
      – Phone Number
      – Initial Requirement

      This information may be linked together with what has already been gathered (as stated in the “what information is retained?” section) via Tracking Software.

      How is this information gathered?

      We gather this information through lead generation forms on our website and tracking software as mentioned in the “what information is retained” section, as well as over the phone when relevant.

      How long will the data be kept for?

      For a reasonable period of time after you have stopped being an active customer, we may continue to contact you with information relating to our products and services. We deem a reasonable period of time to be 18 months after an order has been completed, or a relevant license period has expired. After this time, the data we hold will either be deleted, anonymised or retained providing you have asked us to do so.

      Who will the data be passed to?

      This information will not be passed on to anyone other than authorised employees of Captivate+ and relevant processors for example a company sending promotional material on behalf of Captivate+. Additionally, if a legal matter were to arise, then we may need to provide this information for those purposes.

      While you are a customer of Captivate+, the basis for processing your data is ‘contract’. When you are no longer an active customer of Captivate+, the basis is ‘legitimate interest’ as we would like you to once again order products/services from us. Prior to placing the order, an enquirer is processed on ‘legitimate interest’. We may use your details for the purpose of creating a profile to gauge decision making. For example, using information held, we may create profiles based on the following:

      – Email Address
      – Telephone Number
      – Geographic Location
      – Job Title/Job Role

       

      8. Data Subject Rights (Subject Access Request, Erasure, Rectification)

      You have the right to ask for details of the personal information we hold on you (Subject Access Request) which we will provide free of charge in an electronic format normally within 28 days of your request. You can also request that we stop processing your information in full or in part and/or request we delete any and all information we hold on you.

       

      10. Contact Us

      If you need to contact us then please email us at compliance@captivateplus.com.

       

      11. To contact the regulator, please see below:

      Go to www.ico.org.uk

      If you are based outside the UK, please contact the relevant data protection regulator in your country.

       

      Policy Updated – Oct 2023