Privacy Policy
BACKGROUND:
TRAC Marketing understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, www.tracmarketing.co.uk (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
Please read this Privacy Policy carefully and ensure that you understand it. [Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site] and [You will be required to read and accept this Privacy Policy when signing up for an Account. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.
1. Definitions and Interpretation
In this Policy, the following terms shall have the following meanings:
“Account” means an account required to access and use certain areas and features of Our Site;
“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 13, below;
“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;]
"personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the [Data Protection Act 1998] OR [EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”)]; and
“We/Us/Our” means TRAC Marketing, whose registered address is 21 brigade place, Caterham, Surrey, CR3 5ZU, and whose main trading address is 21 brigade place, Caterham, Surrey, CR3 5ZU.
2. Information About Us
Our Site is owned and operated by TRAC Marketing, whose registered address is 21 Brigade Place, Caterham, Surrey, CR3 5ZU and whose main trading address is 21 Brigade Place, Caterham, Surrey, CR3 5ZU
Our Data Protection Officer is Roger Wilks, and can be contacted by email at roger.wilks@tracmarketing.co.uk, by telephone on 07803544599, or by post at 21 Brigade Place, Caterham, Surrey, CR3 5ZU.
3. What Does This Policy Cover?
This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.
4. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’. Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
5. What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
a) The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.
b) The right to access the personal data we hold about you. Part 13 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 15 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to data portability. This means that, if you have provided personal data to us directly, we am using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
h) Rights relating to automated decision-making and profiling.
If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
6. What Data Do We Collect?
Depending upon your use of Our Site, We may collect some or all of the following personal [and non-personal] data (please also see section 13 on Our use of Cookies and similar technologies https://www.tracmarketing.co.uk/cookie-policy:
a) name;
b) date of birth;
c) gender;
d) business/company name
e) job title;
f) profession;
g) contact information such as email addresses and telephone numbers;
h) demographic information such as postcode, preferences, and interests;
i) Financial information such as credit/debit card numbers;
j) IP address;
k) web browser type and version;
l) operating system;
m) a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;
7. How Do We Use Your Data?
All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the [Data Protection Act 1998] OR [GDPR] at all times. For more details on security see section 7, below.
Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
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Providing and managing your Account;
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Providing and managing your access to Our Site;
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Personalising and tailoring your experience on Our Site;
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Supplying Our products and services to you (please note that We require your personal data in order to enter into a contract with you);
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Personalising and tailoring Our products and services for you;
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Replying to emails from you;
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Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time;
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Market research;
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Analysing your use of Our Site products and services and gathering feedback to enable Us to continually improve Our Site and your user experience;
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by [email] AND/OR [telephone] AND/OR [text message] AND/OR [post] with information, news, and offers on our [products] AND/OR [services]. You will not be sent any unlawful marketing or spam. we will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.]
Third Parties (including <<insert details of third parties whose content appears on the site>>) whose content appears on our Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.
We use the following automated system[s] for carrying out certain kinds of decision-making and profiling. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the GDPR gives you the right to do so. Please contact us] to find out more using the details in Part 15.
8. How Long Will You Keep My Personal Data?
we will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will, therefore, be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
• once any activity has ceased data will be removed after 6 months
9. How and Where Do You Store or Transfer My Personal Data?
we will only store or transfer your personal data in the UK. This means that it will be fully protected under the GDPR.
10. Do You Share My Personal Data?
we will not share any of your personal data with any third parties for any purposes, subject to one important exception. In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if [we are] OR [I am] involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
11. How Can I Control My Personal Data?
11.1 In addition to your rights under the GDPR, set out in Part 5, when you submit personal data via our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails.
11.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receive.
12. Can I Withhold Information?
You may access certain areas of our Site without providing any personal data at all. However, to use all features and functions available on our Site you may be required to submit or allow for the collection of certain data.] You may restrict our use of Cookies. For more information, see Part 14 and our Cookie Policy https://www.tracmarketing.co.uk/cookie-policy.
13. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. [To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
we will respond to your subject access request within 21days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
14. How Do You Use Cookies?
our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. we use Cookies to facilitate and improve your experience of our Site and to provide and improve our products and services. we have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.
By using our Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us]. Third-party Cookies are used on our Site for analytics purposes. For more details, please refer to the table below. These Cookies are not integral to the functioning of our Site and your use and experience of our Site will not be impaired by refusing consent to them.
All Cookies used by and on our Site are used in accordance with current Cookie Law. Before Cookies are placed on your computer or device, you will be shown a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of our Site may not function fully or as intended. You will be given the opportunity to allow only first-party Cookies and block third-party Cookies.
Certain features of our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that our Site may not work properly if you do so. we have taken great care to ensure that your privacy is not at risk by allowing them.
Please see Cookie policy for a full list of cookies used:
https://www.tracmarketing.co.uk/cookie-policy
15. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Roger WIlks): Email address: roger.wilks@tracmarketing.co.uk . Telephone number: 07803544599. Postal Address: 21 brigade place, Caterham, Surrey, CR3 5ZU.
16. Changes to this Privacy Policy
we may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection. Any changes will be immediately posted on our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of our Site following the alterations. we recommend that you check this page regularly to keep up-to-date.