Privacy and personal data protection
For the purposes of this statement, ‘UK Data Privacy Legislation’ means all applicable data protection and privacy legislation in force from time to time in the UK including the UK-GDPR, as amended, the Data Protection Act 2018, as amended and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended. This statement should help you to understand how EngageTech complies with the UK Data Privacy Legislation.
Please take the time to read this statement and understand how we process personal data.
Who we are: EngageTech Ltd of 1st Floor 24 Southwark Bridge Road, London, SE1 9HF (Company Number 07229376). For any queries about your personal data or how we process our data then please contact email@example.com. Alternatively, you can call us on +44 (0) 3966 3641 or write to us by post at 1st Floor 24 Southwark Bridge Road, London, SE1 9HF.
What we do: EngageTech generates sales pipeline for our clients. Providing accurate business intelligence focusing primarily in the technology sector.
What personal data we collect
The types of data we will collect may include but is not limited to:
- Contact Data: your full name, corporate email address, workplace address, workplace phone numbers.
- Research Data: Written records and notes of conversations that you have had with members of our team. Publicly- available information such as that found on websites such as LinkedIn or your corporate domains.
- Records of Correspondence: records of emails/mail that you have sent to us.
- Analytics Data: your IP address or other device identifier, technical log information, cookies, and information about how you use our website.
How we collect personal data
We collect data in a series of ways:
- Face to Face (e.g. interview)
- Phone (e.g. a conversation with one of our Sales Development Reps)
- Research of Information in the public domain (e.g. company website, LinkedIn)
Why we process and share the personal data
We process personal data in order to profile the procurement characteristics of individuals and the companies they represent, including their current and potential requirements, their priorities, their preferences and their commercial interests.
We share personal data with our clients who are interested in matching the procurement characteristics of the data subjects and their companies with offers of goods and services.
With whom we share personal data
We share personal data with our clients and they tend to be technology companies, value-added resellers and distributors.
The personal data which is processed and shared during the course of a commercial agreement between us and a client may be retained and processed by either party or their successors or assigns after the termination of the commercial agreement.
Lawful basis for processing personal data
EngageTech relies upon its own and its clients’ ‘Legitimate Interests’ as the lawful basis for processing personal data.
It is in ours and our clients’ legitimate interests to process personal data for the purposes of:
- Operating and improving our/their websites;
- Marketing (including direct marketing) and delivering our/their business services;
- Communicating with you and our/their other clients and suppliers;
- Detecting and preventing activity which is contrary to our/their legitimate interests;
- Other activities which may be or become legitimate from time to time and of which we/they shall make the relevant data subjects aware at the relevant time.
We rely upon ‘Legitimate Interests’ and not some other legal basis for processing personal data because:
- We only process data relating to company representatives (no sole traders or unlimited partnerships);
- We only process data relating to companies which have not registered on the Corporate Telephone Preference Service;
- We only process data relating to companies and company representatives who have not previously objected to our processing of their personal data.
- We do not process data relating to companies or company representatives who manage legal or insurance claims;
- The data we process is very unlikely to affect the fundamental rights and freedoms of the data subjects because we only ever process information that is in the public domain or that has been given to us freely by the data subject or their company;
- We and our clients only use the processed data for business to business (B2B) marketing and not for marketing to individual consumers;
- We and our clients only process data for directs marketing by human interaction and not for marketing by automated telephone call or recorded message;
International data transfer
Our clients operate around the world, which means that your personal data may be transferred to and processed in countries other than the UK. However, we require that our clients shall only transfer shared personal data outside the UK if they first ensure that:
- The transfer is to a country approved as providing adequate protection pursuant to Article 45 of the UK-GDPR; or
- There are appropriate safeguards in place pursuant to Article 46 of the UK-GDPR; or
- One of the derogations for specific situations in Article 49 of the UK-GDPR applies to the transfer.
Retention of personal data
Personal data processed for direct marketing purposes is only retained by us if it continues to be accurate and useful and only for so long as we need it to provide our business services, comply with our legal obligations, resolve disputes or enforce agreements. Data retention periods are set out in our Data Retention Policy and reviewed from time to time.
We cannot determine a maximum retention period for our clients but our standard commercial agreement requires them to comply with data protection legislation and retain the data which we share with them only for so long as it remains accurate and for so long as they have a legitimate interest in keeping it.
Your personal data rights
You have the following rights:
- You can request access to, or correction/updating or deletion of your personal data at any time;
- You can object to processing of your personal data, ask us to restrict processing of your personal data or request portability of your personal data at any time;
- You can opt-out of marketing communications we send you at any time;
- If we have collected and processed any of your personal data on the basis of your consent, then you can withdraw your consent at any time. (Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted on lawful processing grounds other than consent.)
- You can complain to the Information Commissioner’s Office (ICO) about our processing of your personal data at any time (contact details, are available at https://ico.org.uk). However, we would ask that you try to solve any issue with us directly first.
You can contact us to query our data processing practices or to exercise your personal data rights via any of the means set out above, under the heading ‘About EngageTech’ or by using any unsubscribe mechanism supplied, such as an unsubscribe link in an email.
We respond to all requests we receive from individuals wishing to exercise their personal data rights in accordance with the UK Data Privacy Legislation.