Privacy Policy
Background
This Privacy Policy explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
Smart Advertiser and 9Figure Publishing Ltd (“We”, “Us”, “Our”) understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our customers and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
You have certain rights in relation to your data, including the right to object to processing based on legitimate interests, profiling, and direct marketing. You can exercise your rights at any time by emailing us at [email protected] For further details about our processing and your rights, please see below.
How Our Website Works
If you’d like to request and receive quotes or information for any of our products, you will need to complete and submit the form on any of our websites.
Once we’ve received your request, we’ll connect you with one or more relevant companies (depending on the specific permissions you have given us). We’ll tell the Client who you are, and your product requirements, and they’ll then contact you directly to discuss your requirements and potentially provide you with a quote.
You’ll see on any of our websites that we have a clear consent statement. This statement sets out the Clients which will contact you.
You can choose which Clients to buy from but you are not obliged to purchase from any of them.
Information About Smart Advertiser and 9Figure Publishing Ltdd.
Limited Company registered in England under company number 13619205.Email address: [email protected]
What Does This Notice Cover?
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
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.
What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
The right to be informed about our collection and use of your personal data.
The right to access the personal data we hold about you.
The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete.
The right to erasure, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have, subject to terms and conditions.
The right to restrict (i.e. prevent) the processing of your personal data.
The right to object to us using your personal data for a particular purpose or purposes.
The right to data portability. This means that, if you have provided personal data to us directly, we can use it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask for a copy of that personal data to re-use with another service or business in many cases.
Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. You can find the relevant contact details and the best way to make a complaint to the ICO at www.ico.org.uk.
The Data We Collect About You
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes first name and last name.
Contact Data includes address, email address and telephone number(s).
Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Product Data includes form responses (the data entered and selected within our online contact form).
Usage Data includes information about how you use our website.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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 do not collect any Special Categories of Personal Data about you (this 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). Nor do we collect any information about criminal convictions and offences.
How We Collect Your Personal Data
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email or otherwise.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, pixels, server logs and other similar technologies. Please see our cookie policy for further details.
Technical Data from analytics providers such as Google
How We Use Your Personal Data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to effectively perform the service you require
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.
To manage your registration on our websites;
Determine whether any of the Clients or approved partners we work with may have services, products and offers that may be of interest to you based on the preferences and permissions you have supplied to us.
For analysis purposes. Where this is done, the information is aggregated and wherever possible anonymised in line with the ICO’s code of practice. These products are of a marketing nature.
We may process your personal data ourselves or through third party data processors that will process data on our behalf. We ensure the data processor complies with this policy and all current data protection regulations.
Our lawful basis for processing your general personal data:
Legitimate interest. The data is required for us to provide the service that you have requested. 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 telephone, email and post with information, news, and offers on our products and 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 always have the opportunity to opt-out.
From time to time, Service Providers may return data to us. They may do this if they have a query regarding a request for Quotes that we have sent to them in order to enable us to resolve the query. They may also return data to us, together with confirmation on whether or not a product has been purchased, in order to enable us to improve our marketing.
Sharing of Your Personal Data
We may have to share your personal data with the parties set out below for the purposes set out in our lawful basis for the processing of your general person data:
Companies acting as data processors, joint data controllers or independent data controllers who provide the introduction to FCA authorised providers by means of IT and system services which may be based on the data you have provided.
FCA authorised insurance providers acting as data processors, joint data controllers or independent data controllers in order to provide the services required.
How Long Will You Keep My Personal Data?
We have a data retention policy, which clearly sets out how long we keep data for, and for what reasons. We will not keep your personal data for any longer than is necessary in light of the reasons for which it was first collected. Your personal data will therefore be kept for the following periods:
We will keep your contact details following an enquiry to any of our websites for a period of 24 months. We need to do this to ensure you do not receive any further communication from us or from any of our partners if your information has been supplied to them previously.
This enables us to provide our services to you, and fulfil our legal obligations. We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information. We will store all the personal information you provide on our secure servers that are subject to strict security requirements.
Data Security
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. 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.
Data Storage - EEA
We will only store or transfer your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the GDPR or to equivalent standards by law.
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”.
Subject access requests can be made in writing, over the phone or via email. 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 28 day’s 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.
Cookies
Some of our websites may use cookies to collect information. You will be given a Cookie notification bar when you first visit any of our sites where your permission will be requested if that particular website uses Cookies. Cookies are small data files which are placed on your computer or other mobile or handheld device (such as smart ‘phones or ‘tablets’), as you browse our websites. They are used to ‘remember’ when your computer or device accesses our websites. We do not use cookies to collect or record information on users’ name, address or other contact details. The cookies stored on your computer or other device when you access our websites are set by us and other third parties. Cookies may also be set by third parties who we use for marketing. None of these third parties collect any personal data from which they would be able to identify individual customers. The main purposes for which cookies are used are:
For technical purposes essential to effective operation of websites.
To drive marketing, particularly banner advertisements and targeted updates.
How do I disable Cookies?
If you want to disable cookies you need to change your website browser settings to reject cookies. How to do this will depend on the browser you use, and we provide further detail below on how to disable cookies for the most popular browsers:
For Microsoft Internet Explorer:
Choose the menu “tools” then “Internet Options”
Click on the “privacy” tab
Select the setting the appropriate setting
For Mozilla Firefox:
Choose the menu “Tools” then “Options”
Click on the icon “Privacy
” Find the menu “Cookie” and select the relevant options
For Opera 6.0 and further:
Choose the menu “Files” > “Preferences”
Privacy
What will happen if I disable Cookies?
This depends on which cookies you disable. However, in general the website may not operate effectively if cookies are deactivated.
Changes To This Privacy Notice.
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 made available by posting a new version on our website. You should check this page occasionally to ensure you are happy with any changes, although anything that will affect you will be communicated directly to you. Last updated: June 2020.
