Your Privacy: Table Of Contents

1. Important information and who we are
2. The data we collect about you
3. How is your personal data collected?
4. How we use your personal data
5. Disclosures of your personal data
6. International transfers
7. Data security
8. Data retention
9. Your legal rights
10. Glossary

Welcome to the Park Row Marketing ltd privacy policy.

Park Row Marketing respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED?
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA 
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. GLOSSARY

Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Park Row Marketing collects and processes your personal data through your use of this website and our general business practices, including any data you may provide through this website when you sign up to our newsletter or purchase a service.

We are a marketing agency, using primarily corporate contact details excluded from this privacy policy under the Privacy and Electronic Communication Directive to collect ‘lead’ information on interests in our clients’ products or services, which we then pass on to our clients as third party data controllers and processors. Where we do come into contact with personal data, the way we handle that data is set out in this privacy policy. 

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

We as Park Row Marketing Ltd is the controller and responsible for your personal data (collectively referred to as “Park Row Marketing”, “we”, “us” or “our” in this privacy policy).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

Full name of legal entity: Park Row Marketing ltd

Contact: Director Owen Wood

Email address: admin@parkrowmarketing.co.uk

Postal address: Henleaze House, Harbury Road, Bristol, England, BS9 4PN

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

Giving Feedback or Making a Complaint

Introduction

Park Row Marketing ltd defines a complaint as “any expression of dissatisfaction, whether oral or written, and whether justified or not”; a very wide and all encompassing description. However, a complaint is also an opportunity to turn an unhappy customer into a satisfied long term client.

Our Agents, Quality Control Team and Managers all follow strict guidelines, which we follow for complaints regarding regulated sales. In particular, you can expects complaint to be thoroughly investigated and comprehensively documented.

A complaint can be triggered in the following manners:

• End Customer – A Contact who has received communication from us on behalf of our clients and following which has expressed dissatisfaction via Park Row Marketing ltd’s channels
• End Customer via Client – A Contact who has received communication from us on behalf of our clients and following which has expressed dissatisfaction via client’s contact channels
• Self-Triggered – During our Quality Control and Management processes, we identify an End Customer or Client’s dissatisfaction and we trigger the complaint process

What counts as a complaint?

Examples include;

• • A broken promise: If there’s a major issue e.g. an outage that prevents us from keeping a promise
  • Client initiated: If a client expresses dissatisfaction 
  • Agent behaviour: If an agent behaves in a way while representing a client which we deem unacceptable
  • Prospect response: If a prospect expresses dissatisfaction at our contact

Long-Term Thinking: Preserve The Client Relationship

One of our central tenets is that we always preserve the client relationship. This is about us going the extra mile and over-communicating to:

• Solve issues quickly
• Show clients how good we can handle issues to give them long term faith

How Will your complaint be handled?

1. Step 1: We acknowledge the complaint ASAP: Acknowledge the complaint and tell the client what we are going to do. Thank you for bringing this to our attention. We will then launch a full investigation into the complaint, look at all the facts and share them openly with you and agree a timeline
2. Step 2: Collect the facts: Within 1 working day of receiving notification of the complaint, we will launch an investigation. We have audit trails of contact, activities and approval processes, so we compare what happened with what was expected to have happened. Examples of this includes: Listening to all relevant calls, Reviewing all notes on the CRM, Consulting with all parties, agents to get their account and Comparing with our quality standards
3. Step 3: Outcome of Investigation: Within 5 working days, we will have an outcome to share. We make a point of being open and honest with clients, including being able to admit fault where applicable. 3 outcomes are either Fully upheld – our team are fully responsible for causing the complaint, Partly upheld – we acknowledge part of the role which was played causing the complaint or Not upheld – we acted entirely within what was agreed and our quality standards
4. Step 4: Final Response, Resolution and moving forward: Your appointed complaint owner will discuss next steps and ways that we can move forward. We perform weekly complaint reviews to assess our complaint levels and how we can always improve.

In exceptional situations, if a full reply cannot be given to all the points raised in a complaint for reasons beyond the control of the firm, then the firm will send a holding reply, clearly indicating the reasons for the delay in providing a full reply to the complaint and specifying the deadline by which the payment service user will receive a full reply.

Terms of the Resolution

Any terms of the resolution is offered on condition that this complaint is considered resolved. The outcome will be acknowledged in writing. 

Closing a complaint

On receipt of a complaint, a respondent must ensure that the complainant is kept informed thereafter of the progress of the measures being taken for the complaint’s resolution send the complainant a prompt written acknowledgement providing early reassurance that it has received the complaint and is dealing with it.

A complaint is considered closed if:

1. A final response has been provided by Park Row Marketing ltd
2. The complainant has, verbally or in writing, accepted the terms of the resolution offered by Park Row Marketing ltd
3. Where the complaint is reported as closed because the complainant has not replied to us within 5 business days of the written response

Where a complaint is reported as closed because the complainant has not replied to us within 5 business days, we may treat the date of the final response as the date the complaint was closed for the purposes of reporting.

Use of client email addresses

In accordance with our client’s instructions, we may use client email addresses to communicate or send marketing messages on their behalf. If one is unable to be provided, then we may from time to time use a separate email to communicate or send marketing messages.

If we use a client email address, we will forward this email address to admin@parkrowmarketing.co.uk. This aids processing of responses, opt outs and any complaints (if applicable). The client retains ownership and responsibility for the inbox. At the end of the campaign, it is the client’s responsibility to ensure that the auto forward is removed in line with their own GDPR policy.

Web Chat Widget

In accordance with our client’s instructions, a web chat widget may be installed on client’s website(s) to communicate or send marketing messages on their behalf to visitors. At the end of the campaign, it is the client’s responsibility to ensure that the widget is removed from client’s website in line with their own GDPR policy.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 18 December 2020. Historic versions can be obtained by contacting the data privacy manager using the details above. 

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

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) or data about corporate entities, like a company.

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, maiden name, last name, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, 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.
• Profile Data includes your Webchat Transcripts and Email Transcripts, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes emails, document views, email link clicks and opens, and your preferences in receiving marketing from us and our third parties and your communication preferences.

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 policy.

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.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by webchat, post, phone, email or otherwise. This includes personal data you provide when you:
  • apply for our services;
  • communicate with us through webchat on third party websites;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see section titled ‘cookies’ under ‘HOW WE USE YOUR PERSONAL DATA’ for further details.
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
• Technical Data from analytics providers, such as Google based outside the EU;

• Search information providers, such as Funnelin and Bark, based inside the EU, accessing information on LinkedIn.
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services, such as PayPal, Go Cardless, and Quickbooks, based outside the EU
• Identity and Contact Data from data brokers or aggregators, such as Marketscan based outside the EU (privacy policy)
• Identity and Contact Data from publicly available sources, such as Companies House and social media accounts, like LinkedIn

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 perform the contract we are about to enter into or have entered into 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 obligation.

Please refer to the meaning of Lawful Basis under the glossary to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. Please note that this does not apply to webchats on third party websites, to whom we act as agent. 

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of services purchase or other transactions.

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

• Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

We do not share the information collected by our cookies with any third parties. However, we may receive information from the cookies on third party websites, who have their own privacy and cookie policies – some of which may link to this document. 

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

Change of purpose

We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table ‘Purposes for which we will use your personal data’ above.

• External Third Parties as set out in the Glossary.
• Specific third parties listed in the table Purposes for which we will use your personal data 
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

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 and only permit them to process your personal data for specified purposes and in accordance with our instructions.

How Does The Guaranteed Standard of Leads Work?

The guarantee of quality is all about making best use of your time by using our services to work to provide you with a stream of leads & sales to the agreed standard. This guarantee is valid for the duration of a live, paid campaign with you. We will get leads up to the standard that we agreed as defined in writing in the scripts, messages & customer discovery. If they aren’t at the right standard, simply send them back and we’ll happily re-qualify and re-book.

If we are successful in contacting the prospect, we will do our best to bring the conversation up to the standard that we agreed as defined in writing in the scripts, messages & customer discovery.

The work performed by us to recontact prospects will be funded as part of the paid package that you have with us. If we are unable to contact the prospect or they are no longer interested, we will continue to periodically keep in touch with them on your behalf for the duration of a live, paid campaign with you. Our guarantee is no longer valid once a campaign has ended.

International transfers

Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe, such as ‘Standard Contractual Clauses for Controllers to Controllers’

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

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 retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential 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, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy, which you can request from us by contacting us.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us 

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

In addition to any third parties specifically mentioned throughout this document, External Third Parties can be summarised as follows:

• We are a marketing based company, receiving and passing ‘lead’ information between third party data processors and controllers – all of whom are based within the EEA, and who we further bind by contractual clauses in relation to data protection and confidentiality. 
• Professional advisers, acting as processors or joint controllers, including lawyers, bankers, auditors and insurers based within the EEA, who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data’s accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.