Last updated: Tuesday 12th July, 2022
2. Website analytics and cookies
We passionately believe in privacy-first digital marketing.
We do not:
- set any cookies on the browsers of our website visitors
- retarget visitors that have shown no interest in our proposition other than visiting our website
2.1 Fathom Analytics
Using this privacy-friendly website analytics software, your IP address is only briefly processed, and neither HC Marketing Limited or any of its employees are able to identify you. As per the CCPA, your personal information is de-identified. You can read more about this on Fathom Analytics' website.
The purpose of us using this software is to understand our website traffic in the most privacy-friendly way possible so that we can continually improve our website and business. The lawful basis as per the GDPR is "f); where our legitimate interests are to improve our website and business continually." No personal data is stored over time.
2.2 Cookies and tracking pixels
We do not use Google’s global site tag (gtag.js), the Facebook pixel, or any other cookies. Cookies are sometimes used to provide essential services on some websites, but more often they are used to create, track and market to custom audiences based on the website browsing and/or conversion behaviour of website visitors.
We believe that tracking browsing behaviour and retargeting visitors based on cookies and pixels is creepy and unnecessary. In fact, we’d actually like surveillance-based advertising to be banned (you can read more about this topic at https://usefathom.com/blog/ban-surveillance-based-ads).
3. What data do we collect?
We only collect data that is required to:
- Develop effective marketing recommendations
- Assist you in assessing the suitability of our services
- Deliver our services
This includes personal identification information (such as your name, email address, phone number, business name, address, job title etc.), payment information, and commercial/marketing information about your business (such as revenue or sales goals, conversion rates, marketing cost data etc).
4. How and why do we process your data?
We typically collect and process personal data relating to potential or existing customers, website visitors and vendors/collaboration partners.
We only process your personal data when we have a purpose and a lawful basis for doing so. Under the GDPR Article 6-1, the lawful bases we rely on are:
- Where you have given your consent
- Where we have a contractual obligation (services contract in place)
- We have a legal obligation
- We have a legitimate interest
We may process personal data when you:
- Complete a form or engage with chatbots/live chat on our website
- Communicate with us online (email, video calls, social media, etc.) or by telephone
- Use our services and/or software
- Deliver products/services to our business or or enter into a collaboration with us
Any personal data you provide to us is given voluntarily, but we are unable to provide our services if you choose not to.
We do not rent or sell any personal data to others, we do not use automated decisions or profiling in the processing of your personal data, and we do not process any special category data as per Article 9 of the GDPR.
5. How do we use and/or share your data?
To run our business efficiently and securely, we sometimes will have to share your personal data with other trusted parties such as:
- Data processors - providers of various services that make our services possible may process your personal data on our behalf
- Our accountants, lawyers or other professional advisors
- Internal support functions - e.g. information technology specialists
- Public authorities - when we are obliged to report to them
We use data processors for a range of business processes, including:
- Email, calendaring and digital meetings
- Customer relationship management
- Hosting this website and working with online payment providers
- Transactional emails to customers
- Project management and support ticket systems
- Delivering marketing campaigns on your behalf
We don't publish detailed information about our data processors to protect our business. If you'd like to know more about our processing and with whom we share your personal data, you can contact us.
We practice data minimization, so we will only use data suppliers to process your personal data when required (such as using Stripe to process payments for example).
6. How do we store your data?
We may store your data securely in the cloud, and it is only accessed via 2FA on hardware devices controlled by HC Marketing Limited.
We will keep your data only as long as is necessary to deliver our services or to comply with relevant legislation, or until you request that we erase your data [see 8: What are your data protection rights?]
7. Our role as a data processor
When we deliver marketing campaigns and related digital services we process data from your website visitors and customers on your behalf. In this case you are the controller of such data, and we are a data processor.
We comply with the requirements as per GDPR Article 28, including:
- Only carrying out processing on your behalf and as per your instructions
- Using sufficient technical and organisational security measures to protect data that we process on your behalf
- Requiring our employees to treat your data as confidential
- Governing this processing by a Data Processing Agreement
We would like to send you information about products and services of ours that we think you might like, as well as those of our partner companies.
Whether you have consented to receive marketing communications from us, or these are sent based on legitimate interest, you may always opt out at a later date.
You have the right to stop HC Marketing Limited from contacting you for marketing purposes, or from giving your data to other HC Marketing Limited Group Companies, at any time.
If you no longer wish to be contacted for marketing purposes, please contact us.
9. What are your data protection rights?
We would like to make sure that all of our website users are aware of their data protection rights:
The right to access – You have the right to request that HC Marketing Limited provides a copy of your personal data that we hold. We may charge you a small fee for this service.
The right to rectification – You have the right to request that HC Marketing Limited corrects any information you believe is inaccurate. You also have the right to request HC Marketing Limited completes any information you believe is incomplete.
The right to erasure – You have the right to request that HC Marketing Limited erases your personal data, under certain conditions.
The right to restrict processing – You have the right to request that HC Marketing Limited restricts the processing of your personal data, under certain conditions.
The right to object to processing – You have the right to object to HC Marketing Limited’s processing of your personal data, under certain conditions.
The right to data portability – You have the right to request that HC Marketing Limited transfers the data that we have collected to another organisation, or directly to you, under certain conditions.
You may contact us if you have any questions about how we handle your data, or would like to exercise one of your rights. You are entitled to a reply within 30 days.
10. Privacy policies of other websites
12. How to contact us:
HC Marketing Limited
Floor 2, Rock House
49-51 Cambridge Road
07469 175 712
13. How to contact the ICO:
Should you wish to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner, you may contact the Information Commissioner’s Office.