privacy policy 

 

We ask that you read this privacy policy carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.

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

 

Full name of legal entity: Client Talk Limited

Email address: info@clienttalk.co.uk

Postal address: Unit 4, City Limits, Danehill, Reading, RG6 4UP

 

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.

 

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.

 

This privacy policy is divided into the following sections, which you can click through to if you choose to do so:  

  

 
 Who we are 
 
This website is operated by Client Talk Limited. We are a marketing and business development consultancy.   
 
We collect, use and are responsible for processing certain personal information about you. When we do so we are regulated under the Data Protection Act 2018, which gives effect to and supplements the General Data Protection Regulation which applies across the European Union (including in the United Kingdom) and the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 and we are responsible as ‘controller’ of that personal information for the purposes of those laws. 
 
Our website 
 

This privacy policy aims to give you information on how Client Talk Limited collects and processes your personal data through your use of this website, including any data you may provide through our website.

 

This website is not intended for children and we do not knowingly collect data relating to children.
 
Throughout our website we may link to other websites owned and operated by certain trusted third-parties to provide you with relevant information. 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. For privacy information relating to these other third-party websites, please read their privacy policies as appropriate. 
 
Our collection and use of your personal information 
 

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 information about you when you browse our website, register with us, contact us, send us feedback, purchase products or services via our website and compete customer surveys or participate in competitions via our website. 
 
The personal information we collect about you depends on the particular activities carried out through our website. This information includes: 
 

  1. Identity Data includes your full name, title and gender

  2. Contact Data includes your billing address, delivery address, email address and telephone numbers

  3. Financial Data incudes bank account and payment card details

  4. Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us

  5. 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.

  6. Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses

  7. Usage Data includes information about how you use our website, products and services.

  8. Marketing and Communication Data includes details of any feedback you give us by phone, email, post or via social media  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.

 
We use this personal information to: 
 

  • create and manage your account with us 

  • verify your identity 

  • provide goods and services to you 

  • customise our website and its content to your particular preferences 

  • notify you of any changes to our website or to our services that may affect you 

  • improve our services

  • provide you with information, including insights and invitations to events 

 
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 goods or 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.
 
Our legal basis for processing your personal information 
 
When we use your personal information we are required to have a legal basis for doing so. There are various different legal bases on which we may rely, depending on what personal information we process and why. 
 
The legal bases we may rely on include:  
 

  • contract: where our use of your personal information is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract 

  • legal obligation: where our use of your personal information is necessary for us to comply with a legal obligation

  • legitimate interests: where our use of your personal information is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal information which overrides our legitimate interests) 

 

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.

 

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 below.

Purpose: To register you as a new customer

Type of data: (a) Identity; (b) Contact

Lawful basis: Performance of a contract with you

 

Purpose: To process and deliver your order including: (a) Manage payments, fees and charges; (b) Collect and recover money owed to us

Type of data: (a) Identity; (b) Contact; (c) Financial; (d) Transaction; (e) Marketing and Communications

Lawful basis: (a) Performance of a contract with you; (b) Necessary for our legitimate interests (to recover debts due to us)

Purpose: To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy; (b) Asking you to leave a review or take a survey

Type of data: (a) Identity; (b) Contact; (c) Profile; (d) Marketing and Communications

Lawful basis: (a) Performance of a contract with you; (b) Necessary to comply with a legal obligation; (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

 

Purpose: To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Type of data: (a) Identity; (b) Contact; (c) Technical

Lawful basis: (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise); (b) Necessary to comply with a legal obligation

 

Purpose: To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

Type of data: (a) Identity; (b) Contact; (c) Profile; (d) Usage; (e) Marketing and Communications; (f) Technical

Lawful basis: Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

 

Purpose:  To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

Type of data: (a) Technical; (b) Usage

Lawful basis: Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

Purpose: To make suggestions and recommendations to you about goods or services that may be of interest to you

Type of data: (a) Identity; (b) Contact; (c) Technical; (d) Usage; (e) Profile; (f) Marketing and Communications

Lawful basis: Necessary for our legitimate interests (to develop our products/services and grow our business)

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.

 

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.

 

 

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.


 
Further information—the personal information we collect, when and how we use it 
 
For further details on when we collect personal information, what we collect as well as how we use it, please read the following: 

When information is collected: When you register with us 

What information we ask for:  Contact details: your name, email address and telephone number 

How and why we use your information: We ask for this: 

  •  to create and manage your account with us 

  •  to communicate with you about your account 

 

We rely on legitimate interests as the lawful basis for collecting and using your personal information. 

We will keep this information until: 

  •  you close your account with us 

  •  we close your account 

  

Who we share your personal information with 

We will share personal information with law enforcement or other authorities if required by applicable law. 

 

We currently do not share personal information with any other third party. 

 

We may share personal information with 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 will always will get your express opt-in consent before we share your personal data with any third party for marketing purposes. You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.

 

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.

We do not transfer your personal data outside the European Economic Area (EEA).

 
Cookies and other tracking technologies 
 
A cookie is a small text file which is placed onto your device (eg computer, smartphone or other electronic device) when you use our website. We use cookies on our website. These help us recognise you and your device and store some information about your preferences or past actions. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
 
Marketing 
 

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).

We would like to send you information about Client Talk Ltd, eg, products and services, competitions and special offers, which may be of interest to you. Where we have your express opt-in consent we may do this by post, email or telephone. 
 
We will only ask whether you would like us to send you marketing messages when you tick the relevant boxes when you complete our form for the first time.  
 
If you have previously agreed to being contacted in this way, you can unsubscribe at any time by: 
 
—contacting us at info@clienttalk.co.uk 
 
—using the ‘unsubscribe’ link in emails 
 
It may take up to 5 days for this to take place. 
 
For more information on your rights in relation to marketing, see ‘Your rights’ below. 
 
Your rights 
 

Under certain circumstances you have rights under data protection laws in relation to your personal data. These include:
 

  • request access to your personal information

  • require us to correct any mistakes in your personal information which we hold 

  • require the erasure of personal information

  • object at any time to processing of personal information

  • request restriction of processing of your personal information

  • request transfer of your personal data

  • right to withdraw consent

 
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation. 
 
If you would like to exercise any of those rights, please email, call or write to us using the contact details provided at the start of this privacy policy.

 

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.

 

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.

 

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.


Keeping your personal information secure 
 
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a genuine business need to know it. Those processing your information will do so only on our instructions and are subject to a duty of confidentiality. 
 
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so. 

How to complain 
 
We hope that we can resolve any query or concern you raise about our use of your information. 
 
You have the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113. 
 
Changes to this privacy policy 
 
We keep our privacy policy under regular review. This website privacy policy was published on 25 September 2019 and last updated on 23 October 2020. 

How to contact us 
 
Please contact us if you have any questions about this privacy notice or the information we hold about you.