Privacy policy

Our Privacy Policy sets out how we will process the information that personally identifies any individual
(‘Personal Data’) that we collect and receive from and about users of our website or subscribe to our newsletters.

In simple terms, our privacy pledges to you are:

  • We will only collect, keep, use and share Personal Data for legitimate business reasons that we explain in this document, or if we’re legally required to do so.
  • We will be as clear and open as we can with you on what Personal Data we collect and how it will be processed.
  • We will keep all Personal Data up to date and reflect your preferences. We will also keep all data safely and securely with appropriate measures to prevent abuse.
For our customers and clients
Data Collection

We collect the following Personal Data from or about you as a customer of Carswell Gould:

  • Personal Data collected directly from you through business processes, such as your name, phone number, postal
    address, email address. The legal basis for the collection and processing of this data is the provision to you
    of the services accessed by you.
  • Personal Data collected automatically from the use by you of the website. The data transmitted from your browser
    such as your IP address, the date and time of the visit, the pages accessed, the access status/HTTP status code,
    your browser, your operating system and interface, as well as the language and version of the browser software.
    The legal basis for collecting and processing this personal data is to be able to operate the website and
    provide you with access to the pages you wish to access.
  • Personal Data received indirectly through our suppliers which enables us to create and store and record
    communications history. The legal basis for collecting and processing this personal data is our legitimate
    interests in knowing more about our customers.
Data Uses

We use your Personal Data:

  • For the administration of your account and to contact you about your account (for example with details on the work we produce for you).
  • To contact you with marketing messages which you have requested or agreed to receive from us (for example via a email newsletter).
  • To contact you with surveys and feedback requests
Cookies

We use cookies (small text files which are transferred to your browser by the website to identify data
traffic patterns, personalise contents and support security). The cookies we use are described in more detail in our
cookie statement. They do not provide any information which might disclose the identity of a specific person but
they may potentially identify your computer, your browser and your internet settings. You can easily change how
cookies are stored and used in your browser settings at any time by selecting the function “accept no cookies”.
However,  by disabling essential cookies, some website features may no longer work.

Google Analytics

Google Analytics, a web analytics service provided by Google Inc. (“Google”), also places cookies on your
computer to enable Google to provide us with activity reports relating to the website. Google uses this data only
to provide us with information on how users use the website and does not associate your IP address with any other
data held by Google. The information generated by Google cookies about your use of the platform (including your IP
address) will be transmitted to and stored by Google on servers in the United States. Again, if you wish to stop
this, you can stop these cookies being collected by changing the settings on your browser or by downloading and
installing the browser plug-in available under https://tools.google.com/dlpage/gaoptout?hl=en-GB.

Data Sharing

Carswell Gould will not sell your information. We will not share your information with any third party, except as stated in this Privacy Notice or as required to operate the website, provide our services to you and administer your account.

Social Media

We will share your Personal Data with social media sites to enable them to provide marketing messages that you have agreed to receive from them. The social media sites we share your Personal Data with, as at the date of this Privacy Policy and their respective privacy statements, are:

  1. Facebook, https://www.facebook.com/privacy/explanation
  2. Hootsuite, https://hootsuite.com/legal/privacy
  3. Twitter, https://twitter.com/en/privacy
  4. Linkedin, https://www.linkedin.com/legal/privacy-policy

For our followers on Social Media

Data Collection

If you follow one of our social media channels, Carswell Gould will receive Personal Data about you, such as
your account name, gender, general interests, location, age. The legal basis for processing this data is our
legitimate interest in providing social media and marketing content that is of interest to our followers on social
media.

Data Uses

We use this Personal Data:

  • to provide bespoke social media content (for example, by analysing your general interests).
  • to create targeted content across all our social media channels (for example, by analysing responses to posts, events and videos).
  • to find out more about our digital community (for example, by analysing the age ranges of our followers).
Data Sharing

Carswell Gould will not sell your information. We will not share your information with any third party,
except as stated in this Privacy Notice or as required to operate the sites, provide our services to you and
administer your account.

For our website visitors

Data Collection

By using our website, we collect Personal Data about you, such as: site referrals, browsing pattern, browser
type, location, general interests, gender, age. The data transmitted from your browser includes your IP address, the
date and time of the visit the pages accessed, the access status/ HTTP status code, your browser, your operating
system and interface, as well as the language and version of the browser software. The legal basis for collecting
and processing this personal data is our legitimate interest in operating the sites, providing  you with access to
the pages you wish to access, understanding the interests of our potential customers and providing you with relevant
information about our services.

Data Uses

We use this Personal Data:

  • to provide you with bespoke website content (for example, by analysing our site visitors’ age
    ranges);
  • to gain insight into your behaviour and preferences (for example, by analysing the website pages you
    visit);
  • to create bespoke marketing messages (for example, by analysing the click-throughs on our site);
  • to re-target our website visitors with relevant marketing messages (for example by using cookies
    hosted on our site);
  • to collect site statistics.

For more information please see our Cookie Statement.

Data Sharing

Carswell Gould will not sell your information. We will not share your information with any third party,
except as stated in this Privacy Notice or as required to operate our website, and we will provide our services to you and
administer your account, or otherwise as required or permitted by law.

 

For our data processors

We use third party processors to collect, export, process and store Personal Data on our behalf. The processors we use
currently are the following:

  1. Google Drive, https://cloud.google.com/security/compliance/eu-data-protection/
  2. Social Media Platform: Facebook, some data centres located in the U.S. Privacy Shield Certified. https://www.facebook.com/privacy/explanation
  3. Survey Tool: Survey Monkey, located in the U.S. Privacy Shield Certified. https://www.surveymonkey.com/mp/policy/privacy-policy/
  4. Email marketing
    Carswell Gould uses the Campaign Monitor system, on behalf of our clients
    and for ourselves, to send e-newsletters and other electronic content. Campaign Monitor is based in
    Australia but Carswell Gould has enacted an additional Data Protection Agreement which ensures that all
    Carswell Gould data processed by Campaign Monitor is compliant with EU GDPR regulations. You can access
    the agreement here or see the general policy here.
  5. Web Management Tools
    1. Moz, https://moz.com/privacy-policy
    2. Google Analytics, located in the U.S. Privacy Shield Certified. https://www.google.com/policies/privacy/

 

International Data Transfers

We use data processors located outside the European Economic Area only after taking such steps as are
required to ensure that Personal Data they process on our behalf receives protection equivalent to that provided in
the EEA. Our processors are either certified as compliant with the EU-U.S. Privacy Shield Framework where they are
located in the USA or have entered into an agreement with us, containing the model clauses approved by the European
Commission as providing contractual protection equivalent to that provided by the data protection regulations
applicable in the EEA. To learn more about the Privacy Shield program, please visit www.privacyshield.gov.

Data Security
  • We use a variety of technical and physical safeguards which exist to protect the security and
    integrity of your Personal Data. This helps protect it from accidental or unauthorised access, use,
    alteration or disclosure to unauthorised third parties. These measures include device encryption, firewalls
    and virus checking procedures.
  • Where we keep Personal Data files on local devices, these devices are protected and accessible only
    to authorised Carswell Gould employees.
  • As a matter of course, we undertake periodic reviews of our security systems to ensure that they
    remain fit for purpose and that your Personal Data remains safe and secure.
Duration of Storage

  • We will maintain records of your Personal Data for as long as you remain:

    • a registered subscriber to our mailing list;
    • have completed a purchase with Carswell Gould in the last 36 months; or
    • for as long as is necessary to provide our services to you.

 

If you have not opened any email communication from a Carswell Gould brand or interacted in any other way
with our brands for 36 months, we will regard you as an inactive subscriber and delete your details from our records
except where retention is necessary to enable us to enforce our legal rights, or to protect the rights, property or
safety of our employees.

Your Rights in Relation to Personal Data
  • You can update your subscription preferences or unsubscribe from our marketing communications at
    any time by following the link in the footer of the last email you received from us (“Update your
    subscription preferences” or “Unsubscribe”) or by sending your request with detailed instructions for our
    Account Management team.
  • You have the right to update and correct the personal information on your account. You also have
    the right to request from us all personal information that we hold that relates to you, to request
    restriction of the processing of that data and to request that we delete that data.  Where allowed by
    applicable law, there may be an administrative charge for supply of copies of data and we may also require
    you to provide us with appropriate identification before we comply with this request. You also have the
    right to object to our continued processing of your personal data.  You may also have the right to data
    portability. If you have a complaint about the way in which we use your personal information, you have the
    right to complain to the Information Commissioner www.ico.gov.uk.
Changes to our Privacy Notice

We will update this Privacy Notice from time to time to reflect changes in our business. All such changes
will be posted to the website and where necessary, we will also contact our subscribers by email.

Contacting us

Carswell Gould Marcom Ltd is the Data Controller in respect of any Personal Data that you submit to us or
that we collect from or about you. We are a company registered in England and Wales (registered no. 10149312) with
registered offices at 16 Brunswick Place, Southampton, SO15 2AQ

If you would like to know what information we hold about you or if you have any other queries or complaints
in relation to this Privacy Notice, or our Sites, our contact details are as follows:

Carswell Gould Marcom Ltd, 16 Brunswick Place, Southampton, SO15 2AQ
[email protected]
023 8023 8001