Website Privacy Notice

(Version 14 May 2018)

1. Introduction
   1. We are committed to safeguarding the privacy of our website visitors and service users; in this policy we explain how we will handle your personal data.
2. How we use your personal data
   1. In this Section 2 we have set out:

      (a) the general categories of personal data that we may process;

      (b) the purposes for which we may process personal data; and

      (d) the legal bases of the processing.

   2. We may process information contained in any enquiry you submit to us regarding products and/or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you. The legal basis for this processing is consent.
   3. We confirm we are operating in compliance with the GDPR, PECR and the DMA and the current Data Protection Laws.
3. Providing your personal data to others
   1. We may disclose the following information to our subcontractors insofar as reasonably necessary for processing your inquiry:
      • First Name
      • Last Name
      • Job Title
      • Company name
      • Company registration number
      • Website
      • Email address
      • LinkedIn profile ID
      • Company telephone number
      • Trading or registered address
      • Sector
      • Turnover or estimated turnover
      • Employee numbers or estimated employee numbers
      • Profit or estimated profit
      • Growth rate or estimated growth rate
      • Year founded
   2. In addition to the specific disclosures of personal data set out in this Section 3, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person
4. Retaining and deleting personal data
   1. This Section 4 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
   2. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
   3. All personal data will also be audited and updated annually to ensure it is kept up to date. We continue to hold personal data if a data subject asks to be unsubscribed as we need to have a record of the data in order to avoid contacting the individual requesting to be unsubscribed again in the future. Data subjects have the right to request we remove their data from our database, which we will of course do, but we do so on the grounds that the data subject understands that removal of their data means that we cannot guarantee to avoid contacting them again in the future.
   4. Notwithstanding the other provisions of this Section 4, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
5. Amendments
   1. We may update this policy from time to time by publishing a new version on our website.
   2. You should check this page occasionally to ensure you are happy with any changes to this policy.
6. Your rights
   1. In this Section 6, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
   2. Your principal rights under data protection law are:

      (a) the right to access;

      (b) the right to rectification;

      (c) the right to erasure;

      (d) the right to restrict processing;

      (e) the right to object to processing;

      (f) the right to data portability;

      (g) the right to complain to a supervisory authority; and

      (h) the right to withdraw consent.

   3. You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
   4. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
   5. In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.
   6. In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
   7. You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.
   8. You have the right to object to our processing of your personal data for direct marketing purposes. If you make such an objection, we will cease to process your personal data for this purpose.
   9. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
   10. To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
   11. You may exercise any of your rights in relation to your personal data by written notice to us.
7. Our details
   1. This website is owned and operated by Black Card Marketing Limited, Axminster Devon, EX137RL
   2. We are registered in England and Wales under registration number 06598692, and our registered office is at 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ.
   3. Our principal place of business is given above.
   4. You can contact us: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ.
8. Data protection officer
   1. Our data protection officer's contact details are: Rodney Giles. Address as above (7.2).