Effective Date / Last Modified: 5th May 2018
The General Data Protection Regulation (“GDPR”) is the biggest shake up of Data Protection and Privacy laws in the EU in decades and is forcing companies to change the way they use Personal Data; and it ensures you have greater control over how your data is used by companies in today’s technological world. Please take the time to read this statement to understand how we process the personal data we may hold about you. We may need to update this from time to time so do check back regularly to stay up to date.
2. About ContentCrowd
Who we are:
Content Crowd Ltd of Quay House, Quay Road, Newton Abbot, Devon, TQ12 2BU (company number: 07277582). For any privacy or data protection queries please email ContentCrowd at email@example.com
. You can also call us on +44 (0)20 3322 3485, email us for general enquiries at firstname.lastname@example.org
or write to us at ContentCrowd c/o WeWork Moorgate, 1 Fore Street Avenue, London, EC2Y 9DT, United Kingdom.
Privacy Main Contact:
Mr. Gareth Morris, Director, email@example.com
What we do:
ContentCrowd provides content syndication & lead generation services to businesses looking to promote their content to other businesses. We do this by hosting content on our site and utilising email promotion.
Why we do it:
It’s our mission to enable businesses to promote more effectively and to enable individuals to search for and find relevant content that they want.
3. Lawful Basis for processing Personal Data
The General Data Protection Regulation (GDPR) defines six lawful bases for the processing of Personal Data. Of these six we have concluded that our most appropriate lawful basis for processing personal data is legitimate interest. This is because:
4. What data does ContentCrowd have?
- The lead generation services we offer are designed to enable our customers to promote their offerings more effectively to the right people at other businesses; we only provide business to business lead generation services.
- By hosting our customers’ content in our ‘Content Library’ we can also provide additional opt-in consent to customers when individuals choose to take specific content.
- The processing we do is very unlikely to affect the fundamental rights and freedoms of the individuals whose data we process when we perform our lead generation services. We have concluded this because:
- We only process information that is:
- specific to business (B2B) data (never personal (B2C) data);
- in the public domain;
- available to individuals who can search for and obtain the content they want by agreeing to opt-in and receive such content using form-fill options on our site.
- We help our customers promote their offerings more effectively to those individuals in businesses who would reasonably have a legitimate interest in receiving such communication
- It’s in the interest of individuals whose personal data we process for us to maintain healthy and accurate information so that businesses can better reach the most relevant business contacts
- As a ContentCrowd customer we will rely on our contractual relationship to process your personal data to provide goods and/or services to you.
- Should we rely on your consent in any circumstances to process your personal data you can easily withdraw your consent at any time by contacting us at firstname.lastname@example.org or by using any unsubscribe mechanism supplied (such as an unsubscribe link in an email).
The type of information we may process about you may include:
- Personal Data, such as your name, your business telephone number and email address, that may be processed from the public domain, for example on a website or public register, or information that you give to us when you become a customer;
- Details you provide to us by filling in forms, using chat tools on our sites or via telephone or email;
- If you contact us, we may keep a record of that correspondence;
- Details of transactions you carry out through our site and of the fulfilment of your orders; and
- Details of your visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing or other purposes.
- In order to support system administration and reporting we may collect your computer information (such as IP address to identify your location when signing up to ContentCrowd). We will never pass on this information to third parties unless required to by law.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer or mobile device. For example, cookies can be used to collect information about your use of the services during your current session and over time (including the webpages you view and the files you download), your operating system and browser type, your internet service provider, your domain name and IP address, the website that you visited before our website, and the link that you use to leave our website.
If you are concerned about having cookies on your computer, you can choose to set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it. You can also delete cookies from your computer. However, if you choose to block or delete cookies, certain features of the ContentCrowd services or web site may not operate correctly.
6. What does ContentCrowd do with the data?
Use of the data for providing services:
ContentCrowd may use your personal data when providing lead generation services to its customers. When a customer contracts us to do this ContentCrowd is a data processor and our customer is the data controller with respect to the Data Protection Laws. When we provide services we shall:
- match information provided by our customer against the data we may process to determine the best individuals to target for our customer; we do this by understanding the job title/role, company and location of individuals that best fit this criteria;
- perform our services in accordance with applicable data protection laws
- use email and telemarketing communication to offer our customers’ products and/or services to the individuals who may reasonably have a legitimate interest in receiving such marketing communication;
- communicate with you using domains that we own. These are: accountingvip.com; totalprofession.com; dailywhitepaper.com; marketertrends.com; salesfeature.com; techprocontent.com; informhr.com; featuredit.com; techhound.com; it-whitepapers.net; martechdaily.com;
- ensure you can easily opt out of receiving any future communication from us and that you know your privacy rights and can instruct us when exercising your rights;
- confirm which 3rd parties as appropriate we pass your personal data on to and why. The only personal data we shall ever provide to our customers are your name, job title, business email address, business telephone number and if applicable your public LinkedIn profile link.
- ensure reasonable steps are taken to process and store data securely and in accordance with applicable laws
It is mission-critical for our business to be able to have access to and use accurate data that enables us to deliver a high quality service. Therefore, we will retain your personal information for as long as it remains accurate and up to date (as best we can tell it is accurate) and we will remove your data if we confirm that it is no longer accurate or you have requested to restrict us from processing your data. You may request for us to delete or erase your data and we will comply with such requests unless the law restricts us from doing so, in which case we shall restrict the processing of your data and explain this to you at the time.
Use of the data outside of providing services:
We use your information for several other purposes outside of providing lead generation services such as:
- Providing our customers with the confidence that we have access to accurate data that enables us to better promote their goods and services using direct marketing to the right people (decision makers, influencers, champions etc.) in other businesses;
- Ensuring we can keep an accurate list for suppression purposes in accordance with the appropriate data protection laws;
- Where applicable helping us keep you up to date our services, changes in policies and other important notifications;
- Enabling you to interact with features or tools on our website such as our live chat function;
- Providing you with the services we have and offering new services;
- Improving your user experience;
- Gathering analytics on usage and other statistics in order to improve features and functionality.
Should we need to contact you we will generally do this via email from our email@example.com
address but we may also contact you by post or telephone unless you request otherwise.
7. Your Rights
You have the right to:
8. Changes to this Privacy Notice
- Access: You may request to see the personal data we hold about you. This includes the right to obtain a confirmation as to whether or not we process any of your personal data;
- Rectification: You may request that we correct any inaccuracies in the personal data that we hold on you;
- Be Forgotten: From May 2018, in certain circumstances you may have the right to be forgotten (which means we have to erase your personally identifiable data). In such cases we would recommend typically that we supress you from future communications, rather than delete your data;
- Restriction: In some cases you may ask for the processing of your personal data to be restricted because there is some disagreement about its accuracy or legitimate usage – i.e. requesting that we do not process your personal data for direct marketing purposes by keeping a single record of your data on a suppression list;
- Object: to state that you object to our processing of your personal data if we are relying on legitimate interest as the lawful ground for processing; and
- Portability: You may request to have your personal data transferred from us to a different organisation.
, we will post these changes on our web site(s) in order to keep you informed and where appropriate, we shall notify you via email.