Regulation (EU) 2016/679 of the European Parliament – the General Data Protection Regulation (‘GDPR’) – obliges us to provide you with information about how and why we use your personal data. We recognise our obligations and your legal rights set out in the GDPR.
Scope & definitions
- Registered users of Brookes & Co or its associated services processing a database or email list. These users are referred to as CLIENTS in this declaration.
- Members of the database list or recipients of the permission-based marketing e-mails by an intermediary of Brookes & Co. These mailing lists are generated by the clients of Brookes & Co and administered by Brookes & Co. The members of these mailing lists are referred to as SUBSCRIBERS.
- Internet users seeking information from a website administered by Brookes & Co. The users of these sites are referred to as USERS.
Brookes & Co is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website or its associated services, then you can be assured that it will only be used in accordance with this privacy statement. Brookes & Co may change this policy from time to time by updating this page.
Brookes & Co is committed to protecting and respecting your privacy and complying with the principles of the GDPR. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
For the purpose of the GDPR, the data controller, or in the case of handling clients’ mailing lists for permission-based marketing, the data processor is Brookes & Co, St Mary’s House, 25 Church Street, Uttoxeter, Staffordshire ST14 8AG.
We aim to process information about you fairly and in a transparent manner and the aim of this document is to provide you with sufficient information for you to be able to understand what we are doing with your data. If you are unsure how we are handling information about you or you think we could improve our privacy information, please let us know.
What we collect
We may collect the following information: name and job title; contact information including email address; geodemographic information such as postcode, preferences, and interests; other information relevant to customer surveys and/or offers.
All personal data will be used exclusively for administrative purposes.
Use of personal information
Brookes & Co will not divulge any client’s or subscriber’s personal information. The user of www.brookesandco.net can, without obligation, gather essential information regarding Brookes & Co provided that the user does not reproduce the content for personal or commercial purposes.
If the user wishes to download electronic documents from the site, subscribe to a mailing list or become a client of Brookes & Co, Brookes & Co reserves the right to gather personal information about the user with the objective of verifying, where applicable, the identity or registration, or to subscribe them to a mailing list.
What we do with the information we gather
We require this information to understand your needs and provide you with a better service, and in particular for the following reasons: internal record keeping; we may use the information to improve our products and services; we may periodically send permission-based marketing emails about a client’s new products or service, special offers or any other information which we think you may find interesting using the email address which has been provided.
Any marketing that we create for our clients, regardless of online or offline, will be considerate to the ways an individual will consent to receive further communications, which is a positive confirmation that is clearly presented. We maintain records of the process of consent for presentation to that client, individual or the ICO if required. All staff, from marketing services to studio, HR and accounting, are trained to understand their obligations.
From time to time, we may also use your information to contact you for market research purposes or to help administer an event on behalf of our client. We may contact you by email, phone or mail.
All personal data provided to Brookes & Co will be stored in a secure database and protected with SSL (Secure Socket Layers). This data, including subscriber lists belonging to the clients of Brookes & Co, will be exclusively accessible by a secure interface, protected by authentication. Access to this data is only available to Brookes & Co authorised personnel for maintenance and analysis purposes.
Brookes & Co will not divulge any information allowing a client or subscriber to be publicly identified without their prior written permission.
Brookes & Co and its clients promise to never rent, sell or disclose their subscriber lists to third parties without the prior consent of subscribers except in the rare circumstance where European law requires it in accordance with a court order.
Disclosing, sharing and transferring your personal data
We may share personal data with some of our suppliers who process data on our behalf to help us to provide services to our clients. Categories of organisation and purpose are listed below:
- Marketing agencies – to provide relevant digital content to our clients
- Marketing database hosting & cleansing companies, mailing housing and email broadcasters – to provide permission-based marketing services/fulfilment services
- Database hosting companies – to host our CRM database including data storage
- Venue service providers – for the administration and operation of events
- Market research companies – to undertake research on behalf of our clients
- Freelance subcontractors – to provide creative services to our clients
We require these recipients to only use personal data for the intended purpose of the disclosure and that they destroy or return it when it is no longer needed.
We may also disclose personal data to third parties (the police, DVLA or any other public authority body) from time to time if we are under a duty to comply with any legal obligation.
The data processing is carried out using computers and/or IT enabled tools, following procedures strictly related to the purposes indicated. In addition to the data controller, in some cases, the data may be accessible to certain types of persons in charge, involved with the operation of the site (administration, sales, marketing, system administration) or external parties (such as third party technical service providers, mail fulfilment, hosting providers, IT companies, communications agencies) appointed, if necessary, as data processors by the data owner.
We will only hold data for a given period. If we have had no transaction or activity with a contact on the client mailing lists of Brookes & Co, it will be deleted after a maximum of three years. This applies to all data, including: customers, potential customers and any other information we hold on individuals.
Consent and identity
Subscribers, clients and users may decline at any time to make personal information available on the website www.brookesandco.net. However, Brookes & Co reserves the right to accept or decline the registration if the personal data is found to be incomplete, fraudulent or furnished by a subscriber who has not attained the age of majority. Any data not conforming to the rules detailed above will be removed from the client database by Brookes & Co.
Corrections and un-subscriptions
A client of Brookes & Co may communicate, through the contact section of the website with regards to correcting or validating information submitted.
Subscribers to the client mailing lists of Brookes & Co are asked to communicate directly with the client to correct or validate any personal information regarding their registration to all permission-based marketing emails. If a subscriber’s modification requests are not respected by a client of Brookes & Co, Brookes & Co reserves the right to impose sanctions on the client’s usage.
Brookes & Co requires all clients of Brookes & Co to include a clearly articulated option to unsubscribe from the mailing list in all permission-based marketing e-mails.
A subscriber may be able to unsubscribe at any time from a subscriber list generated by a client of Brookes & Co. The subscriber may also unsubscribe at the same time from the subscriber lists by submitting a verbal or written request to the client. Should an unsubscribe request made by a subscriber not be met by a client of Brookes & Co service within a period of 72 hours, the subscriber may lodge a complaint directly with Brookes & Co through the contact section of the website.
Brookes & Co reserves the right to impose sanctions or to suspend service to any, and all, clients who do not conform to these requirements.
Brookes & Co cannot be used for fraudulent purposes, those of an explicit nature or any activity not respecting European law or that of any country to which e-mails are being sent.
Any clients of Brookes & Co or its associated services not conforming to the content rules will have their service blocked without warning. Brookes & Co reserves the right to pursue any client not conforming to these rules to protect the integrity of the services offered to its subscribers, clients, and users.
Links to other websites
The website www.brookesandco.net, as well as all electronic communications transmitted by the clients of Brookes & Co are permitted to contain hyperlinks to other sites either belonging to partners of Brookes & Co or not.
Usage of secondary information
Invisible GIFs and pixel tags are utilised in the permission-based marketing e-mails sent by the clients of Brookes & Co to permit Brookes & Co to assemble general information regarding the success of transmission.
Once a subscriber opens an HTML e-mail sent by a client of Brookes & Co, the computer of the recipient grants access to Brookes & Co’s servers to transmit these invisible GIFs. This tool allows Brookes & Co to assemble the following information: e-mail addresses and the dates and times of the delivery and opening of messages. This data allows Brookes & Co to optimise the e-mail delivery and ensures the transmission rules of all permission-based marketing e-mails are being respected by the clients of Brookes & Co.
Brookes & Co reserves the right to gather IP addresses in its files for statistical purposes or to test the functionality of its e-mail servers.
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added, and the cookie helps analyse web traffic or lets you know when you visit a site. Cookies allow web applications to respond to you as an individual.
The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. We use traffic log cookies to identify which pages are being used.
This helps us analyse data about webpage traffic and improve our website to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
Notification of changes
This policy is under regular review and may be adapted pending legislative changes.
Kate Newton, Managing Director, Brookes & Co, St Mary’s House, 25 Church Street, Uttoxeter, Staffordshire, ST14 8AG, firstname.lastname@example.org.
This policy is effective from 14th May 2018.