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Thursday 18th April 2019 | Telephone numbers on TPS: 18,833,385 | Telephone numbers on CTPS: 2,250,187 | Total numbers registered: 21,083,572

Privacy Notice – Business Contact Data

We are 121prodata Ltd is a company based in the United Kingdom. 121prodata controls personal data about our business contacts and their representatives.

121prodata is registered in England and Wales under registration number 05832245, and our registered office is at 7-10 Chandos Street, London W1G 9DQ. Our principal place of business is 1 Ashway, Northleach, Cheltenham, Gloucestershire GL54 3PB.

You can contact us about issues relating to personal data, including the contents of this notice, by any of the following methods:
Post: 1 Ashway, Northleach, Cheltenham, Gloucestershire GL54 3PB
Email: privacy@121prodata.co.uk
Telephone: 01451 860805

This section explains the purposes for which we use personal data about our business contacts and their representatives. More detail about the types of personal data that we might use for these purposes can be found in section 4 below.

Marketing
We use personal data for marketing purposes, typically in relation to current or potential clients and their representatives. This includes providing you with original insight, commentary and research on data, marketing and research, early notifications of exclusive events, webinars and updates on our products and services. We will not make contact with you for marketing purposes through any channel (such as email, telephone or post) if you have told us that you don't want to hear from us in that way. Please note that if you ask us not to contact you for marketing purposes, you might still hear from us for other reasons – for example, as part of our ordinary relationship management activity.

Relationship management
We use personal data for relationship management purposes. Relationship management is the ongoing maintenance of our relationship with our clients, suppliers and their representatives. This could include activities such as letting you know about service changes, projects and campaigns, planned maintenance activity, contacting you with billing enquiries, inviting you to events and webinars, dealing with your enquiries, or asking you about what sorts of services you want us to develop.

Providing services
We use your personal data to provide you with information and services that you have asked for. For example, if you commission a project or campaign, we will use your contact details to keep you informed of progress. If you sign up to one of our events or webinars we might use your contact details to let you know how to access it.

Monitoring and improving our website
We use information such as how different people navigate around our website, how long they spend on particular pages, whether they download any of our content (including service information, agreements, white papers and so on) in order to help improve the user experience of our website. It also allows us to tailor the website to match your interests and preferences better and helps us understand who has visited which pages to determine the most popular areas of the website. This information is also used for security and system administration and to generate aggregate non-personalised information for use by us.

Legal and regulatory purposes
We may use your personal data for legal and regulatory purposes. For example, this might include responding to complaints or enquiries from you or a regulator about how we have used your personal data.

The United Kingdom’s data protection law allows the use of personal data where the benefits (or “legitimate interests”) of doing so outweigh the possible negative implications for the relevant individuals. If you object to us using these grounds you can do so at any time as explained in section 9.

The benefits that are being pursued are:

Interest Explanation
Marketing We have an interest in promoting our services to our clients and potential clients by email, telephone and post.
Helping people learn about services that might be of use to them Our clients and potential clients have an interest in learning about services that they might find useful.
Maintaining and using our business relationships; understanding and keeping in touch with our clients and suppliers We have an interest in maintaining and making use of our relationship with you. For example, if you work for one of our clients we may need to contact you in connection with one of the services that your employer has purchased from us. Or if you work for one of our suppliers we may need to contact you about a service that your employer supplies to us. We also have an interest in understanding what kinds of people use our services and how they use them.
Commercial Interests Like any commercial organisation, we seek to earn revenue through services that we provide to our clients.

In some circumstances, we may have other grounds to process personal data. These are set out in the following table, along with examples of the circumstances in which they might apply.

Grounds Examples
Necessary for performance of a contract with the relevant individual, or to take steps for entering into a contract. If you sign up to one of our services, it will often be necessary for us to use your details in order to provide that service.
Necessary in order to comply with a legal obligation. Regulators, government bodies and courts have powers to order us to provide information and, like any other organisation; we sometimes have to comply with their requests.

We obtain and use information from various different sources.

Type of information Description Source
Name and contact details This is basic personal data about you at your place of work, and how to get in touch with you, including your name, job title, location, telephone numbers, email address and social media profiles. This information is usually provided directly by the relevant individuals; it could for example be given over the telephone, in an email, through our websites, or in person at an event. In addition, we may use publically-available and website sources, like LinkedIn, or marketing lists from carefully selected data suppliers.

We produce these records ourselves.
Organisation-related details This is information about your organisation, your role within it and who your colleagues are.
Contact history This is information about our dealings with you, such as what information we have sent you, who at 121prodata knows you, and what meetings, events or webinars you have attended. It also includes your behaviour in response to our interactions with you, such as whether you have opened our emails, clicked on a link or watched a video.
Device information We produce these records ourselves by monitoring your use of our website. We produce these records ourselves by monitoring your use of our website.
Website usage This is information about your use of our websites, such as what pages you have visited and what content you have downloaded.
Login credentials This is information such as your user name and password which are processed if you sign up to this website or require FTP access to securely share files. This information is provided by you or may sometimes be generated by us (for example if we set or reset your password).

Service providers
We may provide your information to third parties who help us use it for the purposes descibes in section 2. For example:

  • Our database of business contacts is hosted by third parties on our behalf.
  • We use a third party email broadcasting service in order to send you marketing emails.
  • We use a printing company to produce and send personalised direct mail.
  • We use market research companies to help us better understand our clients.
  • We use data services companies to clean our data and analyse, enhance and provide suppressions to keep it accurate.

These service providers will not be allowed to use your information for their own purposes or on behalf of other organisations, unless you agree otherwise.


Business Transfers
If we sell our business to a third party, or go through a corporate reorganisation, we will transfer personal data to the company that acquires the business.


Regulators
We may sometimes need to pass personal data to a regulator such as the Information Commissioner's Office.

Within Europe
We are based in the United Kingdom, and will normally access and use your information from here.


Elsewhere
Sometimes we will need to send information elsewhere in the world. This might be the case, for example:

  • Where we use cloud-based technology or a data centre or backup facility overseas. For example, our email marketing database and customer relationship management database (which will hold your information) are currently hosted by a service provider in the United States. People in other countries may also need to access that database for purposes such as technical support or system development and testing.

While countries within the European Union all ensure a high standard of data protection law, some parts of the world may not provide the same level of legal protection in relation to personal data. As a result, when we do send personal data overseas, we will make sure that suitable safeguards are in place to protect the information. For example, these safeguards might include:

  • Putting in place a contract with the recipient containing terms which have been approved by the authorities as providing a suitable level of protection.
  • Sending the information to an organisation which is a member of a scheme which has been approved by the authorities as providing a suitable level of protection. One example is the “Privacy Shield” scheme that has been agreed between the European and US authorities.

If your information has been sent overseas like this, you can obtain further information about the safeguards used by contacting us using the details set out in section 1 above.

We will normally keep your personal data while you have or your employer has an ongoing relationship with us or if you have demonstrated an interest in our products and services within the past two years. You can request us to delete it earlier as explained in section 9.

We use certain profiling techniques in order to help us to understand our clients and potential clients. This in turn helps us to understand which people might be interested in which of our products and services.

We do not use automated decision-making or profiling to make any decisions that will significantly affect you. For example, we do not use it to set the prices that we charge for our products and services.

You have several different rights in relation to the personal data that we hold about you. These are briefly described below. To enquire about exercising these rights, please use the contact details set out section 1.

Access: You have a right to find out what personal data we hold about you and certain other information such as how we are using it. You also have a right to receive information in a portable format in certain circumstances.

Objection to direct marketing: You can let us know that you object to us using your personal data for direct marketing. Please unsubscribe from our emails, or contact privacy@121prodata.co.uk

Rectification: If you believe that the information that we hold about you is inaccurate or out of date, you have a right to ask us to correct it.

Objection to legitimate interests: If you disagree with us relying on the legitimate interests ground for using your personal data (see section 3 above), you can object to us doing so. We will the reassess the extent to which we can continue to use the data in light of your particular circumstances. In the case of emails that are sent on the basis of legitimate interests (see section 3), you can do this by clicking on the ‘unsubscribe’ link.

Erasure: In certain circumstances you can ask us to delete your personal data from our systems. However this usually won't apply to all of your data because we might have good reason for needing to keep some of it. For example, so that we do not subsequently contact you if we receive your details again in the future.

Restriction: In certain circumstances you can ask us to restrict in which ways we use your personal data, such as while we are verifying whether the information is accurate. While the information is restricted, it can only be used for certain limited purposes such as bringing or defending legal claims, or protecting another person. It cannot be used or shared for ordinary purposes.

Portability: You have the right to receive limited types of information in a portable format.

If you are not happy you should make contact so that we can investigate your concerns. Please contact us using these details:
Post: 1 Ashway, Northleach, Cheltenham, Gloucestershire GL54 3PB
Email: privacy@121prodata.co.uk
Telephone: 01451 860805


You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO), which is the body that regulates the handling of personal data in the United Kingdom. You can do this online through the ICO’s website at www.ico.org.uk, by telephone on 0303 123 1113, or by writing to them at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF.

We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.

We will store all the personal information you provide on our secure (password and firewall-protected) servers.

Electronic financial transactions entered into through our website will be protected by encryption technology.

You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

You are responsible for keeping the password you use for accessing our website confidential; we will not ask you for your password (except when you log in to our website).