Last updated April 10, 2021
We are Actve Ltd (“Actve”) (“we”, “us”, “our”), and are committed to protecting your personal information and your right to privacy.
Actve Ltd is the controller for the purposes of the General Data Protection Regulation (the “GDPR”) and the Data Protection Act 2018. Actve is a company registered in England and Wales (Company No. 12537851), with its registered office located at International House, 64 Nile Street, London N1 7SR, United Kingdom.
Data subject or “you” or “your”:
A data subject is an “identifiable natural living person who can be directly or indirectly identified in particular by reference to an identifier”. “Identifier” covers almost any information that we might have that could identify you as an individual. It also means that data subjects include employees/associates/ individual customers or individuals within customer organisations – any individual that our organisation holds personal data on.
This is any information or data relating to a data subject that can be used to identify them or is information relating to them which makes that data personal to the data subject. So, this will include names, addresses, other contact details, date of birth, driver’s license, CCTV, emails, online identifiers (provided by their devices, applications and tools such as IP addresses, cookie identifiers etc.).
A data controller determines the purposes and means of how your personal data is processed.
A data processor is any person other than an employee of the data controller who processes the data on behalf of the data controller.
Data processing covers just about anything that we do with your personal data including both automated electronic processing and manual processing within a structured filling system including collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
This Notice provides details about:
- What information we collect
- How we use your information
- Who your information will be shared with
- How long we will keep your information
- How we keep your information safe
- Your privacy rights
- Updates to this policy
- How to contact us about this policy
1. WHAT INFORMATION WE COLLECT
When you interact with us, whether by using our Website or communicating with us, we may collect the following information about you:
information you give us: if you sign up for an account on our Website, complete any online forms (such as registration forms, competitions, and surveys), opt in to receive our newsletters and special offers, enter a competition or promotion, participate in social media functions with our Website, or correspond with us (by email, telephone, social media or otherwise).
Depending on what you provide, this information could include your first and last name, email address, postal code, phone number, and other similar contact data. When you sign up for an account, we collect passwords, password hints and similar security information used for authentication and account access.
We can collect other publicly available personal data, including any which you have shared via a public platform (such as Instagram, Twitter, YouTube, LinkedIn, or public Facebook page).
Information automatically collected: each time you visit the Site, certain information such as IP address and/or browser and device characteristics will be collected automatically.
Like many businesses, we collect information through cookies and similar technologies. This can help improve your experience with the Site and make it easier to interact with us. This may include storing your location or language preferences to save you having to re-enter information when returning to, or ensuring that items you wish to order don’t disappear as you navigate between pages on our Site.
Information collected from other sources: We may collect limited data from public databases, marketing partners, and other outside sources. By logging in, you are giving us permission to obtain certain information and content.
2. HOW WE USE YOUR INFORMATION
We process your information for purposes based on legitimate business interests, the fulfilment of our contract with you, compliance with our legal obligations, and/or your consent which you can withdraw at any time.
We use personal information collected via our Sites for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests (“Business Purposes”), in order to enter into or perform a contract with you (“Contractual”), with your consent (“Consent”), and/or for compliance with our legal obligations (“Legal Reasons”). We indicate the specific processing grounds we rely on next to each purpose listed below.
We also use the information for marketing and advertising purposes. Where you have told us you would like to receive marketing communications, we and our Partners will use your personal information (including your name, email address and address) to occasionally send you updates, news, and offers via email, post, or other forms of media. We may use your information (including supplemental information received from partners that we append to our existing customer information as described below), to tailor these messages to you. You may unsubscribe from our email marketing communications by modifying your preferences in your account’s profile management section, or by following the opt out instructions in the promotional emails that are sent to you.
We use the information we collect or receive:
To register and manage your account in our website: If you choose to link your account with us to a third party account *(such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process.
To send administrative information to you: We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
Deliver targeted advertising to you. We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.
To protect our Sites. We may use your information as part of our efforts to keep our Sites safe and secure (for example, for fraud monitoring and prevention).
To enforce our terms, conditions and policies.
To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Sites, products, services, marketing and your experience.
3. WHO YOUR INFORMATION WILL BE SHARED WITH
We only share information with your consent, to comply with laws, to protect your rights, or to fulfil business obligations.
We may process or share data based on the following legal basis:
To comply with legal requests: on occasion we may be required to liaise with various regulators and law enforcement agencies in a number of different countries, whether as a result of law, a court order, or another legal process. Although we dispute requests wherever suitable, in some cases we may have to share your information with the regulators or law enforcement agencies. Where we consider it appropriate, and provided we are not prohibited from doing so by law or court order, we will attempt to notify you of these legal demands.
To aggregate information with third parties: we may aggregate your information with the information of other customers, creating a dataset of information about the usage of our Website, and other general, grouped information about our customers on the basis of our legitimate interest to understand the usage of our service and demand for our product. Although this dataset is aggregated and anonymised, meaning it cannot identify you as an individual, it provides a valuable insight into the use of our Site and we may therefore share it with select third parties. These parties may include providers of plugins or similar technologies to help measure traffic, our Partners and other providers to allow them to better stock products, and our investors.
Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Sites, which will enable them to collect data about how you interact with the Sites over time. This information may be used to, among other things, analyse and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
To provide the Site and our services, we work with a number of carefully selected third parties. To do this, we may share your information with the following third parties. We have categorised each party so that you may be easily understand the purpose of our data collection and processing practices. If we have processed your data based on your consent and you wish to revoke your consent, please contact us.
Advertising, Direct Marketing, and Lead Generation:
Social Media Sharing and Advertising:
Please note that refusing cookies does not mean you will no longer receive online advertising. It does mean that the company or companies from which you opted out will no longer deliver adverts tailored to your web preferences and usage patterns, so you may see a greater number of adverts that are irrelevant to you and your preferences.
5. HOW LONG WE WILL KEEP YOUR INFORMATION
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
It is important to ensure that the personal data we hold about you is accurate and up-to-date, and you should let us know if anything changes. You can contact us by using the details set out in the “Contact us” section below.
6. HOW WE KEEP YOUR INFORMATION SAFE
Actve is committed to keeping your personal data safe and secure and so we have numerous security measures in place to protect the loss, misuse and alteration of information under our control. However, please also remember that we cannot guarantee that the internet itself is 100% secure. You should only access the services within a secure environment.
We take a number of reasonable steps to try to protect the personal information that you provide, including:
Encryption of personal data;
Regular cyber security assessments of all service providers who may handle your personal data
7. YOUR PRIVACY RIGHTS
In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.
Under the GDPR and Data Protection Act 2018, you have the following rights in relation to your personal data, which we will always aim to uphold:
The right to be informed about how we collect and use your personal data – this Privacy Notice should tell you everything that you need to know but if you have any further questions then please contact us using the contact details below;
The right of access to your personal data and the right to verify the lawfulness of the processing;
The right to have your personal data rectified to correct inaccurate information or to have it completed if it is incomplete – please contact us using the contact details below;
The right to erasure of your personal data – sometimes known as “the right to be forgotten”. That is the right to have us delete or otherwise dispose of any of your personal data – please contact us using the contact details below;
The right to restrict the processing of your personal data;
The right to data portability so that they can take and use their personal data for their own purposes across different services;
The right to object to use processing your data on for a particular purpose or purposes;
Rights concerning automated decision making and profiling.
You should note that some of these rights, for example the right to require us to transfer your data to another service provider or the right to object to automated decision making, may not apply as they have specific requirements and exemptions which apply to them and they may not apply to personal data recorded and stored by us. However, some have no conditions attached, so your right to withdraw consent or object to processing for direct marketing are absolute rights.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
Whilst this Notice sets out a general summary of your legal rights in respect of personal data, this is a very complex area of law. More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-public/.
If you wish to exercise any of the above rights, you can always contact us using the details set out in the ‘Contact Us‘ section below.
8. UPDATES TO THIS POLICY
9. HOW TO CONTACT US ABOUT THIS POLICY
If you have questions or comments about this policy, you may email us at firstname.lastname@example.org or by post to:
64 Nile Street
London, N1 7SR