Privacy Policy

BluSky Marketing Privacy Policy 2018

This is privacy notice of BluSky Marketing Limited.

BluSky Marketing Limited (“us”, “we”, or “our”) operates the http://www.bluskymarketing.com website, salary survey programmes, hotel guest experience surveys, employee engagement surveys and event management services (the “Service”).  In regards to Blue Sky Wildlife, the digital wildlife trading name of BluSky Marketing Limited, please refer to the specific Blue Sky Wildlife privacy policy here.

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy.

We respect your privacy and are determined to protect your personal data. The purpose of this privacy notice is to inform you as to how we look after your personal data when you use our Services (regardless of where you visit it from). We will also tell you about your privacy rights and how the data protection law protects you.

This privacy notice is provided in a structured format so you can view the specific areas set out below.

  1. WHO WE ARE AND IMPORTANT INFORMATION
  2. THE PERSONAL DATA WE COLLECT ABOUT YOU
  3. HOW WE COLLECT YOUR PERSONAL DATA
  4. HOW WE USE YOUR PERSONAL DATA
  5. WHO WE SHARE YOUR PERSONAL DATA WITH
  6. INTERNATIONAL TRANSFERS
  7. DATA SECURITY
  8. DATA RETENTION
  9. YOUR LEGAL RIGHTS
  10. Changes to this notice and your duty to inform us of changes
  11. QUERIES, REQUESTS OR CONCERNS

  

  1. WHO WE ARE AND IMPORTANT INFORMATION 

What is the purpose of this privacy notice?

This privacy notice aims to give you information on how we collect and process your personal data through the use of our Services, including any data you may provide through this website when you http://www.bluskymarketing.com/contact-us.

Our Services are not intended for children and we do not knowingly collect data relating to children.

You must read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Data controller(s)

BluSky Marketing Limited is a) processor and b) controller responsible for your personal data (collectively referred to as BluSky Marketing Limited, “we”, “us” or “our” in this privacy notice). Our contact details are Suite 17, Unit 16A, Oakham Enterprise Park, Ashwell Road, Oakham, Rutland, LE15 7TU, United Kingdom.  Phone: +44 (0)1572 420 012 or email hello[at]bluskymarketing[dot]com.

For all data matters contact Chris Larsen, Data Protection Officer via email hello[at]bluskymarketing[dot]com or call +44(0) 1572 420 012.

BluSky Marketing Limited is the processor and controller responsible for this website.

Third-party links outside of our control

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.

When you leave our website, we encourage you to read the privacy notice of every website you visit.

  1. THE PERSONAL DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioners Office.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  • Identity Data includes first name, last name, username, title, date of birth, gender
  • Contact Data includes email address, telephone numbers, billing address
  • We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from personal data but is not considered personal data in the law as this data does not directly or indirectly reveal your identity.  For example responses to salary survey and/or employee engagement programmes only provide aggregated data with statistical responses below 10 not available to be viewed by our clients.  Responses to our hotel guest experience survey provide aggregated data and personal data available to be view by our hotel client.  The hotel client sends out the invitation to respond to the hotel guest experience survey as an invitation to respond.  However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect your personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

  1. HOW WE COLLECT YOUR PERSONAL DATA

We use different methods to collect data from and about you including through:

  • You may give us your identity, contact and financial data by responding to surveys, filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • Apply for our products or services;
    • Subscribe to our service or publications;
    • Request marketing collateral to be sent to you;
    • Respond to a hotel guest experience survey, employee engagement survey and/or salary survey.
  • Third parties or publicly available sources. We may receive personal data about you from various public sources as set out below:

(a) Search information regarding exhibitors at the British Birdwatching Fair (based inside the EU) via their website http://birdfair.org.uk/exhibit/

  1. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Performance of Contract thismeans processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
  • Legitimate Interest this means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting our Data Protection Officer.
  • Comply with a legal or regulatory obligation this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Generally we do rely on consent as a legal basis for processing your personal data.  We do not send any personal data to third party direct marketing communications who contact you via email or text message.  You have the right to withdraw consent to marketing at any time by contacting our Data Protection Officer.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, with the legal bases we rely on to do so.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact our Data Protection Officer if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer (a) Identity

(b) Contact

Performance of a contract with you
To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

Necessary for our legitimate interests (to develop our products/services and grow our business for example Birdfair exhibitors)
Participation in a hotel guest experience survey, salary survey and/or employee engagement survey (a) Identity

(b) Contact

Necessary for our legitimate interests (invitation and consent to participate in a hotel guest experience survey, salary survey and/or employee engagement survey)

 

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

You may receive marketing communications from us from time to time if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We do not participate in third-party marketing activities nor do we sell your personal data to any third parties.  Please note our clients who engage our services do have access to your personal data (e.g. hotel guest experience surveys) and you would only be contact by them if you have consented to receive further information from them.

Opting out

You can ask us to stop sending you marketing messages at any time by contact our Data Protection Officer who will remove you from the relevant database and/or if you receive an email campaign use the unsubscribe button at the bottom of that email.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies please contact our Data Protection Officer.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact our Data Protection Officer.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

  1. WHO WE SHARE YOUR PERSONAL DATA WITH

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

  1. INTERNATIONAL TRANSFERS

Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by implementing safeguards:

Please contact us http://www.bluskymarketing.com/contact-us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

  1. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

  1. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers including contact, identity, financial and transaction data for six (6) years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see Your legal rights below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

  1. YOUR LEGAL RIGHTS

Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data:

  • The right to request a copy of the personal data which we hold about you;
  • The right to request that we correct any personal data if it is found to be inaccurate or out of date;
  • The right to request your personal data is erased where it is no longer necessary to retain such data;
  • The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data;
  • The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), where applicable i.e. where our processing is based on consent or is necessary for the performance of our contract with you or where we process your data by automated means);
  • The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
  • The right to object to our processing of personal data, where applicable i.e. where processing is based on our legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct marketing or processing for the purposes of scientific/historical research and statistics).

If you wish to exercise any of the rights set out above, please our Data Protection Officer.

No fee required – with some exceptions

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

  1. Changes to this notice and your duty to inform us of changes

This version was last updated on 14th May 2018 and historic versions are can be obtained by contacting our Data Protection Officer.

From 25th May 2018 there will be changes in Data Protection laws and will then be able to respond to some of your requests (for example how data is used within a hotel guest experience survey).  We are still working towards getting our systems ready for some of these changes.

Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.

  1. Queries, requests or concerns

To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact our Data Protection Officer via http://www.bluskymarketing.com/contact-us.

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England, UK.