About this Privacy Notice:
Network understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our Partners and their employees and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
This Privacy Notice was last updated in June 2022.
- Information About Us
Network Digital Marketing Limited (Network) is registered in England under company number 04009390.
Registered address: Unit 3 First Floor Glass House Business Park, Glass House Road, Wigan, Lancashire, England, WN3 6GL.
We have a Data Protection Officer whose email address is: [email protected]
- What Does This Notice Cover?
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
- What Is Personal Data?
Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in section 5, below.
- What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold. For more information about our use of your personal data or to exercise these rights, contact our Data Protection Officer at [email protected]:
- The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions.
- The right to access the personal data we hold about you. If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request.” There is not normally any charge for a subject access request, however if your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding. We will respond to your subject access request as soon as is reasonably possible and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete.
- The right to be forgotten, i.e., the right to ask us to delete or otherwise dispose of any of your personal data that we hold
- The right to restrict (i.e., prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to withdraw consent. This means that, if we arerelying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
- The right to access the personal data we hold about you. If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request.” There is not normally any charge for a subject access request, however if your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding. We will respond to your subject access request as soon as is reasonably possible and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
It is important that your personal data is kept accurate and up to date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first at [email protected].
- What Personal Data Do You Collect and How?
We may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. We do not collect any ‘special category,’ ‘sensitive’ personal data, any personal data relating to children nor anydata relating to criminal convictions or offences.
| Data Collected | How We Collect the Data |
| Identity Information including name, title, job title. | We will collect this data from you directly or from public sources or third parties. |
| Contact information including business address, business email address, business telephone number. | We will collect this data from you directly or from public sources or third parties. |
| Business information including business name, business address, company number. | We will collect this data from you directly or from public sources or third parties. |
| Payment information including card details and bank account numbers. | We will collect this data from you directly. |
- How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how wemay use your personal data, and our lawful bases [A1] [A2] [A3] for doing so:
| What We Do | What Data We Use | Our Lawful Basis |
| Administering ourbusiness. | Identity Information, Contact Information, Business Information. | Legitimate Interests – to ensure our business runs efficiently. |
| Obtainingproducts or services from you. | Identity Information, Contact Information, Business Information, Payment Information. | Performance of a Contract. |
| Managing payments for your products or services. | Identity Information, Contact Information, Business Information, Payment Information. | Performance of a Contract. |
| Communicating with you. | Identity Information, Contact Information, Business Information. | Legitimate Interests – to ensure our business runs efficiently. |
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
- How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected, and not for longer than 12 months after you cease to be a partner or prospective partner of Network, or as required to meet legal and regulatory requirements.
- How and Where Do You Store or Transfer My Personal Data?
We will usually only store your personal datain the UK or the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the EU GDPR and/or to equivalent standards by law. Transfers of personal data to the EEA from the UK are permitted without additional safeguards.
We, or our trusted suppliers, may store some of your personal data in countries outside of the UK or EEA. These are known as “third countries.” We will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:
We will only store or transfer personal data in or to countries that are deemed to provide an adequate level of protection for personal data. For further information about adequacy decisions and adequacy regulations, please refer to the Information Commissioner’s Office.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
- limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
- having procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so.
Our trusted suppliers who we share data with include[A4] :
- Bloomreach Ltd – to create and send email communications to Partners.
- Zoho – to manage Partner relationships.
- Sage – to manage invoices and payments.
- Stripe – we use Stripe for payment services. Stripe collects and processes personal data, including identifying information about the devices that connect to its services. Stripe uses this information to operate and improve the services it provides to us, including for fraud detection and prevention. You can learn more about Stripe and its processing activities via privacy policy at https://stripe.com/privacy.
- Creditsafe – to perform basic credit checks and verify company details.
- Google Analytics – providing information which helps us understand how people are using our website.
- Kentico Kontent – powers our Partner Portal where you might add offers to our site.
- HM Revenue and Customs – financial records as required by law.
- Do You Share My Personal Data?
We will not share any of your personal data with any third parties, other than our trusted suppliers, for any purposes, subject to the following exceptions.
If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same ways that we have used it, as specified in this Privacy Notice.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
We may share your personal data with other companies in our group for business administration purposes. This includes any holding company or its subsidiaries or our own subsidiaries.
If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in sections 4 and 8.
If any personal data is transferred outside of the UK/EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in section 8.
If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same ways that we have used it, as specified in this Privacy Notice.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
- Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
[A1]Bases or basis?
I think bases is correct in this context as the “What We Do” column are the “Bases” but just double checking.
[A2]I’ve checked, and bases is the plural of basis
[A4]Changed list to be bulleted just to be a bit clearer.