1.1 We are Radiate B2B Limited, a company registered in England and Wales under company number 10704141 with registered address Launch Lab At Franklin Building, 124 Goswell Road, London, England, EC1V 7DP. We take the privacy of your information very seriously. Our Privacy Notice is designed to tell you, the user of our services about our practices regarding the collection, use and disclosure of personal information which may be provided to us via our website, associated apps and other digital products we provide or collected through other means such as an online form, email, or telephone communication.
1.2 In general, our services relate to the provision of advertisement services to users by managing clients’ marketing campaigns to identify and target companies. More information on the different offerings we provide is available on our website.
1.3 This notice applies to personal data:
1) provided by our clients (which may include the organisation who has subscribed to our software service and for whom you work) or our prospective clients and their staff;
2) provided by you (for instance whether you are an end-user to the services or simply visiting the Radiate B2B website; and
3) collected directly by us through publicly available information, but this notice does not apply to information we hold in relation to our employees and staff. In this notice “you” refers to any individual whose personal data we hold or process (other than our staff).
1.4 In this notice references to the “Platform” are references to any website, app or other means by which you provide personal data to us or access our services.
1.5 This privacy notice is governed by the EU General Data Protection Regulation (the “GDPR”), the retained EU law version of the GDPR (“UK GDPR”), the Data Protection Act 2018 and any other applicable data or privacy legislation. This notice may be updated from time to time and you should check this page regularly for any updates. Changes to this notice are effective when they are posted on this page.
2. Personal data we collect
2.1 Below we have set out the categories of personal data (information that can be uniquely identified with you) we may collect and process about you, the legal basis we rely on to process the data and how we may process the data:
2.1.1 Contact information of our users who have registered with us or whose details have been passed to us on behalf of their employer or organisation for whom they work (you may for example be a client who has subscribed to our services or an end-user of the services). Contact information may include your name, surname, company name, job title/role, email address, telephone number and address (“Contact Information”).
We process this information to provide our services and communicate with you (including with respect to customer care and support) on the basis of performing our contract with you or on the basis of our legitimate interest in providing our services to you.
2.1.2 Information which we hold because you are a client of ours (“Client Information”) and which we process during the course of providing our services to you.
We process this information on the basis of the performance of our contract with you or on the basis of our legitimate interest in providing our services to you.
2.1.3 Financial information which we hold in the context of providing/receiving services from you (“Financial Information”) such as billing and banking information.
We process this information when we provide or receive services (as the case may be) on the basis of the performance of our contract with you or on the basis of our legitimate interest in providing our services to you.
2.1.4 Technical Information in the form of cookies and IP addresses. A cookie is a small text file which asks permission to be placed on your computer’s hard drive or mobile device. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site.
Where applicable and necessary, we process Technical Information on the basis that you have consented to this in order to improve or communicate with you about our services and/or to customise the website according to your personal interests, or on the basis of our legitimate interest in providing our services to you. For more information, please see the “Cookies and IP Address” section below.
If you are a client of ours and you provide us with a list of company / domain names, we may share this with a technical provider in order for them to generate a list of IP addresses relating to that company / domain. We then use this generated information for targeted advertising purposes, as part of our overall provision of services to you. Alternatively, we may share an IP address with the technical provider to generate a domain name linked to that IP address. This information would also be used for targeted advertising purposes. In these circumstances, we process this information on the basis of the performance of our contract with you or on the basis of our legitimate interest in providing our services to you.
2.1.5 Marketing information. We may hold information about you in order to provide information about our services. This may include names, job titles, email addresses, phone numbers, addresses, and other information (“Marketing Information”).
We process this information in order to improve our services, communicate with you about our services or for market research purposes, on the basis of our legitimate interests in communicating with you about our services or on the basis that you have consented to receiving the information.
2.2 We will not collect any sensitive personal data without your prior consent. By sensitive personal data we mean data which falls within certain ‘special categories’ which are defined in the GDPR/UK GDPR (e.g. health data) and which require additional protection and consent measures.
2.3 We generally collect information from you directly however we may also collect certain information from the organisation for whom you work (such as your contact information and job title/role) or other third party. If we obtain your personal data from a third party, your privacy rights under this notice are not affected and you are still able to exercise the rights contained within this privacy notice.
3. Cookies and IP Address
3.3 Once you close your browser, our access to the cookie terminates. You have the ability 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. To change your browse settings you should go to your advanced preferences.
3.4 If you choose not to accept the cookies, this will not affect your access to the majority of information available on our Platform. However, you will not be able to make full use of our online services.
3.5 You can find more information about the cookies we currently use here.
3.6 An Internet Protocol (IP) address is a number assigned to your computer by your Internet Service Provider (ISP), so you can access the Internet. We may use your IP address to diagnose problems with our server, report aggregate information, and determine the fastest route for your computer to use in connecting to our Platform, and to administer and improve the Platform. We may also use IP addresses for targeted advertising as specified in clause 2.1.4 above.
4. Data Retention
4.1 Our current data retention policy is to delete or destroy (to the extent we are able to) the personal data we hold about you after the following periods:
4.1.1 In respect of records relating to a contract with us – 7 years from either the end of the contract or the date you last used our services (whichever is later).
4.1.2 In respect of Technical Information – such data is removed after a date set by the client or 2 years (whichever is later). After such period, only aggregated data (from which all personal data has been removed) is stored by us.
4.1.3 In respect of Marketing Information – 7 years from the last date on which you have interacted with us.
4.2 For any category of personal data not specifically defined in this notice, and unless otherwise specified by applicable law, the required retention period for any personal data will be deemed to be 7 years from the date of receipt by us of that data or (if later) the end of the relevant contract, arrangement or interaction with that person.
4.3 The retention periods stated in this notice can be prolonged or shortened as may be required (for example, in the event that legal proceedings apply to the data or if there is an ongoing investigation into the data).
4.4 We review the personal data (and the categories of personal data) we are holding on a regular basis to ensure the data we are holding is still relevant to our business and is accurate. If we discover that certain data we are holding is no longer necessary or accurate, we will take reasonable steps to correct or delete this data as may be required.
4.5 If you wish to request that data we hold about you is amended or deleted, please see clause 8 below, which explains your privacy rights.
5. Sharing your information
5.1 We may disclose information to third parties in the following circumstances:
5.1.1 We may work with other professionals and providers in providing and delivering our services to you, such as Hubspot, Xero, AWS (hosted in Frankfurt), Zoho Campaigns, Tidio, LinkedIn, Facebook, and Adform and other service technology providers. AWS, Hubspot, Xero, LinkedIn, Facebook and Adform are based in the United States.
5.1.2 In order to enforce any terms and conditions or agreements for our services that may apply.
5.1.3 Where we carry out research to gain an insight into the use of our services, the results of this research (but not your personal data itself) may be transferred to interested third parties.
5.1.4 If we are subcontracting services to a third party we may provide information to that third party in order to provide the relevant services.
5.1.5 We may disclose information to our group companies (as the case may be).
5.1.6 If we are under a duty to disclose or share your personal data in order to comply with any legal obligation (for example, if required to do so by a court order or for the purposes of prevention of fraud or other crime).
5.1.7 If we are under a duty to disclose or share your personal data in order to comply with any legal obligation (for example, if required to do so by a court order or for the purposes of prevention of fraud or other crime).
5.1.8 We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation, but we will take steps with the aim of ensuring that your privacy rights continue to be protected.
5.1.9 To protect our rights, property and safety, or the rights, property and safety of our users or any other third parties. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
5.2 Other than as set out above, we shall not disclose any of your personal information unless you give us permission to do so. If we do supply your personal information to a third party we will take steps to ensure that your privacy rights are protected and that third party complies with the terms of this notice.
6.1 We will take all reasonable steps to ensure that appropriate technical and organisational measures are carried out in order to safeguard the information we collect from you and protect against unlawful access and accidental loss or damage. These measures may include (as necessary):
6.1.1 protecting our servers by both hardware and software firewalls;
6.1.2 locating our data processing storage facilities in secure locations;
6.1.3 encrypting all data stored on our server with an industry standard encryption method that encrypts the data between your computer and our server so that in the event of your network being insecure no data is passed in a format that could easily be deciphered;
6.1.4 ensuring that all communication with our servers is encrypted through Secure Sockets Layer (SSL), an industry standard encryption method that encrypts data between your computer and our servers so that in the event of your network being insecure no data is passed in a format that could easily be deciphered;
6.1.5 when necessary, disposing of or deleting your data so it is done so securely;
6.1.6 regularly backing up and encrypting all data we hold.
6.2 We will ensure that our employees are aware of their privacy and data security obligations. We will take reasonable steps to ensure that the employees of third parties working on our behalf are aware of their privacy and data security obligations.
6.3 This notice and our procedures for handling personal data will be reviewed as necessary.
7. Your privacy rights
7.1 The GDPR/UK GDPR gives you the following rights in respect of personal data we hold about you:
The right to be informed You have a right to know about our personal data protection and data processing activities, details of which are contained in this notice.
The right of access You can make what is known as a Subject Access Request (“SAR”) to request information about the personal data we hold about you (free of charge, save for reasonable expenses for repeat requests). If you wish to make a SAR please contact us as described below.
The right to correction Please inform us if information we hold about you is incomplete or inaccurate in any way and we will update our records as soon as possible, but in any event within one month.
We will take reasonable steps to communicate the change to any third parties to whom we have passed the same information.
The right to erasure (the ‘right to be forgotten’) Please notify us if you no longer wish us to hold personal data about you (although in practice it is not possible to provide our services without holding your personal data). Unless we have reasonable grounds to refuse the erasure, on receipt of such a request we will securely delete the personal data in question within one month. The data may continue to exist in certain backup, but we will take steps to ensure that it will not be accessible.
We will communicate the erasure to any third parties to whom we have passed the same information.
The right to restrict processing You can request that we no longer process your personal data in certain ways, whilst not requiring us to delete the same data.
The right to data portability You have right to receive copies of personal data we hold about you in a commonly used and easily storable format (please let us know a format which suits you). You may also request that we transfer your personal data directly to third party (where technically possible).
The right to object Unless we have overriding legitimate grounds for such processing, you may object to us using your personal data if you feel your fundamental rights and freedoms are impacted. You may also object if we use your personal data for direct marketing purposes (including profiling) or for research or statistical purposes. Please notify your objection to us and we will gladly cease such processing, unless we have overriding legitimate grounds.
Rights with respect to automated decision-making and profiling You have a right not to be subject to automated decision-making (including profiling) when those decisions have a legal (or similarly significant effect) on you. You are not entitled to this right when the automated processing is necessary for us to perform our obligations under a contract with you, it is permitted by law, or if you have given your explicit consent.
Notwithstanding the above, we only process this information at a departmental level within a company and not in a way that impacts individuals.
Right to withdraw consent If we are relying on your consent as the basis on which we are processing your personal data, you have the right to withdraw your consent at any time. Even if you have not expressly given your consent to our processing, you also have the right to object (see above).
7.2 All SARs and other requests or notifications in respect of your above rights must be sent to us in writing to Riaz Kanani at: [email protected].
7.3 We will endeavour to comply with such requests as soon as possible but in any event we will comply within one month of receipt (unless a longer period of time to respond is reasonable by virtue of the complexity or number of your requests).
8. Data Breaches
8.1 If personal data we hold about you is subject to a breach or unauthorised disclosure or access, we will report this to our data protection manager or officer (if an officer has been appointed) and the Information Commissioner’s Office (ICO) (as necessary).
8.2 If a breach is likely to result in a risk to your data rights and freedoms, we will notify you as soon as possible.
9. Other websites
9.1 Our Platform may contain links and references to other websites. Please be aware that this notice does not apply to those websites.
9.2 We cannot be responsible for the privacy policies and practices of sites that are not operated by us, even if you access them via the Platform. We recommend that you check the policy of each site you visit and contact its owner or operator if you have any concerns or questions.
9.3 In addition, if you came to this Platform via a third party site, we cannot be responsible for the privacy policies and practices of the owners or operators of that third party site and recommend that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.
10. Transferring your information outside the UK or EEA
10.1 We will not transfer your personal data in a systematic way outside of the UK or European Economic Area (“EEA”) but there may be circumstances in which certain personal data is transferred outside of the UK or EEA, in particular:
10.1.1 From time to time, some of our data processors (including third party payment processors or server providers), may be based outside of the UK or EEA. In that case, we will ensure we have an agreement in place with such processors to provide adequate safeguards and a copy of such safeguards will be available on request.
10.1.2 If you use our services while you are outside the UK or EEA, your information may be transferred outside the UK or EEA in order to provide you with our services or communicate with you.
10.1.3 We may communicate with individuals or organisations outside of the UK or EEA in providing our services. Those communications may include personal data (such as contact information).
10.1.4 From time to time your information may be stored in devices which are used by our staff outside of the UK or EEA (but staff will be subject to our cyber-security policies).
10.2 If we transfer your information outside of the UK or EEA, and the third country or international organisation in question has not been deemed by the Secretary of State or EU Commission (as the case may be) to have adequate data protection laws, we will provide appropriate safeguards and we will be responsible for ensuring your privacy rights continue to be protected as outlined in this notice.
11. Notification of changes to the contents of this notice
We will post details of any changes to our policy on the Platform to help ensure you are always aware of the information we collect, how we use it, and in what circumstances, if any, we share it with other parties.
12. Contact us
If at any time you would like to contact us with your views about our privacy practices, or with any enquiry or complaint relating to your personal information or how it is handled, you can do so via the following email address: [email protected].
If we are unable to resolve any issues you may have or you would like to make a further complaint, you can contact the Information Commissioner’s Office by visiting http://www.ico.org.uk/ for further assistance.