Privacy Policy

PRIVACY NOTICE

PLEASE READ THIS POLICY CAREFULLY. IF YOU DO NOT ACCEPT THESE TERMS, YOU ARE ADVISED NOT TO USE THE WEBSITE

This policy was last updated: 6th March 2019

Use of this website, www.purpletangerine.com, constitutes your legal agreement to the terms within this Privacy Policy and your acceptance of the policy is deemed to occur upon your first use of the website. 

Purple Tangerine may change this policy from time to time by updating this page. On each visit to the website you should refer to this page to ensure that you are aware of and accept any changes.

Policy Statement

Purple Tangerine recognises the trust you place in us when you share personal information with us. We are committed to being open, honest and transparent with our use of personal data.

This privacy policy provides you with details of the personal information we collect when we engage with you, how we will use and look after your personal information, your privacy rights and how the law protects you 

We will take all reasonable steps to ensure that personal information is safeguarded and kept in accordance with data protection law.

By providing us with your data, you warrant that you are over 13 years of age.

About Us

The Purple Tangerine Limited (“Purple Tangerine”) is registered in England and Wales under Company Registration Number 04048446. Our registered office address is at Forge House, The High Street, Charing, Kent TN27 0LS.

Our website at www.purpletangerine.com and sub sites including www.footballstudio.net and www.golf-studio.co.uk are designed to promote our marketing agency and consultancy services as well as well as marketing opportunities.

Where we manage personal data, we identify as a Data Controller and recognise and act on our obligations under applicable data protection law. For any issues relating to data protection the person responsible is Nigel Jones. You can contact him in relation to data protection matters by email to nigel@purpletangerine.com

What personal data do we collect?

Personal information is any information relating to an identified or identifiable individual.  It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal information about you when we engage with you. This will include:

Identity Data - title, first name, last name, job title, company name or similar identifier. If you interact with us through social media, this may include your social media user name;

Contact Data - billing address, delivery address, email address and telephone numbers;

Transaction Data - details about services you have purchased from us or we have purchased from you.

How do we collect personal data?

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

Our Contact Form

The Contact Form on our website is used to collect your name, email and phone number as well as your message, so that we can respond to your communications and provide details of our services and deal with general company enquiries. Data is held on the grounds of being legitimate to our business interests.

Emails

We retain copies of emails sent to us on our servers which are hosted by UK Hosting. Your personal information will be held by us in accordance with this Privacy Policy and will be on the basis of being legitimate to our business interests.

Telephone calls

Calls to us may be recorded and any data relating to the call may be retained by us. The data will be held on the basis of being for our legitimate business needs or in order to fulfil our contractual obligations if you are a client of ours.

Other direct interactions

You may give us your data by filling in forms or by corresponding with us face-to-face, by post, or through chat or social media. This includes personal data you provide when you: sign up to receive our free consultation; make enquiries or request information be sent to you; order our services; ask for information to be sent to you; engage with us on social media; enter a competition, promotion or survey; contact us direct; or leave comments or reviews on our services.

Social media

We use social media to engage with users and link to our Facebook, Twitter, and LinkedIn pages. We do not keep any specific data that identifies you as an individual user but hold details of our followers on these platforms. You should refer to the Privacy Policies of these channels to understand how they treat your data in relation to linking to our site.

Facebook:        https://www.facebook.com/privacy/explanation

LinkedIn:          https://www.linkedin.com/legal/privacy-policy

Twitter:             https://twitter.com/privacy

If you send us a direct message via social media, the details may be retained by us only as relevant to any ongoing contract or to further our legitimate business interests or as required for legal purposes. The third-party provider may also retain details in accordance with their Privacy Policy.

Testimonials

We may ask you for a testimonial in relation to our services that may be used on our website or social media. Your name and company may be used. Data is only published on the basis of valid consent obtained from you.

Visits to our website

When you visit our website we do not attempt to identify you as an individual user and we will not collect personal information about you unless you specifically provide this to us.

Special categories of data

We do not generally 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.

Children

We do not market this website at those under 18 years old. Consistent with the GDPR we will never knowingly request personally identifiable information from anyone under the age of 16 years old.

Information we get from other sources

From time to time, we may need to obtain information from third parties about you. This will only apply where it is necessary to provide our services and as permitted by law. 

We may receive personal data relating to: your identity and contact data from data partners; and data from any third parties who are permitted by law or have your permission to share your personal data with us, such as via social media or review sites. 

How do we use your data?

UK data protection law requires us to have a “legal basis” for processing personal data. The legal basis we rely on are: 

  • Performance of a contract we are about to enter into or have entered into with you;
  • Compliance with a legal or regulatory obligation;
  • Carrying out activities that are legitimate to our business interests;
  • Consent. However, generally, we shall not rely on consent as a legal basis for processing your personal data other than where the law requires it. Where our legal basis is consent, you have the right to withdraw consent any time.

We may use the information we collect from you in the following ways:

  • To administer and improve the website;
  • To personalise the content and user experience of the website;
  • To allow us to respond to communications;
  • To send email notifications which have been specifically requested;
  • To send marketing communications, where expressly agreed;
  • To provide third parties with statistical information about our users;
  • To ask for feedback or testimonials;
  • To deal with enquiries and complaints made by or about you relating to the website.

Users contacting this website and/or its owners do so at their own discretion and provide any such personal data requested at their own risk. Your personal information is kept private and stored securely until a time it is no longer required or has no use.

Our legitimate interests

When we use our legitimate interests as the legal basis for processing your personal information, we will consider and balance any potential impact on you and your rights before we process your personal data. We will only then proceed where we believe our interests are not overridden by the impact on you. Our legitimate interests include the management of our business operations.

Sharing information

Disclosure

We don’t share, sell, or distribute your data to third parties, except as contractually agreed with you or as provided in this Privacy Policy. We may disclose your personal information if we are required to do so by law, in connection with any legal proceedings, and in order to establish, exercise or defend our legal rights, or if otherwise legally permitted.

Client Status Reports

We may send some Clients status reports in relation to companies we have contacted on their behalf to see if they are interested in sponsorship or partnership marketing campaigns. Contact details are kept on an excel spreadsheet and include details of the company name, name and title of contact and a summary of the status.

Data Processors

We may use Data Processors who act on our instruction in relation to the management of your data and they must adhere to all data protection laws and regulations. We will ensure that any Data Processors used only operate on our written instructions and comply with their obligations under the GDPR. You will be informed of any other Data Controllers who have access to your data and who may determine processing activities separately to us, or as a Joint Data Controller. 

Marketing

We may carry out direct marketing by email, phone, text or post.

Our marketing databases are managed by third parties, salesforce.com and Campaign Monitor who will send email communications on our behalf only with your express consent. These third parties operate under a contractual agreement with Purple Tangerine and are not permitted to use your personal data for their own purposes. They act on our instructions which must comply with the obligations of data processors under the GDPR and Data Protection Act 2018. You can refer to their Privacy Policies at https://www.salesforce.com/products/marketing-cloud/sfmc/salesforce-dmp-privacy/ and https://www.campaignmonitor.com/policies/

You have the option not to give consent and to withdraw consent at any time from future marketing communications. You may withdraw your consent for us to contact you by emailing us at info@purpletangerine.com. We may continue to contact you if there is another lawful basis to do so.

Non-personally identifiable information may be provided to other third parties for marketing, advertising or other uses.

External links

Users of the website are advised to adopt a policy of caution before clicking on any external web links. Clicking an external link will take the user away from our website. Once you leave our website or are redirected to a third-party website, plug-in or application, you are no longer governed by this Privacy Policy or our website’s terms and conditions. We cannot guarantee or verify the contents of any externally linked website and users click on external links at their own risk. Purple Tangerine and its owners cannot be held liable for any damages, or the consequences of visiting any external links.

Social Media Platforms

Communication, engagement and actions taken through external social media platforms that this website and its owners participate on are subject to our terms and conditions as well as the privacy policies held with each social media platform respectively.

Users are advised to use social media platforms wisely and communicate and/or engage with them with due care and caution in regard to their own privacy and personal details. This website nor its owners will not ask for personal or sensitive information through social media platforms and encourage users wishing to discuss sensitive details to contact them through primary communication channels such as by telephone or email.

Purple Tangerine uses social sharing buttons which help share web content directly from web pages to the social media platform in question. Users are advised that before using such social sharing buttons, that they do so at their own discretion, and should consider that the social media platform may track and save requests to share a web page, through the users’ social media platform account.

Payment Processing

This website does not process customer payments for our services. Payments handled on our premises shall comply with the standard procedures and requirements as laid down by law to ensure that personal data is kept secure.

If we purchase products or services from you we will keep your account details you send us as part of your invoices on our files. A record of your account details will also be kept with our banking services provider.

Data Retention

We keep your personal information in accordance with our Data Retention Policy which reflects our needs to provide services to you as contracted and also as required to meet legal, statutory and regulatory obligations. The need to hold information is regularly reviewed and data will be disposed of when no longer required.

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, personal data is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such system and are required to keep the information confidential.

We take appropriate steps to ensure a safe processing of personal data, however, we cannot guarantee the security of data transmitted through our website or by email.  Any transmission is at your own risk.

Data Storage

Our website is hosted by UKhosting.co.uk. Any information that you supply to us may be stored and processed by our servers located in the UK. Your data may be transferred in accordance with the relevant data protection laws.

Rights of Data Subjects 

Purple Tangerine recognises a data subjects rights and will uphold these in accordance with data protection laws. You are entitled to see the information held about you and you may ask us about any of the following:

Subject access requests

Data subjects (i.e. individuals) have the right to access personal data that is held by submitting a subject access request (SAR) to Purple Tangerine. We will endeavour to respond quickly to any such requests, which legally require us to respond within one month of receiving the request and necessary information. A subject access request can be made by emailing us at info@purpletangerine.com

Right to rectification

Data subjects have the right to request that we amend or change personal information that is inaccurate or incorrect.

Right to erasure

Data subjects have the right to ask us to delete personal information from our systems without giving any reason and at any time. We will act on any such request without delay.

Right to restrict processing

Data subjects have the right to rectification or erasure of personal data in the following circumstances:

-        Personal data is not accurate;

-        The processing of data is unlawful - data subjects may request that processing is restricted;

-        Data is required to exercise legal rights or defend legal claims;

-        Data is unlawful but there may be lawful grounds for processing, which override this right.

Right to data portability

Data subjects have the right to obtain and request the transfer of their data to different service providers.

Right to object

Data subjects have the right to object to the processing of data at any time based on their particular situation. This includes objecting to profiling unless it is in the ‘public interest’ or exercised lawfully by an official authority. We will only process data under lawful grounds.

Right not to be subject to decisions based on automated processing

We do not use any automated processing that results in any automated decision based on a data subject’s personal information.

Using your rights

If you wish to invoke any of these rights, you should contact the person responsible for data protection by email to info@purpletangerine.com

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 fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

Data Breaches

We will report any unlawful breach of data as required by the GDPR within 72 hours of the breach occurring, if it is considered that there is an actual, or possibility, that data within our control including the control of our data processors, has been compromised. If the breach is classified as ‘high risk’ we will notify all data subjects concerned using an appropriate means of communication. We will report any relevant breaches to the ICO, see below.


Important Information

Questions and queries

If you have any concerns about how we handle your data, you can contact the Data Controller by email to info@purpletangerine.com

Changes to our Privacy Policy

We reserve the right to change this Privacy Policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the website.

You will be deemed to have accepted any changes to the terms of the privacy policy on your next visit of the website following the amendment.

Complaints

If you want to raise a concern about the use of your data, you can contact us by email to info@purpletangerine.com. Alternatively, you can formally raise a concern or complaint to the Information Commissioner’s Office (ICO) directly on 0303 123 1113, or see the options for reporting issues on https://ico.org.uk/concerns/


Legal Terms

No Waiver

No failure or delay by us in exercising any of our rights in accordance with this Privacy Policy or our terms and conditions shall be deemed to be a waiver of that right, and no waiver of a breach of any provision of the Agreement shall be deemed to be a waiver of any subsequent breach of the same or any other provision.

Severance

If one or more of the provisions of this Privacy Policy or our terms and conditions is found to be unlawful, invalid or otherwise unenforceable, those provision(s) shall be deemed severed from the remainder of these terms and conditions and shall remain enforceable.

Third Party Rights

The terms of this Privacy Policy shall not confer rights on any third parties and accordingly the Contracts (Rights of Third Parties) Act shall not apply.

Jurisdiction and Governing Law

The terms of this Privacy Policy and all disputes, whether contractual or otherwise, arising out of or in connection with the policy are governed by and shall be construed in accordance with the laws of England and Wales and each party submits to the exclusive jurisdiction of the English courts.

 

Copyright © 2019 Purple Tangerine Limited

About Us

Established in 2000, Purple Tangerine is a leading independent global team of marketing specialists.

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