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First Rate Marketing Ltd (“First Rate”, “Company”, “we”, “us” “our”) takes its data privacy obligations seriously and cares about protecting the information of all the people and companies we deal with, including customers (“User”, “you”), staff and suppliers.
First Rate is a private limited company, with company number 11934962, at registered address office 12 Floor, Broadgate Tower, 20 Primrose St, London EC2A 2EW.
Please read this Policy carefully, as it will help you understand what we do with the Personal Information we collect on you.
1. Collecting Personal Information Data
“Personal Information” refers to information about you that identifies you and reveals your identity.
We may collect Personal Information from Users in a variety of ways, including, but not limited to:
- Users visiting the Site and filling out the ‘Contact’ form;
- Subscribing to our newsletter;
- Holding records and copies of your correspondence, if you contact us.
Users can always refuse to supply Personal Information but must be aware that in certain circumstances, this may prevent them from engaging in certain Site related activities.
2. Collecting Non-Personally Identifiable Information
We may collect certain non-personally identifying information about Users when they interact with our Site. Users cannot be identified from this type of information. Non-Personally identifying Information we may collect includes:
- Browser name;
- Internet Protocol (IP) addresses;
- Operating system;
- Language preferences.
This information is collected automatically when Users visit our Site.
3. How We Use Your Personal Information
We will only use your Personal Information when legally permitted. The most common uses of your Personal Information are:
- Where we need to perform the contract between us;
- Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests;
- Where we need to comply with a legal or regulatory obligation.
We sometimes require your Personal Information to understand your needs and provide a better service to you. Some of the instances where this use of your Personal Information may apply include:
- To provide and maintain our services;
- To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication,
- To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about, unless you have opted not to receive such information;
- To prevent fraud or abuse.
4. Disclosure of Your Personal Information
We do not sell, trade, or rent Users Personal Information to others. We may share generic aggregated demographic information not linked to any personal identification.
We make use of some sub-processors who are given access to some of the Personal Information you provide in order to facilitate the service we provide through the Site. Sub-processors are subject to confidentiality obligations and data privacy requirements in their service agreements.
4.2 Legal requirements
The Company may disclose Your Personal Information in the good faith belief that such action is necessary to:
- Comply with a legal obligation;
- Protect and defend the rights or property of the Company;
- Prevent or investigate possible wrongdoing in connection with the service(s);
- Protect the personal safety of Users of the Site;
- Protect against legal liability.
5. Protecting Your Personal Information
We adopt appropriate data collection, storage and processing practices, technical and organisational security measures to protect against unauthorised access, alteration, disclosure or destruction of your Personal Information.
Our Site is secured using an SSL which is an encrypted based internet security protocol to ensure User’s Personal Information is safe and secure. A backend virus protection is also set up on the Site that verifies logins to the backend of the website and prevents malicious attacks.
6. Retention Periods of Your Personal Information
The Company will retain your Personal Information only for as long as is necessary to carry out the purposes set out in this Policy. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
7. Legal Basis For Processing Personal Information Under GDPR
We may process Personal Information under the following conditions:
- Consent: You have given Your consent for processing Personal Information for one or more specific purposes.
- Performance of a contract: Provision of Personal Information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof.
8. Rights Under GDPR
You have a number of rights under applicable data protection legislation.
Under the GDPR, you have the right to ‘block’ or request the deletion or removal of Personal Information to prevent further processing. This right to erasure is also known as ‘the right to be forgotten’.
Specific circumstances in which you can request the deletion or removal of Personal Information includes:
- Where the Personal Information is no longer necessary for the purposes for which it is collected or otherwise processed;
- When you have withdrawn your consent;
- When you object to the processing;
- Where the Personal Information has to be erased in order to comply with a legal obligation;
- In case a deletion is not possible due to legal, statutory requirements, data anonymisation will occur.
8.1 Exercising of Your GDPR Data Protection Rights
You may exercise your rights of access, rectification, cancellation and opposition by contacting us at:
Postal address: First Rate Marketing, 12 Floor, Broadgate Tower, 20 Primrose St, London EC2A 2EW
9. Children’s Privacy
Our Site is not intended for children under 16 years old.
We do not knowingly collect Personal Information from children under 16 years old. If we learn we have collected or received Personal Information from a child under 16 years old, we take appropriate action including erasing this data from our systems.
If you believe we might have any information from or about a child under 16 years old, please contact us using the information in the “Contact Information” in section 10.
10. Contact Us
11. Changes and Amendments
We may update this policy at any time. We encourage Users to frequently check this page for any changes to stay informed about how we are helping to protect the Personal Information we collect.