The Data Supermarket Ltd understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, www.thedatasupermarket.com (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site and You will be required to read and accept this Privacy Policy when signing up for an Account. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.
Definitions and Interpretation
In these Terms of Use, unless the context otherwise requires, the following expressions have the following meanings:
| “Cookie” |
Means a small file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. |
| “Data Protection Regulations” |
Means the Data Protection and Privacy Electronic Communications (EU Exit) Regulations 2019, which incorporates the EU Regulation 2016/679 General Data Protection Regulation into (“UK GDPR”).
|
| “Personal Data” |
Means the Data Supermarket Marketplace where Sellers can offer to sell data to potential buyers
|
| “Platform” |
Means any and all data that relates to an classentifiable person who can be directly or indirectly identified from that data, as defined in the Data Protection and Privacy Electronic Communications (EU Exit) Regulations 2019, which incorporates the EU Regulation 2016/679 General Data Protection Regulation into UK law (“UK GDPR”).
|
| “We/Us/Our” |
Means The Data Supermarket Ltd a limited company registered in England and Wales under company number 13855926 whose registered is The Innovation Centre, Brunswick Street, Nelson, England, BB9 0PQ
|
| “EU” |
Means the European Union.
|
| “UK” |
Means the European Union.
|
Ownership and Contact Information
- Our Site is owned and operated by us.
- Our Data Protection Officer can be contacted by email at compliance@thedatasupermarket.com or by post at The Data Supermarket, The Innovation Centre, Brunswick Street, Nelson, England, BB9 0PQ.
ICO Registration
- We are registered with the Information Commissioner’s Office (the, “ICO”). ICO Fee Payer Registration Number: ZB300553.
What Does This Policy Cover?
- This Privacy Policy applies only to your use of Our Site www.thedatasupermarket.com.
- Our Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites, and We advise you to check the privacy policies of any such websites before providing any data to them.
Your Rights
UK and EU users
- The right to be informed about Our collection and use of personal data;
- The right of access to the personal data We hold about you (see section 12);
- The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 15);
- The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 15);
- The right to restrict (i.e. prevent) the processing of your personal data;
- The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
- The right to object to Us using your personal data for particular purposes;
- Rights with respect to automated decision making and profiling.
If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 15, and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you are based outside the UK, or have a complaint concerning our activities outside the UK then you may prefer to lodge a
complaint with a different supervisory authority. A list of those available in the EU can be found here.
Rights applicable to our Californian users
- The California Consumer Privacy Act of 2018 (CCPA) gives consumers specific rights in relation to their personal data collected by businesses. These rights include:
- The right to know about the personal information a business collects about them and how it is used and shared;
- The right to delete personal information collected from them (with some exceptions);
- The right to correct any personal information collected from them;
- The right to opt-out of the sale or sharing of their personal information;
- The right to non-discrimination for exercising their CCPA rights.
In order to exercise your rights under the CCPA you can contact us using the details in section 15 below.
If you wish to exercise your right to opt-out (or opt-in) to the sale of your personal data then please click here. [WILL THERE BE A EASY METHOD BY WHICH THEY CAN OPT OUT OF SELLING THEIR DATA]
Other users
If you are resident outside of the EU, UK or California, we will adhere to any requirements that apply to the country in which you are resident. At a minimum, we will provide all visitors and users of our Site the rights as set in 4.1 above.
What Data Do We Collect?
Depending upon your use of Our Site and/or our services, We may collect some or all of the following personal and non-personal data:
- Full name;
- Home address and residential status;
- Date of birth;
- Gender;
- Business/company name;
- Business details (owners, directors, address and registered company details);
- Job title/profession;
- Contact information such as email addresses and telephone numbers;
- Demographic information such as postcode, preferences, and interests;
- Financial information such as bank name and account details;
- A record of any transactions that occur through your Account with us (i.e. data that you sell or buy through the Platform);
- A record of how and when you used our Site (i.e. any searches you make, any changes you make to your profile/Account on the Platform or the listing that you have made);
- IP address;
- Cookies and tracker information from your browser and/or device;
- Web browser type and version;
- Operating system;
- A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;
- where you contact us by phone, email or post a record of that contact.
How Do We Use Your Data?
All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the Data Protection Regulations at all times. For more details on security see section 8 below.
Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests (see section 7 below for further information). Specifically, We may use your data for the following purposes:
- Providing and managing your Account on our Platform;
- Providing and managing your access to Our Site or the Platform;
- Personalizing and tailoring your experience on Our Site or Platform;
- Supplying Our services to you;
- Keeping our Site functional;
- Personalizing and tailoring Our services for you;
- Replying to emails from you;
- Supplying you with emails that you have opted into;
- Market research;
- Analyzing your use of Our Site and gathering feedback;
- Managing your marketing preferences;
- Managing your data processing preferences;
- Compiling anonymized data for analytical purposes;
- Complying with any legal or regulatory obligations;
- Fraud prevention.
Legitimate Interest
- Where we use legitimate interest for the basis of our processing of your personal data we shall ensure that we can demonstrate compelling legitimate grounds for the processing, which override the interests, rights and freedoms of the individual.
- You have the right to object to our use of your personal data where we use legitimate interest as the basis of processing. You can do this by contacting us on the details in section 15.
- Our legitimate interests include:
- The maintenance of our IT/Data Security systems and processes;
- Putting in place fraud prevention mechanisms;
- Keeping our records up to date;
- Working out which of our products and services may interest you and telling you about them (i.e. direct marketing);
- Developing products and services;
- Being efficient about how we fulfill our legal duties;
- Maintaining a marketing suppression list; and
- Complying with laws/regulations that apply to us.
How and Where Do We Store Your Data?
We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
All our customer data is stored and accessed from our servers in the UK or the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein).
However, some or all of your data may be stored/transferred outside of the EEA or UK. You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store data outside the EEA or UK, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA or UK and in compliance with the Data Protection Regulations including:
- Carrying out due diligence on prospective parties to which we wish to transfer the data to;
- Carrying out a risk assessment on the country to which we will transfer data to ensure that the protection offered to data subjects is equivalent to those provided in the UK, or accepted by the UK regulator as having adequate levels of protections (i.e. an adequacy decision exists);
- Having in place written contracts on the transfer and use of the data (or using EU model contract clauses or the ICO’s International Data Transfer Agreements) that set out clearly the responsibilities of each party and the rights of data subjects;
- Transferring data in an encrypted form or using a secure file transfer protocol;
- Limiting the data transfer to only data that needs to be transferred to achieve the purpose.
Do We Share Your Data?
- We may share your data with other companies for carrying out/putting in place the services that you require. For example, if you wish to purchase data from a Seller on our Platform, then we may share your (i.e. the Buyer) details for them to contact you.
- We may sometimes contract with third parties to supply services to you on Our behalf. These may include search engine facilities, advertising, and marketing companies. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
- In order to provide you with our services (and comply with our contractual obligations) we may need to share some or all of your personal data with our service providers:
- [The Data Supermarket - CRM system]
- [The Data Supermarket - servers]
- [The Data Supermarket - emailing platform for sending email communications]
- [The Data Supermarket - hosting and server provider]
- [The Data Supermarket - campaign management platform]
- [The Data Supermarket - project management platform]
- [The Data Supermarket - customer feedback and reviews platform]
- [PDP Consultancy Services Ltd - Compliance consultant]
- We may compile statistics about the use of Our Site, including data on traffic, usage patterns, user numbers, sales, and other information. We will also compile statistics for registered users of the Platform to enable them to assess the success of any listing they have made on the Platform. All such data will be anonymous and will not include any personally identifying data, or any anonymized data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
- We may sometimes use third-party data processors that are located outside of the UK. Where We transfer any personal data outside the UK, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the Data Protection Regulations.
- In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.
- We may, with your consent, or where it is in our legitimate interest, also share some or all of your personal information with various organizations/categories of organizations:
- We may share your data with regulators and disputes resolution bodies such as:
- Our service providers as listed in 9.3 and 9.7.
- We use the services of Facebook Ireland Limited (Facebook) to carry out certain marketing activities on the Facebook Platform. Specifically, from time to time we use Facebook’s Audience Insights to help us to create targeted audiences for our advertising campaigns on Facebook. In this respect, Facebook acts as our joint processor.
What Happens If Our Business Changes Hands?
We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Any personal data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part, and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by Us.
How Can You Control Your Data?
- In addition to your rights under the Data Protection Regulations, set out in section 4, when you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you control over Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details).
- You may also wish to sign up for one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These services may help prevent you from receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
Your Right to Withhold Information
- You may access Our Site without providing any data at all.
- You may restrict Our use of Cookies. For more information, Our Cookie Policy can be accessed on our website.
How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the Data Protection Regulations, no fee is payable, and We will provide any and all information in response to your request free of charge. Please contact Us for more details at compliance@thedatasupermarket.com or using the contact details below in section 15.
Our Use of Cookies
Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve services. In addition, Our Site uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyze usage statistics, enabling Us to better understand how people use Our Site. For more details, please refer to Our Cookie Policy, which can be accessed on our website.
Contacting Us
If you would like to contact us, please contact Us at compliance@thedatasupermarket.com, or by post at The Data Supermarket Ltd, The Innovation Centre, Brunswick Street, Nelson, England, BB9 0PQ. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 13 above).
Changes to Our Privacy Policy
We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Site, and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.
John Terry
9 months agoThis is a great template, I’ll have to try TDS blogs out.