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Business Contacts Privacy Notice

1. Who we are and how you can contact us
2. What we use personal data for
3. What kinds of personal data we use and where we get it from
4. What our legal grounds for handling personal data are
5. Who we share personal data with
6. Where the personal data is stored and sent
7. How long the personal data is kept for
8. Whether the personal data is used to make decisions about you or to profile you
9. Your rights in relation to the personal data we hold about you
10. Who you can complain to if you are unhappy about the use of your personal data
11. How we keep your data secure
1. Who we are and how you can contact us

We are Chord UK Ltd, a company based in Frome, Somerset in the United Kingdom. Chord controls personal data about our business contacts and their representatives. This means that we are responsible for ensuring that the personal data is used fairly and lawfully.

Chord is registered in England and Wales under registration number 4182583, and our registered office is at G10A Frome Business Park, Manor Road, Frome, BA11 4FN. This is also our principal place of business.

You can contact us about issues relating to personal data, including the contents of this notice, by any of the following methods:

Post: G10A Frome Business Park, Manor Road, Frome, BA11 4FN
Email: privacy@chord-uk.co.uk
Telephone: 01373 867920

2. What we use personal data for

This section explains the purposes for which we use personal data about our business contacts and their representatives. More detail about the types of personal data that we might use for these purposes can be found in section 3 below.

Marketing

We use personal data for marketing purposes, typically in relation to current or potential clients and their representatives. This includes providing you with original insight, commentary and research on data, telemarketing and research, early notifications of exclusive events, webinars and updates on our products and services.

We will not make contact with you for marketing purposes through any particular channel (such as email, telephone or post) if you have told us that you don’t want to hear from us in that way. Please note that if you ask us not to contact you for marketing purposes, you might still hear from us for other reasons – for example, as part of our ordinary relationship management activity.

Relationship management

We use personal data for relationship management purposes. Relationship management is the ongoing maintenance of our relationship with our clients, suppliers and their representatives. This could include activities such as interactions about your campaign, letting you know about service changes or planned maintenance activity, contacting you with billing enquiries, inviting you to events and webinars, dealing with your enquiries, or asking you about what sorts of products you want us to develop.

Providing services

We use your personal data to provide you with information, services and facilities that you have asked for. For example, if you commission a campaign we will use your contacts details to keep you informed of progress. Or if you sign up to one of our events or webinars we might use your contact details to let you know how to access it.

Monitoring and improving our website

We use information such as how different people navigate around our website, how long they spend on particular pages and whether they download any of our content in order to help customise and improve the user experience of our website. It also allows us to tailor the website to match your interests and preferences better and helps us understand who has visited which pages to determine the most popular areas of the website. This information is also used for security and system administration and to generate aggregate non-personalised information for use by us.

Legal and regulatory purposes

We may use your personal data for legal and regulatory purposes. For example, this might include responding to complaints or enquiries from you or a regulator about how we have used your personal data.

3. What kinds of personal data we use and where we get it from

We obtain and use information from various different sources.

Type of information Description Source
Name and contact details This is basic personal data about you at your place of work, and how to get in touch with you, including your name, location, telephone number and email address. This information is usually provided directly by the relevant individuals; it could for example be given over the telephone, in an email, through our websites, or in person at an event. In addition, we may use publicly-available and website sources, like LinkedIn, or marketing lists from carefully selected data suppliers.
Organisation-related details This is information about your organisation, your role within it such as your job title and who your colleagues are.
Login credentials This is information such as your username and password, which are recorded if you sign up to one of our web-based services or require FTPs access to securely share files. This information is provided by you or may sometimes be generated by us (for example, if we reset your password for you).
Contact history This is information about our dealings with you, such as what information we have sent you, who at Chord knows you, and what meetings, events or webinars you have attended. It also includes your behaviour in response to our interactions with you, such as whether you have opened our emails, clicked on a link or watched a video. We produce these records ourselves.
Device information This is information about the device you are using to access our websites, such as the type of device, its operating system, browser, its IP address, and what cookies are on it. We produce these records ourselves by monitoring your use of our website.
Website usage This is information about your use of our website, such as what pages you have visited and what content you have downloaded.

You are free to choose whether or not you give us your personal data. However, if you are signing up to one of our services, we might not be able to provide you with that product of service if you do not give us the information we need in order to do so

4. What our legal grounds for handling personal data are

The United Kingdom’s data protection law allows the use of your personal data where necessary for legitimate purposes provided that this isn’t outweighed by the impact it has on you. The law calls this the “legitimate interests” condition for processing personal data. We rely on this condition for most of our processing activities.

The legitimate interests we are pursuing are:

Interest Explanation
Marketing We have an interest in promoting our services to our clients and potential clients by email, telephone and post*.
Maintaining and using our business relationships; understanding and keeping in touch with our clients and suppliers. We have an interest in maintaining and making use of our relationship with you. For example, if you work for one of our clients we may need to contact you in connection with one of the services that your employer has purchased from us. Or if you work for one of our suppliers we may need to contact you about a service that your employer supplies to us.

We also have an interest in understanding what kinds of people use our services and how they use them.

Helping people learn about services that might be of use to them Our clients and potential clients have an interest in learning about services that they might find useful.
Commercial interests Like any commercial organisation, we seek to earn revenue through the services that we provide to our clients.

*Chord Ltd is a well-established UK-based telemarketing agency, with specific expertise in supporting clients in membership, professional and business services and export development sectors. To grow and generate profits, Chord needs to market its services to existing clients and potential clients. Generating profits enables Chord to contribute to the economy by paying taxes in the UK, pay its staff and reward them for the great work they do and reward its investors for having the confidence to invest.

To achieve these aims Chord has a legitimate interest to process personal data to identify clients and potential clients, who are in job roles that are likely to use our services and communicate this to them, either by phone, email or post. To establish Legitimate Interest as a lawful basis for processing personal data for these purposes a Legitimate Interest Assessment was conducted.

Other grounds

In some circumstances, we may have other grounds to process personal data. These are set out in the following table, along with examples of the circumstances in which they might apply.

Grounds Examples
Necessary for performance of a contract or to take steps for entering into a contract. If you sign up to one of our services, it will often be necessary for us to use your details in order to provide that service.
Necessary in order to comply with a legal obligation. Regulators, government bodies and courts have powers to order us to provide information and, like any other organisation; we sometimes have to comply with their requests.

5. Who we share personal data with
Service providers

We may provide your information to third parties who help us use it for the purposes described in section 2. For example:

  • Our database of personal data may be hosted by third parties on our behalf.
  • We use a third party email broadcasting service in order to send you service and marketing emails.
  • We might use a printing company to produce and send personalised direct mail.
  • We might use marketing research companies to help us better understand our clients.
  • Some of our services rely on us sending personal data to third parties who then analyse or enhance it and return the results to us.

These service providers will not be allowed to use your information for their own purposes or on behalf of other organisations, unless you agree otherwise.

Business Transfers

If we sell our business to a third party, or go through a corporate reorganisation, we will transfer personal data to the company that acquires the business.

Regulators

We may sometimes need to pass personal data to a regulator such as the Information Commissioner’s Office.

6. Where the personal data is stored and sent
Within Europe

We are based in the United Kingdom, and will access and use your information from here.

Elsewhere

We also send information elsewhere in the world. For example:

  • Where we use cloud-based technology or a data centre or backup facility overseas. For example, our email marketing database (which will hold your information) is currently hosted by a service provider in the United States. People in other countries may also need to access that database for purposes such as technical support or system development and testing.
  • While countries within the European Union all ensure a high standard of data protection law, some parts of the world may not provide the same level of legal protection in relation to personal data. As a result, when we do send personal data overseas, we will make sure that suitable safeguards are in place to protect the information. For example, these safeguards might include:
    • Putting in place a contract with the recipient containing terms which have been approved by the authorities as providing a suitable level of protection.
    • Sending the information to an organisation which is a member of a scheme which has been approved by the authorities as providing a suitable level of protection. One example is the “Privacy Shield” scheme that has been agreed between the European and US authorities.

If your information has been sent overseas like this, you can obtain further information about the safeguards used by contacting us using the details set out in section 1 above.

7. How long the personal data is kept for

We will not keep your personal data for longer than we need it.

If you are a representative of one of our clients or potential clients, this means that we will normally keep your data while you or your employer has an ongoing relationship with us or if you have demonstrated an interest in our services within the past two years. You can request us to delete it earlier as explained in section 9.

8. Whether the personal data is used to make decisions about you or to profile you

We use certain profiling techniques in order to help us to understand our clients and potential clients. This in turn helps us to understand which people might be interested in which of our services.

We do not use automated decision-making or profiling to make any decisions that will significantly affect you. For example, we do not use it to set the prices that we charge for our services.

9. Your rights in relation to the personal data we hold about you

You have several different rights in relation to the personal data that we hold about you. These are briefly described below. To enquire about exercising these rights, please use the contact details set out section 1.

Access: You have a right to find out what personal data we hold about you and certain other information such as how we are using it.

Objection to direct marketing: You have the right to object to use using your personal data for direct marketing purposes. If you do this we will stop using it for these purposes.

From 25 May 2018, you also have the following rights:

Rectification: If you believe that the information that we hold about you is inaccurate or out of date, you have a right to ask us to correct it.

Objection to legitimate interests: If you disagree with us relying on the legitimate interests ground for using your personal data (see section 4 above), you can object to us doing so. We will the reassess the extent to which we can continue to use the data in light of your particular circumstances. In the case of emails that are sent on the basis of legitimate interests (see section 4 above), you can do this by clicking on the ‘unsubscribe’ link.

Erasure: In certain circumstances you can ask us to delete your personal data from our systems. However this usually won’t apply to all of your data because we might have good reason for needing to keep some of it. For example, so that we do not subsequently contact you if we receive your details again in the future.

Restriction: In certain circumstances you can ask us to restrict in which we use your personal data.

Portability: You have the right to receive limited kinds of information in a portable format.

10. Who you can complain to if you are unhappy about the use of your personal data

If you are not happy you should make contact so that we can investigate your concerns. Please contact us using these details:

Post: G10A Frome Business Park, Manor Road, Frome, BA11 4FN
Email: privacy@chord-uk.co.uk
Telephone: 01373 867920

You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO), which is the body that regulates the handling of personal data in the United Kingdom. You can do this online through the ICO’s website at www.ico.org.uk, by telephone on 0303 123 1113, or by writing to them at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF.

11. How we keep your data secure

We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.

We will store all the personal information you provide on our secure (password and firewall-protected) servers.

Electronic financial transactions entered into through our website will be protected by encryption technology.

You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

You are responsible for keeping the password you use for accessing our website confidential; we will not ask you for your password (except when you log in to our website).

Contact us

Chord UK Limited
M4 Frome Business Park
Manor Road, Frome
Somerset, BA11 4FN

01373 867920
hello@chord-uk.co.uk

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