PRIVACY POLICY

Click Labs Group is a digital marketing company. We work with over 200 High Street brands and provide you with personalised marketing content from these brands via email, social, display and influencer Media Partners. Our aim is to provide you with offers and content that we believe may be relevant to you.

This privacy statement applies to www.clicklabsgroup.com (the “Site”) and services operated by Click Labs Group and describes how Click Labs Group, ( ‘We’, ‘Us’ or ‘Our’) collects and uses the personal information that you provide or that we collect on our Site, or when using our Affiliate Tracking Network and software powered by Clear Reports (the “Platform”) and any other non-personal information about you that we may hold, such as our marketing lists and supplier contacts. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information.

Please read the following information carefully to understand our practices regarding your personal data and how we will treat it. By visiting our Site and using our Platform you are accepting and consenting to the practices described in this policy.

For the purpose of the General Data Protection Regulations (the GDPR), the data controller is Click Labs Group Ltd, Dolphin House, 103 Frimley Road, Camberley, Surrey, GU15 2PP. Click Labs Group Ltd is a DMA accredited company and is registered with the ICO (number ZA021952). The Data Protection Officer is Piers de Grouchy who can be contacted at compliance@clicklabsgroup.com.

“Personal data” is defined in Article 4(1) of the GDPR:

“(1) ‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

We have a responsibility to ensure that we treat personal data in a responsible and legally compliant way. That’s why we’ve developed this privacy and cookies policy (“Policy”), which:

  • sets out the types of personal data that we collect
  • explains how and why we collect and use your personal data
  • explains when and why we will share personal data within the Click Labs Group and with other organisations; and
  • explains the rights and choices you have when it comes to your personal data

We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

We share data with the following third party data processors who we use to help us provide our services: Clear Reports, Microsoft 365, Skype, Optizmo.

We enable the sharing of your email address, in encrypted form, between our advertiser clients and affiliates where your address is on their marketing suppression (opt -out) list.

We may share information with companies, organisations or individuals outside of Us if we have a good-faith belief that we are obliged to do so by law. This includes the Information Commissioners office

We may transfer information in our possession to a successor entity in connection with a corporate change in control such as a merger or acquisition or the sale of company assets. In this case, your information will remain subject to this/an equivalent privacy policy.

  1. Information we may collect about You
     
    1. Information you give us. You may give us information about you by filling in contact forms on our Site or by corresponding with us by phone, e-mail, SMS, Whatsapp or Skype. This includes information you provide when you contact us through our Site, register with our Platform, where you are an advertiser or affiliate of ours, brief us on a campaign, unsubscribe from one of our media partners or submit a support ticket or otherwise report a problem with our Site. The information you give us may include your name, address, e -mail address and phone number, along with details pertaining to the reason you are communicating with us.
    2. Information we collect about you. Each time an advert is processed via our Platform from our Affiliate/Media partners’ delivery, we collect and store technical identifying information about you which includes, but is not limited to, URLs, Transaction Codes, IP Addresses, Time Stamps, Device Types, SubIDs, User Agents, Device Browsers, Custom Fields, Transaction Values,

      Campaign IDs, Partner IDs. This information is processed in order to provide the Merchant, Media Partners and Data Subjects with a viable and relevant marketing campaign, as well as visibility of all aspects relating to recording the results of a campaign.

      Each time you visit our Site, we will typically collect the following usage information:
       
      • Details of visits to our website (which enables our website to remember information about you and your preferences) and use of our Site. This may include information about your visit, including the full Uniform Resource Locators (URL), clicks through to and from our Site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.
         
    3. Information we receive from other sources. Where you have opted out of receiving marketing by email with our Advertiser clients, we will receive your encrypted email address from the Advertiser, which we share with our publisher affiliates in order that they do not contact you with marketing material against your wishes. This may otherwise be known as a Suppression list.
       
  2. On what basis can we process Your Information?

    The legal grounds for processing your personal data are as follows:
     
    1. It is necessary for the performance of a contract entered into between you and us, or to take steps prior to entering into a contract with you, including those with our advertiser and affiliate clients and our suppliers.
    2. Where you have given us consent to the processing of your personal data for one or more specific purposes.
    3. It is necessary for the purposes of our legitimate interests, except where our interests are overridden by the interests, rights or freedoms of affected individuals (such as you). To determine this we shall consider a number of factors, such as what you w ere told at the time you provided your data, what your expectations are about the processing of the data, the nature of the data, and the impact of the processing on you. Our legitimate interests are to operate our Affiliate Network, improve and promote our services and products , facilitate the suppression of marketing emails with you where you have opted out, comply with data protection legislation, enable your use of our Site, respond to your queries, better understand our customers’ interests and needs, provide our clients with potential sales prospects .
    4. Where it is necessary for us to do so, including sharing your information with others, in order to comply with a legal obligation.
       
  3. Uses made of Your Information

    We use the data you give us, we collect about you and we receive from others:
     
    • To ensure that content from our Site is presented in the most effective , targeted and visual manner for you and for your devices.
    • To provide you, or for permitted selected third parties to provide you, with information about goods or services we feel may interest you; where you have provided permission for us to do so, we may send you marketing messages by email. For those marketing messages you can unsubscribe at any time by clicking on the unsubscribe link in the message.
    • To ensure that you do not receive marketing communications where you have opted out of receiving these.
    • To communicate with you during the course of providing our services, for example with your enquiries and requests.
    • To enable the delivery of adverts to you and to personalise each advert that you will be served, making it more relevant to you. We measure your exposure (contact frequency) to each advert by tracking the number of times you have requested it, heard it or clicked it for statistics reporting purposes and for improving our service over time.
    • To carry out our obligations arising from any contracts entered into between you and us , to provide you with the information, products and services that you request from us and to notify you about changes to our service.
       
  4. Disclosure of Your Information

    We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

    We share data with the following third party data processors who we use to help us provide our services: Clear Reports, Microsoft 365, Skype, Optizmo.

    We enable the sharing of your email address, in encrypted form, between our advertiser clients and affiliates where your address is on their marketing suppression (opt-out) list.

    We may share information with companies, organisations or individuals outside of Us if we have a good-faith belief that we are obliged to do so by law. This includes the Information Commissioners office

    We may transfer information in our possession to a successor entity in connection with a corporate change in control such as a merger or acquisition or the sale of company assets. In this case, your information will remain subject to this/an equivalent privacy policy.
     
  5. Where we store Your Personal Data
     

    Your data will normally (depending on where the server is located) be held on secure servers within the European Economic Area ("EEA") with all reasonable technological and operation measures put in place to safeguard it from unauthorised access. Where possible any identifiable information will be encrypted or minimised.

    There may be occasions however where data that we collect from or about you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA") where data protection laws are not as strict as they are in the UK.

    We currently license a tracking Platform Clear Reports and Optizmo in the US for example. Data may also be processed by staff operating outside the EEA who work for us or for one of our Affiliates or Media Partners. Where your personal data is being transferred outside the EEA, we will either undertake an assessment of the level of protection in light of the circumstances surrounding the transfer or:

    • Only transfer it to a non-EEA country with privacy laws that give the same protection as the EEA; or
    • Ensure we have an agreement in place with the recipient under which they are under a duty to protect your data to the same standards as those in place in the EEA; or
    • Transfer it to US organisations that are signed up to the EU-US Privacy Shield scheme; or
    • We will make sure that any transfers are not repetitive and only limited to the minimum amount of information possible. In certain circumstances we may need to seek your consent unless there is an overriding legal need to transfer the information]; and
      In all cases where your information is transferred outside the EEA, you have a right to contact us for information on the measures we have put in place.
       
  6. How long we keep your data for
     

    We will retain your personal data for only as long as is necessary for the purposes we set out above, but which may at times be a longer period than that for which we need to hold your data to provide those services, i.e. where we are under regulatory or statutory duties to hold your data for a longer period. The following data will be held by us for the periods set out below as is necessary to meet the purposes for which we initially collected this information:

    Name, Email Address and contact numbers of potential and existing clients indefinitely.

    Name and Email Address as part of suppression management indefinitely on Group and Brand level IP Addresses linked to campaign engagement in our tracking system Clear Reports for 24 Months.
     

  7. Other Websites

    Our Site may, from time to time, contain links to and from the websites of our Partner Networks, Advertisers and Affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
     
  8. Data security
     

    We take all reasonable measures to protect the information we collect and store. All transfers to, from and within our Platform are over HTTPS, our servers are located in a secure facility and we strictly control access to the data via strong passwords and two -factor authentication.

    All email addresses which are transmitted over our Platform are transferred in encrypted form.

    Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Site or our Platform, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

    Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
     

  9. Your Rights
     

    Access to Information: You have the right to request a copy of the personal information we hold about you, known as a data subject access request. You also have the right to request that information we hold about you which may be incorrect, or which has been changed since you first told us, is updated or removed. These requests are free of char ge and can be sent to compliance@clicklabsgroup.com.

    Erasure of Your Information: You can ask us to delete or remove your personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where you have withdrawn consent for us to process it (as explained below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

    How you can withdraw your consent: You have the right at any time to withdraw any consent you have given us to process your personal data. Please note if you withdraw your consent it will not affect the lawfulness of any processing of your personal data we have carried out before you withdrew your consent. Should you wish to do so you can change your consent preferences at any time, such as to unsubscribe or opt out of marketing emails by contacting us at compliance@clicklabsgroup.com or by unsubscribing via the link in the email.

    How you can restrict or object to us using Your Information: You can ask us to suspend the way in which we are using Your Information in certain scenarios, or object to our processing your data where we are relying on a legitimate interest ground (or those of a third party) and you feel it impacts on your fundamental rights and freedoms, or where we are processing your personal data for direct marketing purposes. In some cases where you object, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

    Please note that if you want us to restrict or stop processing your data this may impact on our ability to provide our services. Depending on the extent of your request we may be unable to continue providing you with our service.

    Any queries or concerns about the way in which your data is being used can be sent to compliance@clicklabsgroup.com.

    Moving Your Information to another organisation: In the event that we process your data by automated means where you have either provided us with consent for us to use your information or where we used the information to perform a contract with you, you have the right to request that we send to you or to another organisation, a copy of the personal data we hold about you, for example when you are dealing with a different service provider. If you would like us to move, copy, or transfer your information please let us know by email to compliance@clicklabsgroup.com. We will respond to you within one month after assessing whether or not this is possible, taking into account the technical compatibility with the other organisation in question.

    We collect personal data so that we can target you with offers and content that we believe may be relevant to you. Without profiling you in this manner, we would send you less relevant marketing messages. Profiling may include basic information like your postcode and targeting you with local brands. It could be more detailed, such as your salary banding, so that we can send you relevant products for your income bracket. In general, profiles are grouped into segments to aid targeting rather than by individual targeting.

    We do not use data for finance credit checking, medical or religious purposes. We do not store data to identify sexual orientation, political beliefs or religious beliefs.

    We do aggregate personal data to develop and improve the content we display to you on the website and send you via email. For example, as there is an increase in mobile usage, our design process has used data to understand device usage.

    We do use personal data to detect fraudulent activity on our advertising campaigns. For example, this may include detecting invalid applications for a financial product or detecting too many clicks from the same source.

    We do use your personal data to manage promotions and competitions you enter, to contact you or select you for a promotion.

    We do not use your information for automated decision making or profiling that may have a legal or similarly significant effect on you.

  10. Children

    Our services are not aimed at children.
     
  11. Changes to This Policy

    This Privacy Policy is subject to change. We will post the updated version on our Site www.clicklabsgroup.com. Whenever a change is significant, we will place a prominent notice on this Site and we encourage you to periodically review this page for the lat est information on our privacy practices.
     
  12. Questions or Comments and Complaints

If you have questions or comments regarding this privacy statement, please contact us at compliance@clicklabsgroup.com If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to the UK data protection regulator, the Information Commissioner’s Office. Further details can be found at www.ico.org.uk or 0303 123 1113.