The Prosperly Marketing Group of businesses creates and maintains an extensive range of innovative marketing solutions and services - all designed or selected to meet the specific needs of clients.
The GDPR (General Data Protection Regulation) and the Data Protection Act 2018 set out the legal obligations for organisations in regard to the processing of personal data.
PMG is committed to protecting and respecting the privacy of individuals.
We will only process your data if there is a lawful basis for such processing. The lawful basis for processing Personal Data will be one of the following:
You have given PMG clear and specific consent for processing your data.
You, or the organisation you work for, have entered into a contract with us in which the processing of your data is required.
We need to process your data in order to comply with a common law or statutory obligation.
We have a legitimate interest in processing your data in circumstances where it would be reasonable for you to expect such data processing and where there is a minimal privacy impact. Some direct marketing activities may be based on legitimate interests. Where legitimate interest is deemed to apply, PMG will have carried out a Legitimate Interest Assessment.
For the purpose of data protection legislation, the data controller is:
Prosperly Marketing Group Ltd which each has their registered office at: 33 Beech Road, Alresford, Hampshire, SO249JS.
Our websites may contain links to other sites. PMG is not responsible for the privacy practices or the content of such websites. The websites may also include comment fields, chat rooms, forums, message boards, and newsgroups. Please remember that any information that is disclosed in these areas becomes public information and you should exercise caution when deciding to disclose your personal information.
The information you give us may include your name, address, e-mail address and phone number, organisation, job role or title, financial and credit card information and some interests/preferences.
Concerning each of your visits to our websites we will automatically collect the following information:
This is the information we receive about you if you use any of the websites we operate or other services we provide. In these cases, we will have informed you when we collect that data if we intend to share those data internally and combine it with data collected on our websites. We will also have told you for what purpose we will share and combine your data.
We work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies).
We may also purchase marketing lists, containing contact data, from trusted third parties. We will always ensure that there was an appropriate lawful basis for the collection of this data.
We will use the information you give us:
We will use the information we collect about you:
The Internet protocol (IP) address used to connect your computer to the Internet. We use your IP address for the following purposes:
We (or third-party data processors acting on our behalf) may collect, store, and use your personal information for individual website experience improvement.
We collate the information collected about you or provided by you in order to offer you a more tailored marketing experience but always where we either have your consent or where PMG has a legitimate business purpose to do so.
For marketing purposes, we may collect, store and use the following kinds of personal data:
We will use this information to provide you or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you with PMG information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you.
If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you are happy for us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data. You can unsubscribe from receiving these at any time;
If your email address is linked to a business account, we may process your data on the basis of legitimate interests. However, it is possible that we would also recognise your email as belonging to an individual and, in that scenario, we would process your data only if you have given consent. It is possible for one email address to be against both business and personal classifications.
For example, if email@example.com is linked to a business account, PMG will market to you in your business capacity on the basis of legitimate interests until you unsubscribe from these emails. Additionally, since the email address is classified as also belonging to an individual, we will market to you in your personal capacity only if we have received your consent to do so. Your consent may be withdrawn at any time.
PMGs provision of the products or services to you may require the transfer of data to any of PMGs wholly-owned subsidiaries.
PMG has a central database which all PMG companies can access. Some personal data (such as the name on an invoice, or a contact) may be visible by all PMG companies.
We may share your data with external third parties for the following reasons:
PMG uses some services and/or products from external third parties in order to provide the services you have requested. This may include (by way of example only) third parties that provide online storage and other facilities. Further details can be found within the Terms and Conditions related to the product or service you have purchased. If PMG becomes aware of any such third party wishing to transfer your data outside the European Economic Area, PMG shall request that the third party enters into an agreement with PMG based upon standard contractual clauses approved by the European Commission for transfers of personal data to processors outside of the European Economic Area and which agreement shall include security obligations on such third party.
You agree that we have the right to share your personal information with:
We will disclose your personal information to third parties:
The data that we collect from you may be transferred to, and stored at:
PMG uses a range of security measures in order to protect Personal data.
A wide range of technical controls are used, including but not limited to:
A wide range of non-technical controls are used, including but not limited to:
The implementation of such controls may vary between specific products and services.
All websites have security measures in place to protect the loss, misuse and alteration of the information under our control. Where necessary PMG will inform law enforcement agencies or other relevant organisations regarding misconduct.
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted and utilise technologies to ensure PCI DSS compliance. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our websites, 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 websites; 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.
PMG has established a data retention framework based on statutory and non-statutory guidance. The framework applies to both digital and non-digital data. In regard to the retention of personal data of individuals who are neither employees nor former employees, data retention schedules will be applied in accordance with the following:
Data retention schedules will be documented and will be communicated, either through terms and conditions of the relevant product and/or service or upon request.
In accordance with data protection legislation, PMG recognises that data subjects have specific rights that must be protected and observed.
PMG provides employees, customers and other third parties with information about how personal data is collected, processed and managed. PMG seeks to provide this information in language that is clear, concise and intelligible. This information is intended to be easily accessible for internal and external users.
PMG provides data subjects with access to the personal data that it manages as a data controller. A Subject Access Request (SAR) process has been defined (see paragraph 9 below) and communicated. Data subjects for whom PMG is not the data controller but may process their personal data, should – in the first instance – contact the data controller directly when requesting such access.
PMG recognises the right of individuals to have inaccurate or incomplete data to be amended. Data subjects for whom PMG is not the data controller, should – in the first instance – contact the data controller when making a data rectification request.
PMG recognises the right of individuals to request for their data to be deleted or removed where there is no compelling reason for its continued processing. PMG will, in all cases, follow the ICO’s guidance on how and when such a request should be observed. PMG maintains a data retention schedule so that personal data is not retained for longer than is necessary with regard to the purpose for which the data was original collected. However, some personal data may be required to be retained in order to observe other legal or regulatory obligations. In addition, in line with the ICO’s guidance on the constraints that existing when deleting data retained in digital back-ups, PMG will seek to place such back-ups beyond effective use.
Where the right of portability applies, as defined by the ICO, PMG will provide data in a form that is structured, commonly used and in a machine-readable form. In most cases, this will be the CSV format.
PMG recognises the right of individuals to object to the processing of their personal data, where such objections are allowable under data protection legislation. Rights related to automated decision making including profiling PMG does not use automated decision making where such decisions have a significant effect on data subjects.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by not checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us using the details set out below.
The 'Manage my Preferences' link, found in all automated communications, will give you access to an area to show your preferences for communication.
Each time you receive electronic marketing information from us, you have the option to decline to receive further marketing information from us.
To stop receiving email communications from PMG in the future, you can:
Click the 'Manage my Preferences' link and follow the onscreen instructions.
If you change your preferences, we will endeavour to ensure our systems reflect this within one (1) week of receiving your alteration. Please note that if you terminate your PMG account but have also subscribed to newsletters, for example, you must additionally unsubscribe from these in order to cease receiving communication. This also applies to any third parties you have agreed we can share your information with. To prevent you from receiving such communications from PMG in the future, you can send a letter clearly identifying yourself and asking that we remove you from our contact lists. Contact details are set out below.
Our websites 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.
Should you have a concern about PMGs information rights practices, please report it to us for investigation. If, following our internal review, you are not satisfied, you can report the matter to the Information Commissioner’s Office.
The Data Protection Legislation gives you the right to access information held about you. Your right of access can be exercised in accordance with such legislation. Upon receipt of a request to our Data Protection Officer and upon validation of the requestor’s identity, PMG will within one (1) month:
If the request is particularly complex or numerous, PMG may extend the period for repose by up to two (2) months.
If the request is manifestly unfounded or excessive, PMG may charge a fee or refuse to respond.
If disclosing the personal data will adversely affect the rights and freedoms of others, PMG may withhold such personal data. This may extend to intellectual property and trade secrets.
PMG Data Protection Officer
33 Beech Road, Alresford, Hampshire, SO249JS