1. Introduction and general terms
This policy covers services provided by Upfront Business Development Limited (“Upfront”, “we”, “us” or “our” in this policy). Upfront is an outsourced business development agency for marketing, digital and technology businesses (“client” or “clients” in this policy).
Upfront Business Development Limited, 3.02 Clerkenwell Workshops, 27-31 Clerkenwell Close, London EC1R 0AT
Telephone: +44 (0)20 3861 4450
Upfront is registered with the Information Commissioners Office under registration reference ZA325721
Our clients engage us to develop new business opportunities for them. On behalf of our clients we collect data about and contact businesses that they might be interested in our clients’ offerings.
Upfront is committed to protecting and respecting your privacy. This policy explains the basis on which personal information we collect from you will be processed by us. Where we decide the purpose or means for which personal data supplied by you is processed, we are the “data controller.” We will comply with all applicable data protection laws, including the General Data Protection Regulation 2016/679.
This policy explains the following:
- What personal information we may collect about you;
- Grounds for processing;
- Who we share your information with;
- How we will use that information;
- Who we may disclose that information to; and
- Your rights regarding the information.
2. WHY DO WE COLLECT YOUR DATA?
The reason we collect your data depends upon your relationship with Upfront. We only use your data for business to business purposes. There are two situations in which we collect, process and store your personal data:
- As Upfront
For outreach and marketing purposes we may contact you about a product, service, event, responding to an enquiry or contacting you about matters requiring your attention
- Acting on behalf of a client of Upfront
For outreach and marketing purposes if you are a decision maker we may contact you about a product or service that our client offers. We will only contact you if we think that the product or service is of interest to you. This is generally based on your job title and type of organisation that you work for.
3. WHAT INFORMATION WILL UPFRONT COLLECT ABOUT ME?
We collect and process the following personal information: name, gender, address, telephone number (direct and mobile), e-mail address, job title.
The majority of the personal information we collect about you comes from publicly available online information. We may also collect information on the phone or face to face.
We may also collect technical information about your computer and/or device that may identify you, including your IP address and behaviour when you receive emails (eg. whether you read the email, open it and forward it on to third recipients). We generally collect this from cookies.
4. GROUNDS OF PROCESSING
On some occasions, Upfront processes your data with your consent. You have the right to withdraw consent at any time. Where consent is the only legal basis for processing, we will cease to process data after consent is withdrawn.
- Legitimate interest
Generally Upfront processes your personal information based on legitimate interest and when these interests are not overridden by your data protection rights.
Upfront is an outsourced business development function for our clients. Our offering involves connecting our clients with businesses that may benefit from their products or services. Therefore, we have a legitimate interest in contacting relevant businesses on behalf of our clients as they may benefit from the products or services of our clients’.
If you are a prospective client of Upfront, we may process your data where we believe that you may benefit from the services of Upfront.
- Necessary to fulfil a contract
Upfront may process your data when we need to do this to fulfil a contract with you..
- Necessary because of a legal obligation
Upfront may process your data to comply with our legal and regulatory obligations eg preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies
5. DATA SHARING
We may share your information with the following:
- Our companies
Access to personal information within Upfront and our group of companies is restricted to those individuals who have a need to access the information for our business purposes.
- Our clients
- Our service providers
This includes external third-party service providers, such as accountants, auditors, experts, lawyers and other outside professional advisors; IT systems, support and hosting service providers; technical engineers; data storage and cloud providers and similar third-party vendors and outsourced service providers that assist us in carrying out business activities.
- Other third parties
- Government authorities
In addition, we may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).
If we are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified via email, account message and/or a prominent notice on our website of any change in ownership or uses of this information, as well as any choices you may have regarding this information.
HOW WE WILL USE INFORMATION WE COLLECT ABOUT YOU AND WHO WILL WE SHARE IT WITH?
For companies that we believe are likely to be interested in services of our clients’ we may from time to time decide to send you information by email, post or phone that we believe will be of interest to your role.
This information may include extracts of research that we have done, or the opportunity to speak with our team to discuss our services. If you are not interested in receiving these communications, please let us know.
For these activities, we use an email distribution engine called Kulea and CRM called Pipedrive.
Please consult the respective Privacy Policies for more information:
As applicable, we will use information about you for promoting, selling and supplying the goods and services of our clients, understanding our customers’ behaviour, activities, preferences, and needs, promoting, marketing and advertising our products and services, improving existing products and services and developing new products and services, responding to enquiries and contacting you about matters requiring your attention. We may use third parties to assist us with this.
We process personal data to comply with our necessary legal and regulatory obligations. These include preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies.
We use various forms of marketing to provide you with promotional materials about our services and services of our clients, as well as the services of other companies in our group of companies. We may use third-party providers to assist us with this.
We process information to understand how visitors use our website and our clients’ websites to compile statistical reports regarding that activity.
This processing is necessary for us to pursue our legitimate interests of improving our services, and providing a better and more personalised experience to our users. We may use third party analytics providers.
6. CONSUMER CONTROL & OPT-OUT OPTIONS
If you do not wish to receive promotional or other marketing material from us please contact us using the above contact details.
7. YOUR RIGHTS IN RELATION TO PERSONAL DATA WHICH WE PROCESS RELATING TO YOU
You have the following rights over the way we process personal data relating to you. We aim to comply without undue delay, and within one month at the latest.
To make a request, please contact us using the above contact details, addressed to the contact above.
Ask for a copy of data we are processing about you and have inaccuracies corrected
You have the right to request a copy of the personal information we hold about you and to have any inaccuracies corrected.
We will use reasonable efforts to the extent required by law to supply, correct or delete personal information held about you on our files (and with any third parties to whom it has been disclosed to).
Object to us processing data about you
You can ask us to restrict, stop processing, or to delete your personal data if:
- you request Upfront to stop processing the personal data;
- Upfront no longer needs to process that personal data for the reason it was collected;
- Upfront is processing that personal data because it is in the public interest or it is in order to pursue a legitimate interest of Upfront, you don’t agree with that processing, and there is no overriding legitimate interest for us to continue processing it;
- the personal data was unlawfully processed; or
- you need the personal data to be deleted in order to comply with a legal obligation.
Obtain a machine-readable copy of your personal data, which you can use with another service provider
- If we are processing data in order to perform our obligations to you, or because you consented, if that processing is carried out by automated means, we will help you to move, copy or transfer your personal data to other IT systems.
- If you request, Upfront will supply you with the relevant personal data in CSV format. Where it is technically feasible, you can ask us to send this information directly to another IT system provider if you prefer.
Make a complaint to a Supervisory Authority
- If you are unhappy with the way we are processing your personal data, please let us know.
- If you do not agree with the way we have processed your data or responded to your concerns, you have the right to lodge a complaint with the Information Commissioner’s Office. Further information, including contact details, are available at https://ico.org.uk
8. DATA RETENTION
We review the personal data we store every two years. If the data is still correct, we will keep it. If it is out of date at this stage, we will remove it.
We typically retain your data for ten years to satisfy our regulatory obligations.
We do not knowingly solicit data from or market to children under the age of 18. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at the above details. We will delete such information from our files within a reasonable time.
Upfront is committed to keeping your personal data safe and secure from unauthorised access to or unauthorised alterations, disclosure or destruction of information that we hold. We will take all reasonable technical and organisational precautions to prevent the loss misuse or alteration of your personal information.
Our security measures include:
- Hashing and encryption of our services and data;
- Regular review of information collection;
- Encryption of our services and data;
- Restricted access of data to employees, contractors and agents; and internal policies setting out our data security. Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.
We will notify you of any changes to this policy by email, notice on the website or account message.
International Data Transfers
Your Personal Information which you supply to us is generally stored and kept inside the European Economic Area, however due to the nature of our global business and the technologies required, your Personal Information may be transferred to third party service providers outside the EEA, in countries where there may be a lower legal level of data protection.
Last updated: May 2018