Policy key definitions:
- “I”, “our”, “us”, or “we” refer to the business, Fresh Brew Marketing Ltd
- “you”, “the user” refer to the person(s) using this website.
- GDPR means General Data Protection Act.
- PECR means Privacy & Electronic Communications Regulation.
- ICO means Information Commissioner’s Office.
- Cookies mean small files stored on a users computer or device.
How we collect your data
Under the GDPR (General Data Protection Regulation) we control and / or process any personal information about you electronically using the following lawful bases.
- We collect your personal data in a number of ways, for example:
- From the information you provide to us when you meet us;
- From information about you provided to us by your company or an intermediary;
- When you communicate with us in writing, by telephone, fax, website registration, email or other forms of electronic
communication. In this respect, we may monitor, record and store any such communication;
- When you complete (or we complete on your behalf) client on-boarding or application or other forms;
- From your agents, advisers, intermediaries, and custodians of your assets;
- From publicly available sources or from third parties, most commonly where we need to conduct background checks about you.
- When you sign up to our marketing activities or subscribe to our blogs.
The categories of personal data we collect
- We may collect any of the following categories of personal data about you:
- Your name and contact information such as your home or business address, job title, email address and telephone number;
- Biographical information which may confirm your identity including your date of birth, tax identification number and your passport number or national identity card details, country of domicile and/or your nationality;
- Information relating to the way you access our websites and emails that we send to you, including your IP Address, subscription time & date, your business’ website, how often you access our website & emails.
- An understanding of your goals and objectives in procuring our services;
- Information about your employment, education, family or personal circumstances, and interests, where relevant; and
- Information to assess whether you may represent a politically-exposed person or money laundering risk.
How we use your data
1. Performance of a contract with you
- The basis for processing your personal data (other than with your consent), how we use that personal data and whom we share it with:
- Performance of a contract with you: We process your personal data because it is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract. In this respect, we use your personal data for the following:
- To prepare a proposal for you regarding the services we offer;
- To provide you with the services you require of us, and as discussed directly with you or as otherwise agreed with you from time to time;
- To deal with any complaints or feedback you may have;
- For any other purpose for which you provide us with your personal data.
- In this respect, we may share your personal data with or transfer it to the following:
- Your agents, advisers, intermediaries, and custodians of your assets who you tell us about;
- Third parties whom we engage to assist in delivering the services to you, including other companies in the Fresh Brew Marketing network
- Our professional advisers where it is necessary for us to obtain their advice or assistance, including lawyers, accountants, IT or public relations advisers;
- Debt collection agencies where it is necessary to recover money you owe us;
- Other third parties such as intermediaries who we introduce to you. We will wherever possible tell you who they are before we introduce you;
- Our data storage providers.
2. Legitimate interests
- We also process your personal data because it is necessary for our legitimate interests, or sometimes where it is necessary for the legitimate interests of another person. In this respect, we use your personal data for the following:
- For marketing to you. In this respect, see the separate section on Marketing below;
- Training our staff or monitoring their performance;
- For the administration and management of our business, including recovering money you owe to us, and archiving or statistical analysis;
- Seeking advice on our rights and obligations, such as where we require our own legal advice.
- In this respect we will share your personal data with the following:
- Our advisers or agents where it is necessary for us to obtain their advice or assistance;
- With third parties and their advisers where those third parties are acquiring, or considering acquiring, all or part of our business.
3. Legal obligations
We also process your personal data for our compliance with a legal obligation which we are under. In this respect, we will use your personal data for the following:
- To meet our compliance and regulatory obligations, such as compliance with anti-money laundering laws;
- As required by tax authorities or any competent court or legal authority.
- In this respect, we will share your personal data with the following:
- Our advisers where it is necessary for us to obtain their advice or assistance;
- Our auditors where it is necessary as part of their auditing functions;
- With third parties who assist us in conducting background checks;
- With relevant regulators or law enforcement agencies where we are required to do so.
Email marketing messages & subscription
Under the GDPR we use the consent lawful basis for anyone subscribing to our newsletter or marketing mailing list. We only collect certain data about you, as detailed in the “Processing of your personal date” above. Any email marketing messages we send are done so through an EMS, email marketing service provider. An EMS is a third party service provider of software / applications that allows marketers to send out email marketing campaigns to a list of users.
Email marketing messages that we send may contain tracking beacons / tracked clickable links or similar server technologies in order to track subscriber activity within email marketing messages. Where used, such marketing messages may record a range of data such as; times, dates, I.P addresses, opens, clicks, forwards, geographic and demographic data. Such data, within its limitations will show the activity each subscriber made for that email campaign.
Any email marketing messages we send are in accordance with the GDPR and the PECR. We provide you with an easy method to withdraw your consent (unsubscribe) or manage your preferences / the information we hold about you at any time. See any marketing messages for instructions on how to unsubscribe or manage your preferences, you can also unsubscribe from all MailChimp lists, by following this link, otherwise contact the EMS provider.
Your individual rights
Under the GDPR your rights are as follows. You can read more about your rights in details here;
- the right to be informed;
- the right of access;
- the right to rectification;
- the right to erasure;
- the right to restrict processing;
- the right to data portability;
- the right to object; and
- the right not to be subject to automated decision-making including profiling.
You also have the right to complain to the ICO [www.ico.org.uk] if you feel there is a problem with the way we are handling your data.
We handle subject access requests in accordance with the GDPR.
Some cookies are required to enjoy and use the full functionality of this website.
One key category of cookie that we use is Google Analytics which sets cookies to help us accurately estimate the number of visitors to our website and volumes of usage. This information helps us to improve our services and website. The data stored by these cookies can only be seen by Google’s and our relevant teams and never shows any confidential information.
Data security and protection
We ensure the security of any personal information we hold by using secure data storage technologies and precise procedures in how we store, access and manage that information. Our methods meet the GDPR compliance requirement.
Transparent Privacy Explanations
We have provided some further explanations about user privacy and the way we use this website to help promote a transparent and honest user privacy methodology.
Sponsored links, affiliate tracking & commissions
Clickable sponsored or affiliate links may be displayed as a website URL like this; www.thetafhotel.co.uk or as a titled text link like this: Bed & Breakfast in Whitland.
Clicking on any adverts, sponsored or affiliate links may track your actions by using a cookie saved to your device. You can read more about cookies on this website above. Your actions are usually recorded as a referral from our website by this cookie. In most cases we earn a very small commission from the advertiser or advertising partner, at no cost to you, whether you make a purchase on their website or not.
We may use advertising partners in these ways to help generate an income from the website, which allows us to continue our work and provide you with the best overall experience and valued information.
If you have any concerns about this we suggest you do not click on any adverts, sponsored or affiliate links found throughout the website.
Transfer and processing of your personal data outside the European Union
When sharing your personal data with third parties as set out in this Privacy Notice, it may be transferred outside the European
Union. In these circumstances, your personal data will only be transferred on one of the following bases:
- The country that we send the personal data to is approved by the European Commission as providing an adequate level of
protection for personal data;
- The transfer is to a recipient in the United States of America who has registered under the EU/US Privacy Shield;
- The recipient has entered into European Commission standard contractual clauses with us; or
- You have explicitly consented to the same.
If you have any questions, or wish to discuss this in more detail, please get in touch with us:
By post: (Registered Office) Fresh Brew Saint Lawrence Lodge, 37 Chamberlain Street, Wells, Somerset, BA5 2PQ
By phone: +44 7900 030 131
By email: firstname.lastname@example.org