Privacy Policy

Privacy Policy - Data Controller

‍Smart Lead Flow is a digital platform subscription service under UKB Marketing LTD (Company number: 11109859, Registered Address: The Coach House, 4 Dean Park Crescent, Bournemouth, Dorset, England, BH1 1LY).UKB Marketing LTD (“UKB Marketing”, “UKB”,  “us”, “we” or “our”) is committed to respecting your privacy and to complying with applicable data protection and privacy laws.You can visit our websites without disclosing any personally identifiable information about yourself (although please note that we may use cookies and collect other non-personally identifiable information about your browsing activity).If you do submit personal information by ordering products, services, registering for an event or completing a web form registration, for example, you can be assured that we will use your personal information only to support your continuing relationship with UKB Marketing and use of our services.We have provided this Privacy Policy Statement to help you understand how we collect, use and protect your information when you visit our websites and when you generally use our products and services.We wish to help you make informed decisions, so please take a few moments to read the sections below and learn how we may use your personal information.
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Personal Information Collection
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‍We endeavour to collect and use your personal information only with your knowledge and consent and typically when you order and subsequently use products and services, make customer enquiries, register for an event, register for information or other services, request product information, submit a job application or when you respond to communications from us (such as questionnaires or surveys).The type of personal information we may collect could include, for example, your name and postal address, date of birth, telephone number, email address, and credit/debit card information; lifestyle and other information collected on registration or through surveys.If you choose to provide us with personal information it will be used in support of the intended purposes stated at the time at which it was collected, and subject to any preferences indicated by you.
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Non-personal Identifying Information
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‍We may also collect non-personally identifying information about your visit to our websites based on your browsing activities. This information may include the pages you browse and products and services viewed or ordered for example. This helps us to better manage and develop our sites, to provide you with a more enjoyable, customised service and experience in the future, and to help us develop and deliver better products and services tailored to your individual interests and needs.From time to time, if you consented accordingly, we may also store and use your information to contact you for market research and marketing purposes. We may contact you by email, phone, SMS or mail.

‍How will we use your information?
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‍We may use your information for a number of purposes which includes: processing your orders and managing and administering your account; delivering any services, products or information requested by you; responding to complaints or account enquiries; administering debt recoveries; verifying your identity when required (you may lose your password or security information for example, and we may then need to ask you for other ‘identifiable’ information to protect your data from unauthorised access).We may also undertake market and product analysis based on your use of our services and products and contact you with information about new developments, products, services and special offers by post, telephone and automated means such as mobile text message (SMS), Email and the internet (subject to any preferences expressed by you).If you have consented to receive details of products and services, events and training you can contact us at any time to have your details removed from lists used by us for any or all of those purposes, to update your information or to otherwise tell us how you would like to receive information about our and/or third party products and services – the choice is yours.
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To update your marketing preferences please email dataprotection@ukbmarketing.com and quote your full name in the body of the email and tell us what you want us to do (i.e. ‘opt-out Email’, ‘opt-out SMS’ etc or if you have previously objected to receiving information by post for example, but would now like to change your mind and receive information then just say, ‘opt-in post’ in the subject header of your email).
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When will we disclose your information to others?
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‍We may only disclose information about you and contact details to (i) companies within the UKB Marketing LTD group for the purposes and subject always to the terms of this Privacy Policy Statement; (ii) in the event that we undergo re-organisation or are sold to a third party, in which case you agree that any personal information we hold about you may be transferred to that re-organised entity or third party for the purposes and subject to the terms of this Privacy Policy Statement.For the purposes of this Privacy Policy Statement, “UKB Marketing LTD group” means UKB Marketing LTD or any company or other entity in which UKB Marketing LTD owns (directly or indirectly) more than 50% of the issued share capital.Please note that UKB Marketing does not sell or pass your personal information to third parties (other than as set out in the paragraph above) unless you have given us permission or unless it is strictly necessary to deliver the products and services ordered or used by you and you are notified beforehand.For example, we may disclose your data to a credit card company to validate your credit card details and obtain payment when you buy a phone or other product or service.UKB Marketing may also be obliged to disclose your personal information to meet any legal or regulatory requirements (for example to comply with a court order) or obligations in accordance with applicable law.
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Social media, blogs, reviews
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‍Any social media posts or comments you send to us on the UKB social media pages or associated pages, for instance, will be shared under the terms of the relevant social media platform (e.g. Facebook / LinkedIn) on which they are written and could be made public. Other people, not us, control these platforms. We are not responsible for this kind of sharing. We recommend you should review the terms and conditions and privacy policies of the social media platforms you use. That way, you will understand how they will use your information, what information relating to you they will place in the public domain, and how you can stop them from doing so if you are unhappy about it.Any blog, review or other posts or comments you make about us, our products and services on any of our blogs, reviews or user community services will be shared with all other members of that service and the public at large. Any comments you make on these services and on social media in general must be not offensive, insulting or defamatory. You are responsible for ensuring that any comments you make comply with any relevant policy on acceptable use of those services.
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How long do we keep your information for?
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‍To make sure we meet our legal data protection and privacy obligations, we only hold on to your information for as long as we actually need it for the purposes we acquired it for in the first place.In most cases, this means we will keep your information for as long as you continue to use our services having expressed interest in them, and for a reasonable period of time afterwards if you stop doing so, to see if we can persuade you to come back to us. After that we will delete it other than where we lawfully can keep any data for audit or legal reasons.We shall keep data on our prospect database for not longer than 5 years from receipt subject to an individual’s right to unsubscribe or be forgotten at any time.

‍Access to your Information
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‍You can write to us at any time to obtain details of the personal information we may hold about you. Please write to us at dataprotection@ukbmarketing.com. Please quote your name and address together with your mobile and/or email address (if relevant). We would be grateful if could also provide brief details of what information you want a copy of (this helps us to more readily locate your data). We will take all reasonable steps to confirm your identity before providing you with details of any personal information we may hold about you.

‍Information Security
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‍UKB Marketing recognises that its customers are increasingly concerned about how companies protect personal information from misuse and abuse and about privacy in general. UKB Marketing is constantly reviewing and enhancing its technical, physical and managerial procedures and rules to protect your personal data from unauthorised access, accidental loss and/or destruction. We use industry standard TLS certificates to provide encryption of data in transit and when personal data is held our Members Area.Please be aware that communications over the Internet, such as emails/webmails, are not secure unless they have been encrypted. Your communications may route through a number of countries before being delivered – this is the nature of the World Wide Web/Internet. UKB Marketing cannot accept responsibility for any unauthorised access or loss of personal information that is beyond our control.
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‍Privacy Support
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‍UKB Marketing reserves the right to amend or modify this Privacy Policy Statement at any time and in response to changes in applicable data protection and privacy legislation.If we decide to change our Privacy Policy, we will post the changes on our website so you know what information we collect and how we use it. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will tell you. You will have a choice as to whether or not we are able to use your information in this different manner.If you have any enquiry about UKB's privacy policy or practices, please email us at dataprotection@ukbmarketing.com.
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Monitoring and or recording of all your Communications
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‍Monitoring or recording of your calls, emails, text messages and other communications may take place in accordance with UK law, and in particular for business purposes, such as for quality control and training, to prevent unauthorised use of UKB Marketing's websites, to ensure effective systems operation and in order to prevent or detect crime.

Privacy Policy - Data Processor

Smart Lead Flow is a digital platform subscription service under UKB Marketing LTD (Company number: 11109859, Registered Address: The Coach House, 4 Dean Park Crescent, Bournemouth, Dorset, England, BH1 1LY).UKB Marketing LTD (“UKB Marketing”, “UKB”,  “us”, “we” or “our”) is committed to respecting your privacy and to complying with applicable data protection and privacy laws. Please read this policy (the “Privacy Policy”) carefully to learn more about UKB Marketing’s privacy practices and policies with respect to Customer Data (defined below) that is collected and used through the Smart Lead Flow Internet application (the “Web App”), mobile application (the “Mobile App”), or administrative interface (collectively, the “Smart Lead Flow Service”). This Privacy Policy applies to “Personal Data,” which is Customer Data that is associated with an identified or identifiable natural person and is protected as personal data or personal information under applicable data protection law. 
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UKB Marketing is a Data Processor/Service Provider for its customers

‍UKB Marketing customers, and not UKB Marketing, determine how and why Personal Data submitted to the Smart Lead Flow Service is used, either by or at the direction of such customers. With respect to such Personal Data, (1) UKB Marketing is a “data processor” (“Data Processor”) under the EU General Data Protection Regulation (“GDPR”), and (2) UKB Marketing’s customers are the controllers under GDPR. (“Data Controller”). This Privacy Policy describes how UKB Marketing processes Personal Data as a Data Processor for the purpose of providing the Smart Lead Flow Service to our customers pursuant to the applicable data processing terms with those customers.As Data Controllers, UKB Marketing’s customers are responsible for disclosing the rights of individuals (“Data Subjects”) with respect to their Personal Data and other information regarding the collection and use of that Personal Data, in accordance with the GDPR, and other laws requiring such disclosures.  
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Scope of this Privacy Policy

‍This Privacy Policy covers the processing of Personal Data that UKB Marketing performs as a Data Processor for and on behalf of its customers. Insofar as it acts as a Data Controller, UKB Marketing processes personal data in accordance with the above Data Controller Privacy Policy.   
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Personal data processed under this policy

‍UKB Marketing acts as a Data Processor with respect to any Personal Data comprised in the Customer Data.  By “Customer Data” we mean the content or information which individuals authorised by a customer submit to the Smart Lead Flow Service. 
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Use of your personal data

‍UKB Marketing uses the Personal Data to provide the Smart Lead Flow to our customers pursuant to the applicable data processing terms with those customers. 
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Disclosing your personal data

‍UKB Marketing does not disclose your Personal Data to third parties except where permitted or requested by our applicable customer, or where required by law.

‍No Sale of Personal Data

‍UKB Marketing does not sell, rent or lease your Personal Data.
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Service Providers

‍UKB Marketing may disclose your Personal Data to our contracted service providers so that they can provide UKB Marketing with services, such as IT, system administration and hosting, and customer support.

UKB Marketing will, to the extent required by law and the applicable customer contract, obtain assurances before disclosing Personal Data to a subcontractor or third-party agent that the recipient will: (a) use the Personal Data only to assist UKB Marketing in providing, maintaining or improving the UKB Marketing Service, (b) provide at least the same level of protection for Personal Data as is required of UKB Marketing, and (c) notify UKB Marketing if the recipient is no longer able to provide the required protections. Upon notice, UKB Marketing will act promptly to endeavour to stop and remediate any unauthorised processing of Personal Data by the recipient. UKB Marketing will remain liable for onward transfers to its subcontractors and third-party agents.
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Security of your personal data

‍As specified in the data processing terms with the applicable Data Controller, UKB Marketing takes reasonable and appropriate measures to protect your Personal Data from loss, misuse, and inappropriate access.  We use standard, industry-wide practices such as firewalls, encryption of Customer Data at rest and in transit, and (in certain areas) Secure Socket Layers (“SSL”) to protect your information.  However, as effective as encryption technology is, no security system is impenetrable. UKB Marketing cannot guarantee the security of our databases, nor can we guarantee that information you supply won't be intercepted while being transmitted to UKB Marketing over the Internet.
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Data Retention

‍Storage periods depend on the data processing terms with our customers and their choices, type of Personal Data, purposes of its collection and processing, and applicable law.
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Children

‍UKB Marketing does not direct the UKB Marketing Service and associated website at children. We do not knowingly collect Personal Data from children under the age of 16. If you are a parent or guardian and believe your child has provided us with Personal Data without your consent, please contact us at dataprotection@ukbmarketing.com.
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Data Subjects in the EU and UK

‍Rights and requests:
Data subjects in the EU and United Kingdom may have certain rights regarding the processing of their Personal Data. You can obtain information about the applicable rights and how to exercise them from the relevant customer that is the Data Controller of your Personal Data. Access Within the scope of our authorization to do so, UKB Marketing will work with its customers, the Data Controllers, to support them in providing their Data Subjects access to their Personal Data that UKB Marketing holds on behalf of its customers. 
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Corrections
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UKB Marketing will take reasonable steps to enable individuals, in connection with its customers, to correct, amend, or delete Personal Data that is demonstrated to be inaccurate.
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Questions and Other Requests
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If you have further questions about the collection, retention and use of your Personal Data, about your choices and rights regarding such collection, retention and use, or wish to exercise your rights under applicable law, you should contact the UKB Marketing customer that is the Data Controller of your Personal Data (this may be your employer). We will forward any such communications to our customer, provide you with contact information for the customer, and work with the customer to address your questions and/or facilitate your choices and rights as appropriate.
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If you have questions about our role as a Data Processor, you can contact us via email at dataprotection@ukbmarketing.com. 
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Complaints
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UKB Marketing may be able to assist you in resolving any complaints about the collection or use of your Personal Data. We will forward your complaint to the relevant customer (often the employer associated with that account), which is the Data Controller of that Personal Data. You may wish to reach out to the Data Controller before contacting UKB Marketing, as the Data Controller may be in the best position to resolve your issue.
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Changes/Updates

‍UKB Marketing reserves the right to update or modify this Privacy Policy at any time without prior notice. Any updates will be posted on the Smart Lead Flow website.