Introduction

Whistl understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website www.leafletdrop.co.uk (“Our Site”).

This privacy policy aims to give you information on how Whistl collects and processes your personal data through Our Site, including any data you may provide through this website when you sign up to it or purchase services through it.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them. By using this site you are accepting the practices described in this policy.

1. Information About Us

1.1 Our Site is owned and operated by Whistl (Doordrop Media) Limited a limited company registered in England under company number 00613278, whose registered address is Meridian House, Fieldhouse Lane, Marlow, Buckinghamshire SL7 1TB (“We/Us/Our”). We are the controller and are responsible for your personal data.  

1.2 Our VAT number is GB991 2657 87

1.3 For any enquiries about this privacy policy please contact GDPR@whistl.co.uk, by telephone on 01628  891644, or by post at Meridian House, Fieldhouse Lane, Marlow, Buckinghamshire, SL7 1TB.

1.4 We are a member of each of the DMA, IPM, Print Power, ELMA, RHA and MCF

1.5 Information Commissioner's Office (ICO) Registration number is: Z6928643

2. What Does This Policy Cover?

2.1 This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

2.2 Please refer to our Compliance Statement for additional information about our approach to Data Protection: https://www.whistl.co.uk/news/whistl-gdpr-compliance-statement/ 

3. Your Rights

3.1. Under certain circumstances, you have rights under data protection laws in relation to your personal data, which this privacy policy and our use of personal data have been designed to uphold:

3.1.1. Right to be informed – When we collect your data we have to tell you what we are going to do with it primarily through this Privacy Policy.

3.1.2. Right of access– You have the right to contact us in writing to request details of the information we hold about you.

3.1.3. Right of rectification– You have the right to ask us to rectify information that we hold about you if this is inaccurate or incomplete.

3.1.4. Right to erasure- This is also known as the right to be forgotten and gives you the right to request your information to be removed if there is no compelling reason for its continued processing. A word of warning though, we keep a list of people who have asked not to be contacted which is used to ensure that you receive no further marketing information from Whistl or client from the result of our activity. Without this list your data could enter our system again from another source and we would have no record of the fact that you asked us not to contact you.

3.1.5. Right to restrict processing– this is the alternative to erasure and gives you the right to tell us to stop processing your data but allowing us to keep enough information about you to ensure that your wishes are respected in the future.

3.1.6. Right to data portability – this gives you the right to ask the holder of your information to transfer that information to another business. This right would be most commonly used if you were switching banks, insurance companies, utility companies or mobile phone companies.

3.1.7. Right to object– you have the right to object to the processing of your data for marketing purposes and profiling for marketing purposes. Your rights and freedoms override our interests.

3.1.8. Rights related to automated decision making including profiling– we do not use automated decision making processes which would have a potentially damaging effect on the information we hold about you. But if we did you have the right to obtain human intervention, express your point of view and obtain an explanation of the decision and challenge it.

3.1.9. Rights to withdrawn consent at any time where relevant– you have the right to withdraw your consent to the processing of your information at any time and we must provide you with the information to need to do so at the time we collect your data and each time we contact you.

3.2 You have the right to make a complaint at any time to the ICO (the UK supervisory authority for data protection issues (www.ico.org.uk)). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

4. What Data Do We Collect?

4.1. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

4.2. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, last name.

Contact Data includes billing address, delivery address, email address and telephone number.

Transaction Data includes details about payment amounts to and from you and other details of products and services you have purchased from us.

Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

Profile Data includes your user journey (I.E the areas of the site you have visited), purchases or orders made by you, feedback and survey responses.

Usage Data includes information about how you use our website, products and services.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Payments to Whistl from you will be made through a Worldpay system. You will need to insert details in that system but we will not collect or store them since it is a separate system.

4.3. We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

4.4. We do not collect any Special Categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

4.5. Where we need to collect personal data by law, or under the terms of a contract we have with you, and you do not provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

5. How we collect your personal data

5.1 We use different methods to collect data from and about you including through:

5.1.1. Direct interactions. You may give us your identity, transaction, profile, usage, marketing and communications and Contact data when you:

  • use any of the tools on Our Site;
  • order any services through Our Site;
  • create an account on Our Site;

5.1.2. Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, [server logs] and other similar technologies. [We may also receive Technical Data about you if you visit other websites employing our cookies.] Please see our cookie policy for further details.

5.2 You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see [insert link]

6. International Transfers

We do not transfer your personal data outside the United Kingdom.

7. How Do We Use Your Data?

7.1. We will only use personal data when the law allows us to. Most commonly, we will use your personal data as follows:

7.1.1. where we need to perform the contract that we have entered into with you;

7.1.2. where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;

7.1.3. where we need to comply with a legal obligation.

7.2. We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

7.3. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer

(a) Identity

(b) Contact

(c) Marketing and communications

Performance of a contract with you

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

 (d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(e) Usage

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) 

(a) Identity

(b) Contact

(c) Technical

(d) Profile

(e) Usage 

(f) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

(c) Profile

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business)

7.4. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

7.5. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

7.6. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

7.7. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

7.8. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. How We Keep Your Data Secure?

8.1. Data security is very important to us, and to protect your data we have taken suitable measures to safeguard and secure any data we hold about you.

8.2. Whistl secures your personal information from unauthorised access, use or disclosure. Whistl secures the personally identifiable information you provide on computer servers in a controlled, secure environment, protected from unauthorised access, use or disclosure. When personal information (such as a credit card number) is transmitted to other Web sites, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol.

9. Data Sharing

We may share your personal data with the following organisations and for the reasons set out in the table below:

Party

Personal Data

Activity

Purpose

Rawnet ltd

Name, address, telephone, email

Full access to our onsite CRM. 

The purpose is to provide appropriate and tailored digital marketing methods.

Gecko

Name, address, telephone, email

Full access to our onsite CRM. 

The purpose is to host and maintain the website.

 

10. How long will you use my personal data for?

10.1. We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

10.2. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

10.3. Whistl will hold your data for up to 2 years once your usage has become inactive. The purpose of this is to market tailored offers and service updates to you. You have the right to be deleted from the system and the right to be forgotten at any time.

11. How Can You Access Your Data?

You have the right to ask for a copy of any of your personal data held by us (where such data is held under GDPR, no fee is payable and we will provide any and all information in response to your request free of charge. Please contact us for more details at GDPR@whistl.co.uk, or using the contact details below in section 9.

12. Contacting Us

If you have any questions about Our Site or this Privacy Policy, please contact us by email at GDPR@whistl.co.uk, by telephone on 01628 891644, or by post at Meridian House, Fieldhouse Lane, Marlow, Buckinghamshire, England, SL7 1TB. Please ensure that your query is clear, particularly if it is a request for information about the data we hold about you.

13. Changes to Our Privacy Policy and to Your Personal Data

13.1. We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.

13.2. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

14. Implementation of Policy

This Policy shall be deemed effective as of 12th March 2019. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.

This Policy has been approved and authorised by:

Name:

Stephen A Betts

Position:

Director Security and GDPR

Date:

12th March 2019

Due for Review by:

12th March 2020

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