Privacy Policy

1. About this document
   
   1. Your personal privacy is of great importance to us. We will only use your personal information in accordance with this privacy policy ("Policy").
   2. We are Starfeb Ltd trading as Marketing Engine, our registered office address is Southfield, 71d Stanhope Road South, Darlington, England, DL3 7SF ("we", "us", "our"). By using the Marketing Engine platform (the "Platform"), using our services, visiting or registering via our website or otherwise engaging with us, you're agreeing to be bound by this Policy. You should read this privacy policy carefully so that you understand how we will handle your personal information.
   3. During the course of our activities we will process personal information (which may be held electronically, or otherwise) about you, and we recognise the need to treat it in an appropriate and lawful manner, in accordance with the UK's General Data Protection Regulation ("UK GDPR"). The purpose of this privacy policy is to explain to you how we will handle your personal information.
   4. If you have any questions regarding this Policy you can contact our Data Protection Representative, Aimee Philipson via email at hello@wearemarketingengine.com
   5. We are registered with the Information Commissioner's Office under registration number ZB676153.
      
      
2. What information do we collect about you? 
   
   1. Personal data means any information about an individual from which that person can be identified. It does not include data which has been anonymised or data which relates to a corporate entity. 
   2. We will collect personal data from you when you sign up to the Platform, interact with our social media platforms, buy a service or product from us, sign up for our newsletter, make enquiries or otherwise provide us with your personal data. 
   3. The categories of personal information we may collect for the purpose of managing your engagement with us include:-
      
      1. Contact Data: Your name and title, personal or professional address, telephone number(s), e-mail address and any other contact details you may provide;
      2. Identification Data: Your first name, last name and title, your login credentials, your internet protocol (IP) address and information regarding which website pages you accessed and when;
      3. Marketing and Communications Data: We may collect information about your marketing preferences if we are entitled to send you marketing materials, your communication preferences and your preferences in respect of third party marketing;
      4. Technical Data: We may collect Google Analytics data including website traffic, user behaviours, audience demographics and device and browser usage data. We may also collect device information including model and operating system, Platform and website usage patterns and data from cookies and similar tracking technologies;
      5. Financial Data: Includes bank account and payment card details; and
      6. Transaction Data: Includes details about products and services you have purchased from us.
         
         
3. How we collect your personal information
   
   1. We will collect your personal information in the following ways:
   2. Information you give us. This is information (including Contact Data and Identification Data) you provide to us by: visiting our website, downloading and using our Platform, signing up to our newsletter, using our services or products or contacting us for any reason. We will also get some of this information by you corresponding with us (for example, by email or text, or using social media messaging services).
   3. Information acquired through automated technologies or interactions. As you interact with our Platform and website, we will automatically collect personal data about you that distinguishes you from other users by using cookies. Please see our Cookie Policy on our website for more details [LINK]. We also use artificial intelligence (AI) which tracks your use of our Platform and analyses results so that we can improve our services, your personal data will be anonymised before being processed.
   4. Information we observe. We will gather personal information about you through the monitoring of our systems including use of the Platform and our website.
   5. Information we create. We will create personal information, where relevant, about you during the course of your subscription such as if you make a bespoke request or provide feedback about the Platform.
      
      
4. Why we collect personal information about you and how we use that information
   
   1. We process your personal information for a variety of commercial purposes and will also process your personal information where necessary to comply with any statutory duties, to which we are subject.
   2. In the table below, where we outline the lawful basis (processing condition) which we rely on to use your personal information, a number of bases are mentioned for processing personal information. All data needs one of the "General" processing conditions. The key to the lawful bases is set out below the table.
   3. The purposes for which we process your personal information and the lawful bases for such processing are as follows:

1. All data We use the following processing conditions:
   
   1. Consent: your consent to one or more specific purposes.  We will set out the basis for consent in a consent notice or in some other form of notice where it is clear we are asking for your consent.  Where we do not get your consent, we will not use your data for that purpose;
   2. Contract: it is necessary to process your data for the performance of a contract to which you are party or to meet our obligations under the contract;
   3. Legitimate interests: we’ve identified this type of processing is a legitimate interest of ours or a third party to give you the best and most secure service and to provide you with the best service/product; we consider that use of your personal information is necessary to achieve that legitimate interest; and we’ve balanced all that against your interests, rights and freedoms.  We set out more detail on our legitimate interest processing below at section 4.5;
2. Our Legitimate Interests We sometimes process personal information on the basis that it is in our legitimate interests to do so. The occasions where we will rely on legitimate interests as our processing condition are set out above. The legitimate interests are as follows:
   
   1. To maintain up to date information about you: we sometimes gather data about you which is useful for building a complete view of your use of the Platform and our website. Although some of this data is not strictly required by law, it is nevertheless useful to us and we consider it in our legitimate interest of running a successful, profitable business.
   2. To ensure our website and Platform are operating correctly and to improve our services: we will monitor the operation and effectiveness of our website and Platform to ensure the effective running of our business.
   3. Network and information security: we will monitor our network and your use of it.  It is a legitimate interest of ours to make sure that your use of our network and systems does not compromise our information security.
   4. To procure insurance policies and to respond to and defend legal claims: it is in our legitimate interests to use your personal information where necessary in the purchase of insurance policies and to respond to and defend legal claims.
3. Disclosures of your personal data 
   
   1. We may share your personal data with the parties set out below for the purposes set out in the table at 4.3 above. 

External Third Parties: Service providers who provide us with services such as (without limitation) assisting us with customer and technology support, payment services, hosting services, fraud prevention and marketing, data enhancement.

For example, we use:

• Parallax Agency Limited, technical support, UK. 

Other service providers we may instruct include:

• [Professional advisers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.]
• [Administrative providers including the printing and postage of hard copy documents or correspondence, and call centres able to support customer services and marketing functions.]
• [HM Revenue & Customs, regulators and other authorities based in the UK who require reporting of processing activities in certain circumstances.]
  
  

6. Ensuring your personal information is accurate We will keep the personal information we store about you accurate and up to date. We will take every reasonable step to erase or rectify inaccurate data without delay. Please tell us if your personal details change or if you become aware of any inaccuracies in the personal information we hold about you. We will contact you from time to time to check your details are still up-to-date. We will also contact you if we become aware of any event which is likely to result in a change to your personal information.
7. Retaining your personal information We will not keep your personal information for longer than is necessary for the purpose(s) for which we process it. This means that information will be destroyed or erased from our systems when it is no longer required. For guidance on how long certain information is likely to be kept before being destroyed, contact the Data Protection Representative by email at hello@wearemarketingengine.com. For further information on the retention of your personal information, please contact the Data Protection Representative.
8. What rights do you have in respect of your personal information?
   
   1. You have the right to:
      
      1. Request access to any personal information we hold about you: 
         
         1. You have a right to access a copy of your own personal information.  We try to respond to all requests within one (1) calendar month. Occasionally, it may take us longer than a month if your request is particularly complex or if you have made a number of requests. In this case, we will notify you and keep you updated on the progress of your request. 
         2. We will request information from you in order to help us confirm your identity and ensure you have a right to access the personal information you have requested to see. This is a security measure to ensure that we do not disclose personal information to any person who has no right to receive it. We may also contact you to ask for further information in relation to your request.
         3. You will normally not have to pay a fee to access your personal information. However, we may charge a reasonable fee if your request is clearly unfounded or excessive (particularly where requests are repetitive). Alternatively, if your request is clearly unfounded or excessive, we may refuse to comply with your request.
      2. Require us to rectify any personal information which we hold about you which is inaccurate.
         
         1. Rectification enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. 
      3. Have personal information erased, in certain circumstances.
         
         1. This right enables you to have your data erased (the so-called "right to be forgotten").  The right relates only to personal information we hold at the time you make the request.  There are also some important restrictions on this right.
         2. The right to have personal information erased applies where:-
            
            1. our use of your personal information is no longer necessary for the purpose for which we gathered it.  Most of the personal information we hold about you in the course of your engagement with us and the Platform is needed by us to manage you as a customer, website or Platform user or social media visitor. However, we will review the information we hold about you if you ask us to erase it, to check we need all of the information we hold;
            2. we have relied on consent as the basis for processing and you withdraw your consent;
            3. we are processing your personal information on the basis of legitimate interests unless we have an overriding interest to continue the processing;
            4. we are processing your personal information unlawfully;
            5. we have to do it to comply with a legal obligation.
         3. The right to erasure does not apply in certain circumstances including where:
            
            1. we have to process the personal information to comply with a legal obligation; or
            2. where we use the personal information to carry a task in the public interest such as where we are investigating fraud or preventing or detecting other unlawful acts.
      4. Have the processing of your personal information restricted, in certain circumstances.
         
         1. This enables you to ask us to suspend the processing of your personal information in the following scenarios:
            
            1. if you want us to establish the information's accuracy;
            2. where our use of the information is unlawful but you do not want us to erase it;
            3. where you need us to hold the information, even if we no longer require it as you need it to establish, exercise or defend legal claims; or
            4. you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.
      5. In certain circumstances, be provided with the personal information that you have supplied to us, in a portable format that can be transmitted to another controller without hindrance.
         
         1. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you
      6. Object to certain types of processing, including legitimate interests based processing and automated processing (which includes profiling) 
         
         1. where we are processing your personal data on the basis of legitimate interests and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your interests, fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your interests, rights and freedoms or that the processing is required for the establishment, exercise or defence of legal claims.
      7. The right to withdraw consent
         
         1. If we are processing any of your personal information based on you having given us consent to do so, you have the right to withdraw that consent at any time. However, this will not affect the lawfulness of any processing we may have undertaken based on your consent before it is withdrawn.
   2. If you wish to exercise any of the rights set out above, you must make the request in writing to the Data Protection Representative by email at hello@wearemarketingengine.com.
   3. If you provided your consent to any of the processing of your personal information, you have the right to withdraw your consent to that processing at any time, where relevant. Please contact the Data Protection Representative by email at hello@wearemarketingengine.com if you wish to do so.
9. How we keep your data secure
   
   1. Keeping your data secure is important to us. We use reasonable and up to date security methods to keep your personal information secure and to prevent unauthorised or unlawful access to your personal information, and against the accidental loss of, or damage to, personal information.
   2. Maintaining data security means guaranteeing the confidentiality, integrity and availability (for authorised purposes) of the personal information.
   3. We have in place procedures and technologies to maintain the security of all personal information from the point of collection to the point of destruction. These include adhering to various security standards, including physical and technological protection, data encryption, patching and software update management, management of access rights, vulnerability scanning and penetration testing, network configuration and monitoring. We will ensure your personal information is only accessible by those who need to see your information for their specific role. We will only transfer personal information to a third party if that third party agrees to comply with those procedures and policies, or if they put in place adequate measures themselves.
10. Providing information to third parties
    
    1. Our employees who need to access your data will view it in order that we can manage your engagement with us and comply with our legal and statutory duties. All of our employees have been trained in data protection and understand the need to keep your information confidential.
    2. In addition to our employees, we also use third-party providers who may process personal information on our behalf to fulfil our promise to you. These providers are carefully selected professional contractors (such as your appliance engineer) who help us provide you with our services and will only collect, use and disclose your information to the extent necessary to allow them to perform these services. We have legally binding contractual agreements in place with any providers we may use to ensure that your data is secure at all times and cannot be accessed for any other purpose.  
    3. Apart from our employees and third-party providers, we will not disclose your personal information to a third party without your consent unless we are satisfied that they are legally entitled to the data. Where we do disclose your personal information to a third party, we will put in place arrangements to make sure your information is well protected and processed strictly in accordance with data protection laws.
    4. We may disclose your personal information to third parties:
       
       1. in the event that we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets;
       2. if we or substantially all of our assets are acquired by a third party, in which case personal information held by us will be one of the transferred assets; and
       3. if we are under a duty to disclose or share your personal information in order to comply with legal obligations or to protect our rights, property, or safety of our customers, suppliers or other employees. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
    5. If your personal information is provided to any third parties, you are entitled to request details of the recipients of your personal information or the categories of recipients of your personal information.
11. Transferring your personal information outside the United Kingdom
    
    1. We will not transfer your personal information outside the UK unless such transfer is compliant with the UK GDPR. This means that we cannot transfer any of your personal information outside the UK unless:
       
       1. the UK government has decided that another country or international organisation ensures an adequate level of protection for your personal information or the data is being transferred to a company in the US which has signed up to the UK-US data bridge; or
       2. the transfer of your personal information is subject to appropriate safeguards, which may include:
          
          1. binding corporate rules; or
          2. the International Data Transfer Agreement or the UK Addendum.
       3. one of the derogations in the UK GDPR applies (including if you explicitly consent to the proposed transfer).
12. Breaches of data protection laws If you consider that we have not complied with data protection laws in respect of personal information about yourself or others, you should raise the matter with our the Data Protection Representative email at hello@wearemarketingengine.com. Any breach of the UK GDPR will be taken seriously.
13. Right to lodge a complaint If you have any issues with our processing of your personal information and would like to make a complaint, you may contact the Information Commissioner's Office on 0303 123 1113 or at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

‍

‍