1. Legal basis for processing

Data protection law states there are several legal reasons why a company may collect and process personal data. We work on the following bases for certain situations:

Contract – We will process your personal data to fulfil an order, deliver a service, essentially comply with our contractual obligations. An example might be, if you order a service for email delivery, we’ll collect your email address to deliver your purchase or pass them to the delivery company.

Legal Compliance – If the law or government requires us to, we may need to collect and process your data. An example might be passing on details of fraud to law enforcement.

Legitimate Interest – In some cases, we require personal data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business. This does not impact your freedom or rights. Examples might be using postal or email details to send direct marketing information by post telling you about products and services that we think might interest you. We may also use your purchase history to send or make available personalised offers.

We do not share the data that we collect directly from you with third parties for their own sales and marketing activity.

2. When do we collect personal data

•  When you visit any of our websites or speak to an account manager on the phone.
•  When you create a credit account with us.
•  When you purchase a product or service by phone but don’t have (or don’t use) an account.
•  When you engage with us on social media.
•  When you contact us by any means with queries, complaints etc.
•  When you enter prize draws or competitions.
•  When you book any kind of appointment with us or book to attend an event, for example a meeting to discuss an opportunity.
•  When you choose to complete any surveys we send you.
•  When you comment on or review our products and services.
•  Any individual may access personal data related to them, including opinions. So, if your comment or review includes information about the Partner who provided that service, it may be passed on to them if requested.
•  When you’ve given a third-party permission to share with us the information they hold about you.
•  Details that you provide us at networking events directly or where you have confirmed to the event organiser or other referring party that you are happy for your details to be shared.
•  From publicly available sources such as Companies House, websites, industry specific directories, press releases and so on.

3. The data we collect

•  Details of your interactions with us through phone contact, email or online. An example might be notes from conversations with you, complaint details, comments, purchase details and web visits.
•  Copies of documents you provide to prove marketing compliance This will include details of your full name, work address, telephone number, ICO number, data protection contact name.
•  Details of your visits to our websites, and which site you came from to ours.
•  Information gathered by the use of cookies in your web browser.
•  Payment card information. This is not stored for longer than it takes to transact
•  Your comments and product reviews.
•  To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed during your visit, the advertisements you clicked on, and any search terms you entered.
•  Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.

4. How we use your details

We want to give you the best possible customer experience. One way to achieve that is to get the richest picture we can of who you are by combining the data we have about you. We then use this to offer you promotions, products and services that are most likely to interest you.

The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.

Of course, if you wish to change how we use your data, you’ll find details in the ‘Your rights’ which can be found in section 12.
Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for.

Here’s how we’ll use your personal data and why:

• To process any orders that you make by using our sales team. If we don’t collect your personal data during ordering, we won’t be able to process your order and comply with our legal obligations. An example may be that your details are passed to a third-party, so they can deliver your purchased product or service that you ordered. We would then keep those details for reasonable period afterwards in order to fulfil obligations such as refunds, guarantees etc.

• To respond to your queries, refund requests and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.

• To protect our business and your account from fraud and other illegal activities. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We’ll do all of this as part of our legitimate interest.

• To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.

• We will use your personal data, preferences and details of your transactions to keep you informed by post, email or telephone about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on.

• To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, marketing data misuse issues, and contractually required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message.

• To administer any of our prize draws or competitions which you enter, based on your consent given at the time of entering.

• To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests.

• To comply with our contractual or legal obligations to share data with law enforcement.

• To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message.

Of course, you are free to opt out of receiving these requests or marketing from us at any time by updating your preferences with us.

Please visit https://fusion-dm.co.uk/opting-direct-marketing/

5. How are your details protected

We will treat your data with the utmost care and take all appropriate steps to protect it.

Access to personal data is limited to authorised personnel, password-protected and encrypted.

We regularly monitor our systems to identify ways to further strengthen security.

Physical access is limited to our premises and areas and equipment used for the storage or processing of data is further restricted to specific employees.

We make use of the latest firewall technology and systems and software updates.

6. Website users

What specific information is obtained?
Our website does not collect specific, detailed information about you as a visitor to our site. Where information is gathered, we will inform you of this along with the explanation of why it is required.

Are any payment details stored?
Payment card details are used solely for individual transactions to which they have been provided for.

What information is retained?
Cookies and tracking software are used on a temporary basis and expire when the site has been left. These are used for purposes such as website improvement. Google Analytics is also used for the same reason of website improvement and understanding how you use it. This information is not shared with anyone.

By using the website, you are consenting to the use of cookies to retain session information for the purposes listed above. This information is held in your web browser and is removed at the end of your session.
The personal information we collect and hold via Tracking software is the following:

• Browser used (Bing, Chrome, Internet Explorer etc.)
• Location (based on IP address)
• Gender
• Age group
• Site searches
• Device(s) used
• Frequency on Site
• Session duration (time spent on the site)
• Page(s) visited
• Page session duration (time spent on specific page)
• Web Surfing Behaviours

We currently use the following companies that may process your personal data through website usage. Facebook, Twitter, LinkedIn, Google, Infusionsoft.

If you need to contact us, you can find the relevant details here https://fusion-dm.co.uk/contact-our-team/

7.  The information we hold

We hold information about people and the businesses they work for necessary for us to conduct our business activities.

• Full Name
• Job title/function
• Company Name
• Company Address
• Company Website Address
• Email Address
• Phone Number
• Initial Requirement
• Transaction history
• Credit/finance history

8. How long will we keep your details

For direct marketing purposes we will keep your details and contact you while you remain a client and for up to six years from your last transaction. If you are an enquirer or prospect, we will keep your details for as long as they remain accurate and up to date. You can opt-out of receiving offers from us at any time.

For accounting purposes, we will keep transactional data for at least six years and dependent upon the requirements of any applicable legislation and government agency guidance.

9. Who might we share your details with

This information will not be shared with any organisation for their own benefit. We might share your details with contracted processors working on our behalf for example a company sending our own promotional material.

We may have a legal obligation to share your details with organisations such as HMRC and law enforcement agencies.
In this instance, we provide only the information required to perform the service. The data will only be used for that exact purpose.
Partners are required to protect and respect your privacy. If we stop using a partner’s service, your data will be deleted or anonymised.

Examples of third parties we work with are:

• Direct marketing companies who help us manage electronic communications, social media platforms such as Google or Facebook to show products that might interest you. This is based on consent or your acceptance of cookies on our website.
• Data Insight companies to ensure your details are up to date and accurate.
• IT Companies who support our website and business systems
• Data Suppliers who would deliver your ordered product.

10. International transfers

We might transfer your details outside of the EEA for the purpose of data processing. Examples of this might include:

• CRM systems
• Data cleansing and validation service providers
• Credit reference agencies
• Data management software solution providers
• Online/virtual server/back-up service providers

11. Automated decision making

We will not make use of your details for automated decision making.

12. Your rights

• The right to be informed. This obligates us to tell you when we collect your details what we will do with them, how we hold them and for how long for example within a data collection notice and this privacy policy.

• The right of access. If you ask us, we are obliged to let you know what details we have about you.
• The right to rectification. You can ask us to update or change the information we hold about you.
• The right to erasure. You can ask us to delete or suppress your details which we will do unless there is an overriding reason that means we must keep all or part of them.
• The right to restrict processing. You can ask to limit the way in which we use your details.
• The right to data portability. You can ask us for a copy of your details in a format suitable for you to provide to another organisation.
• The right to object. You can object to us holding your details, or the way in which we make use of them.
• Rights in relation to automated decision making and profiling.

13. Opting out

You can opt out of receiving direct marketing from us by a number of different means:
If we email you, click the unsubscribe link within the footer of the email.
If we call you, ask our member of staff to suppress your details.

If we write to you, call or write to us or visit our website
Call our Compliance Officer on 01494 642 951

Write to us The Compliance Officer, Fusion Datamarketing, Old Bank House, 39 High Street, High Wycombe, HP11 2AG

Visit our opt out page: www.fusion-dm.co.uk/opting-direct-marketing/

14. Our contact details

Fusion Datamarketing Ltd
Registered in England & Wales 7277066
Registered with the ICO ZA433168
Registered Office: 1 Buckingham Court, Dairy Road, Chelmsford, Essex, CM2 6XW

Trading Address:
Old Bank House, 39 High Street, High Wycombe, HP11 2AG
Telephone 01494 642 951

info@fusion-dm.co.uk

Contact us: https://fusion-dm.co.uk/contact-our-team/

15. The Information Commissioner’s Office

Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF

Helpline number: 0303 123 1113
www.ico.org.uk

If you are based outside the UK, please contact the relevant data protection regulator in your country.

Policy Updated – March 2019