We aim to respect your privacy and are committed to protecting the confidentiality of your personal information. Our aim is to be as clear and open as possible about what we do and why, which is why we go in-depth below to explain what we collect, send and use your data for and what your rights are.
These definitions should help you understand this policy and add clarity to any terms/labels we use. When we say “we,” “us,” “our” and “Spotler” we are referring to Spotler Limited. We are incorporated in England and Wales, providing online platforms and services (commonly referred to as Marketing Automation Software or an Email Service Provider) that you may use to market to or stay in contact with your database (your prospects, leads, customers, etc…). When we say “Customer,” we are referring to the person or entity that is registered with us to use the Service. With regards to “Service” we are referring to our products/software and physical services, like consultancy or email template design. When we say “you,” we are referring either to a Customer or to some other person who visits our Website. A “Contact” is a person you contact through our Service, or a person who you might choose to contact at some point in the future through the use of our Service. Simply speaking, a Contact is anyone on your database that you have passed over to our Service (in to an “Audience Group”) or about whom you have given us information. “Personal Information” means any information that identifies or can be used to identify you or a Contact, directly or indirectly, including, but not limited to, first and last name, email address, occupation or other demographic information. An “Audience Group” is a list of Contacts and all associated information related to those Contacts.
- Questions, Concerns & Contact Information
If you have any questions or comments, or if you want to update, delete or change any Personal Information we hold, or you have a concern about the way in which we have handled any privacy matter, please contact our Data Protection Officer (DPO) through the following ways:
Data Protection Officer: Lee Chadwick
Post: Spotler Limited, 3 The Billings, Walnut Tree Close, Guildford, Surrey, GU1 4UL
Phone: 01483 411911
General email: info@Spotler.co.uk
We process your personal data primarily on the basis of Legitimate Interest as a business but only if necessary for the purpose we collected it for. We will also process data on the basis of contractual and transactional obligation where necessary. We may process your data for;
- Sales and marketing activities such as calls, emails and other types of communications
- Understanding how you interact with the website and social media
- Account activity such as, email, written and verbal communications and agreements
- Financial activity, such as billing communications
- To perform obligations under a contract with you or a business you may work for
We will only store your data, for as long as we need it to undertake any of the processes listed above.
5. How we Collect Information About You
a. About You: When you sign up for and use the website or Service, consult with our customer service team, send us an email, post on our blog, or communicate with us in any way, you are voluntarily giving us information that we collect.
c. IP address lookup: We use third parties to provide information about visitors to our websites. When you visit our website we will record your IP address. This address will be matched against public and proprietary IP address databases to provide us with information about your visit. This information may identify the organisation to whom the IP address is registered but not individuals. In some limited cases i.e. single person companies, it may be possible to identify personal data from publicly available ICANN data.
d. Cookies, tracking & beacons: We may use various technologies to collect and store information when you use our website or Service, and this may include using cookies and similar tracking technologies, such as pixels and web beacons, to analyse trends, administer the website, track users’ movements around the website and Service, serve targeted advertisements, and gather demographic information about our user base as a whole.
Cookies/tracking: Cookies allow us to provide important site functionality, so you don’t have to re-enter lots of information. They also allow us to remember what links and pages have been clicked or viewed during a session. If you have provided us with personal data, completing a contact form for example, we may associate this personal data with other information. This will allow us to identify and record what is most relevant to you.By using your browser controls, you are always in control of the cookies we store and access on your computer. More information on how to control cookies and limit personal data processing can be found at youronlinechoices.com/uk/five-top-tips. For comprehensive information on how to change your cookie settings in a wide variety of different web browsers, visit www.aboutcookies.org.
Spotler’s main cookies:
Google Analytics Cookies: Google Analytics is a website monitoring tool that allows users to see volumes of website visitors, their source, and to analyse how the content of their website is viewed and navigated. This in turn allows optimisation of the content and pages and the marketing programs that drive traffic to the website. Google Analytics does not store any personal information about website visitors, but does use persistent cookies to identify repeat visitors. You may universally opt-out of all Google Analytics tracking used by all websites by visiting the following url – https://tools.google.com/dlpage/gaoptout
This information is used by Spotler to profile website visitors, in order to better understand the way in which our website content is viewed by different segments. It is also used, for example, to identify the types of organisations that might be interested in attending our Best Practice Seminars.
Email Marketing Post-Click Tracking Cookies: These cookies are used to report on the pages that have been viewed by visitors to the site who have followed links from our email marketing campaigns. This analysis helps us to understand additional content that is viewed by the contacts in our database and therefore allows us to improve and tailor future campaigns to those contact’s specific areas of interest.
Beacons/Pixels: On our website and in our emails we use web beacons. When we send emails to Customers, we may track behaviour such as who opened the emails, who clicked the links and which pages of our website they have visited.
This allows us to measure the performance of our email campaigns and to improve our Service and website. To do this, we include single pixel, also called web beacons, in emails we send. Web beacons allow us to collect information about when you open the email, your IP address, your browser or email client type, and other similar details. We also include Web Beacons in the emails we deliver for you. We use the data from those Web Beacons to create reports about how your email campaign performed and what actions your Contacts took. Reports are also available to us when we send email to you, so we may collect and review that information.
e. Data sources: Other than the aforementioned ways of obtaining data (form fills on the website, cookies, verbal and written) we may obtain information about you from third party sources, such as public databases, data service companies, social media platforms, third party data providers and our joint marketing partners. We take steps to ensure that such third parties are legally permitted or required to disclose such information to us.
Examples of the information we may receive from other sources include: demographic information, device information (such as IP addresses), location, email address, contact number, technographics, and online behavioural data (such as information about your use of social media websites, page view information, and search results and links). We use this information, alone or in combination with other information (including Personal Information) we collect, to enhance our ability to provide relevant marketing and content to you and to develop and provide you with more relevant products features, and services.
f. Who will see your data: Your data will only be seen and used by employees of Spotler. We operate a role-based access policy for personal data. What this means, is that an employee will only have access to personal data, if they need that access to do their job. We do not share the personal data of prospects or clients with any third parties.
We may disclose Personal Information and use personal data acquired from and provided by yourself to fulfil any of your requests and to send you appropriate and useful communications. You should be aware this includes, but not limited to, the types of communications explain in section 6, b, point 1.
A copy of our legitimate interests ‘balancing test’ is available on request as part of our commitment to managing your information rights. Please use the details at the start of the page to request this.
We use your data for the following purposes:
a) To promote use of our products and services to you. For example, if we collect your Personal Information when you visit our website and do not sign up for any of the Service, we may send you an email inviting you to sign up or attend an event. If you use any of our Service or website and we think you might benefit from using another part of our Service we offer, we may send you an email about that. You can stop receiving our promotional emails by following the opt-out link included in every email we send.
b) To send you informational and promotional content in accordance with your marketing preferences. You can stop receiving our promotional emails by following the opt-out instructions included in every email.
- Types of communications: By processing your Personal Information under Legitimate Interest, you will receive any specific piece(s) of information you requested, as well as allowing us to send you appropriate and useful communications.This includes but is not limited to; invitations to our industry leading events and webinars, our latest assets (whitepapers, guides, reports, infographics, videos and case studies) and promotional offers on software and services. We would also like to keep you abreast of the charity events and initiatives we partake in.If you are a Customer of Spotler, you will also receive monthly product updates. These updates will highlight the great new releases we have developed. If you have signed up to our fantasy football league, you may also receive an email or two about how good (or bad!) we are performing against you and the prize(s) you may have won.At any time, you can update your preferences (or completely unsubscribe/opt-out of our marketing) by clicking the opt-out link in any emails you receive from us. The link will always be in the footer of the email. You can also stop receiving emails from us using that same link. If you don’t have an email from us to hand and want to update your preferences, fill in the form below. We will send you an email for you to change your preferences as you wish.
- Types of Channel: Within your preference centre you can also specify which channel(s) you would prefer to be contacted on, or you can opt-out completely. The three channels you will have option on are: email, SMS and Post.
c) To bill and collect money owed to us by our Customers. This includes sending you emails, invoices, receipts, notices of delinquency, and alerting you if we need a different credit card number. We use third parties for secure debit and/or credit card transaction processing, and we send billing information to those third parties to process your orders and credit card payments. To learn more about the steps we take to safeguard that data, see Section 14 below.
e) To communicate with our Customers about their account and provide customer support.
f) To enforce compliance with our, User Agreement and applicable law. This may include developing tools and algorithms that help us prevent violations.
g) To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.
h) To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements.
i) To prosecute and defend a court, arbitration, or similar legal proceeding.
j) To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.
k) To provide, support, and improve the Services we offer. This includes our use of the data that our Customers provide us in order to enable our Customers to use the Services to communicate with their Contacts. This also includes, for example, aggregating information from your use of the Services or visit to our website and sharing this information with third parties to improve our Services. This might also include sharing your information or the information you provide us about your Contacts (all anonymised, non-personally identifiable information) with third parties in order to provide and support our Services or to make certain features of the Services available to you. When we do have to share information with third parties, we take steps to protect your information by requiring these third parties to enter into a contract with us that requires them to use the information we transfer to them in a manner that is consistent with this policy.
As you use our Service, you may import into our system Personal Information you have collected from your Contacts (and database). We have no direct relationship with your Contacts or any person other than you, and for that reason, you are responsible for making sure you have the appropriate legal permission for us to collect and process information about those individuals.
Consistent with the uses of Personal Information covered in Section 6, we may transfer Personal Information of you or your Contacts to companies that help us promote, provide, or support our Services or the services of our Customers (“Service Providers”). All Service Providers enter into a contract with us that protects Personal Information and restricts their use of any Personal Information consistent with this policy. As part of our Services, we may use and incorporate into features information you have provided, we have collected from you, or we have collected about Contacts. We may share this information, including Contact email addresses, with third parties in line with the approved uses in Section 6.
If you are a Contact and no longer want to be contacted by one of our Customers, please unsubscribe directly from that Customer’s communications or contact the Customer directly to update or delete your data. If you contact us, we may remove or update your information within a reasonable time and after providing notice to the Customer of your request.
We will retain Personal Information we process on behalf of our Customers for as long as needed to provide our Services or to comply with our legal obligations, resolve disputes, prevent abuse, and enforce our agreements.
We do not disclose any personal information obtained about you from this website to third parties except when we need to do so in order to complete the transaction – e.g. when arranging for a courier company to deliver goods that you have ordered. We may also use the information to keep in contact with you and inform you of developments associated with our business. You will be given the opportunity to remove yourself from any mailing list or similar device. If at any time in the future we should wish to disclose information collected on this website to any third party, it would only be with your knowledge and consent.
We may from time to time provide information of a general nature to third parties – for example, the number of individuals visiting our website or completing a registration form, but we will not use any information that could identify those individuals.
This privacy statement (“Privacy Statement”) applies to the treatment of personally identifiable information submitted by, or otherwise obtained from, you in connection with Spotler’s social posting platform GatorSocial. By using or otherwise accessing GatorSocial, you acknowledge that you accept the practices and policies outlined in this Privacy Statement.
What Personal information does Spotler’s GatorSocial application collect?
We collect the following types of information from our users:
Personal Information You Provide to Us:
- For GatorSocial’s Twitter connection you provide us your Twitter User Identifier (Id), screenname, description and profile image URL. There is no other personal identifiable data stored.
- For GatorSocial’s Facebook connection you provide us your Facebook User Identifier (Id). There is no other personal identifiable data stored.
- For GatorSocial’s LinkedIn connection you provide us your LinkedIn User Identifier (Id). There is no other personal identifiable data stored.
Personal Information Collected Automatically:
For GatorSocial’s Twitter connection, you can send posts direct to your Twitter account and the following information is collected:
- Information of your followers, their screen name and profile image
- Counts of your timeline engagement likes and retweets
- The user mention information
For GatorSocial’s Facebook connection, you can send posts direct to your linked Facebook Page and the following information is collected:
- Facebook page count information is only collected for: likes, mentions, followings and checkins of your page
- Facebook post count information is only collected for: views, engagement and likes
For GatorSocial’s LinkedIn connection, you can send posts to your company LinkedIn page and the following information is collected:
- Collect and store counts only for engagement, impressions, likes and shares, of LinkedIn company Pages
- Collects and stores of the name of your company
a) Blog. We have public blogs on our website. Any information you include in a comment on our blog may be read, collected, and used by anyone. If your Personal Information appears on our blogs and you want it removed, contact on the information provide at the start of this page. If we are unable to remove your information, we will tell you why.
b) Social media platforms and widgets. Our website includes social media features, such as the Facebook Like button. These features may collect information about your IP address and which page you are visiting on our Website, and they may set a cookie to make sure the feature functions properly. Social media features and widgets are either hosted by a third party or hosted directly on our website. We also maintain presences on social media platforms including Facebook, Twitter, and LinkedIn. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.
We may, from time to time, offer surveys, contests, sweepstakes, or other promotions on our websites, software or through social media (collectively “Our Promotions”). Participation in Our Promotions is completely voluntary. Information requested for entry may include personal information such as your name, address, phone number, email address, username, and similar details. We use the information you provide to administer Our Promotions. We may also, unless prohibited by the Promotion’s rules or law, use the information provided to communicate with you, or other people you select, about our Services.
When you send an email marketing campaign, it bounces from server to server as it crosses the Internet. Along the way, server administrators can read what you send. Email was not built for confidential information. Please do not use Spotler to send confidential information.
Sometimes we review the content of our Customers’ email campaigns to make sure they comply with our User Agreement. To improve that process, we have software that helps us find email campaigns that may violate our terms. Our employees or independent contractors may review those particular email campaigns. This benefits all Customers who comply with our User Agreement because it reduces the amount of spam being sent through our servers and helps us maintain high deliverability.
You have certain rights given to you by law, that means you have an amount of control over your personal data that we process.
- Access to Your Personal Data: This right allows you to confirm that your personal data is being processed and to allow you to check if the processing is lawful.
- Correcting Any Mistakes: The right of rectification allows you to instruct an organisation that is processing your personal data, to rectify any mistakes.
- Right to be Forgotten: You have the right to instruct an organisation to erase your personal data.
- Stop Processing: The right to stop the processing of your personal data
- Moving Data: The right to data portability means that under certain circumstances you will be able to ask for your personal data to be transferred from one organisation to another.
- Right to Object to Direct Marketing: You have the right to object to the processing of your personal data for the purposes of direct marketing.
- Object to Profiling: Under certain circumstances, you are able to object to profiling and/or automated decision making.
Right to complain to the Information Commissioners Office (ICO): If you are not happy with an aspect of how Spotler are processing your data, you can lodge a complaint to the supervisory authority, which is the ICO. (www.ico.org.uk)
Before it gets to that situation, please make sure you contact our Data Protection Officer (Lee Chadwick) at privacy@Spotler.co.uk if you wish to exercise any of your rights or if you have any questions about the processing of your personal data.
Although we never sell your data, we may disclose Personal Information to the following types of third parties for the purposes described in this policy. The only Personal Information we share is your email address. We do not share any other information.
Security and Compliance
If a security breach causes an unauthorised access into our system that materially affects you or your contacts in our software, then Spotler will notify you as soon as possible and later report the action we took in response.
For more information on this please refer to our data breach process.
Our servers and offices are located in the United Kingdom and the EU, so your information is stored in UK/EU and is not transferred to, stored, or processed outside the UK/EU. We recommend you check with your other providers as their data protection, privacy, and other laws (such as the United States) might not be as comprehensive as those in the UK/EU.
Please refer to our ‘schedule 4’ for more information.