Last updated: 23 May 2018
Brand Response Ltd knows that you care how information about you is used and shared.
Some of our Clients (as data controllers) may appoint Brand Response to be a data processor for certain of their services, such as online Campaigns, Fundraising, Marketing or related activities, if you are a customer of one of these clients, who is the data controller, you should contact them first about your enquiry relating to data privacy or consult their respective privacy policies.
We may change this Policy from time to time so please check this page occasionally to ensure that you’re happy with any changes. By using our website or online services, you’re agreeing to be bound by this Policy.
Information We Collect
User-Provided Information: You may provide us information about yourself, such as your name and e-mail address or social media identity, if you register for Brand Response Ltd (including by “following,” “liking,” linking your account to Brand Response Ltd, etc., on a third party website or network). If you correspond with us by email, we may retain the content of your email messages, your email address and our responses. We may also retain any messages you send through Brand Response Ltd online channels. You may provide us information in user content you post to Brand Response Ltd website.
Brand Response Ltd do not knowingly process data of any person under the age of 16. Privacy law recognises certain categories of personal information as sensitive and therefore requiring more protection, including health information, ethnicity and political opinions. In limited cases, we may collect sensitive personal data about you. We would only collect sensitive personal data if there is a clear reason for doing so; and will only do so with your explicit consent.
Third Party Services
Brand Response Ltd uses the NationBuilder platform to organise and communicate with our clients, customers and prospects.
You can read more about that company, and the other companies listed below, and its features and policies at NationBuilder.com.
We also use a range of other services to provide data processing services to our clients to which they have agreed as data controllers.
When you visit Brand Response Ltd, NationBuilder may send one or more cookies — a small text file containing a string of alphanumeric characters — to your computer that uniquely identifies your browser and lets NationBuilder help you log in faster and enhance your navigation through Brand Response Ltd website.
A cookie does not collect personal information about you. A persistent cookie remains on your hard drive after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the site. Persistent cookies can be removed by following your web browser’s directions. A session cookie is temporary and disappears after you close your browser. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent.
However, some features of Brand Response Ltd websites may not function properly if the ability to accept cookies is disabled. You can read more about how the NationBuilder service interacts with and protects your information at nationbuilder.com/privacy and nationbuilder.com/confidentiality.
Your information, including Personal Information, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. This is because we work with trusted suppliers, for example our website provider, who are a US company.
If you are located outside United Kingdom and choose to provide information to us, please note that we transfer the information, including Personal Information, to United Kingdom and process it there.
In the event that a dispute arises with regards to the international transfer of data, you agree that the courts of England and Wales shall have exclusive jurisdiction over the matter.
Additionally, any access to this site will leave standard access logs in our server. This happens with almost every site on the Internet and is standard procedure. The access log notes the IP address, user-agent ID, time and page accessed. If your browser sends a referer-ID then this will also be collected. This information is not normally of a personal nature.
We may process data on behalf of, and in accordance with the instructions of our Clients (Data Controller) for their purposes which could may include Campaigns, Fundraising, Marketing or related activities. In processing this data our applications may be hosted on, or use a number of third party platforms for the essential operation of services, including:
Heroku owned by salesforce.com, inc., a Delaware corporation with its principal place of business at The Landmark @ One Market, Suite 300, San Francisco, California 9410
Makerloop, Inc, 610 22nd Street Suite 315 San Francisco, CA 94107
DigitalOcean, Inc 101 Avenue of the Americas 10th Floor New York, NY 10013
Zapier Inc, 548 Market St. #62411 San Francisco, CA 94104–5401
Google. “Google” means either (i) Google Commerce Limited (“GCL”), a company incorporated under the laws of Ireland, with offices at Gordon House, Barrow Street, Dublin 4, Ireland, (ii) Google Ireland Limited, with offices at Gordon House, Barrow Street, Dublin 4, Ireland (iii) Google Asia Pacific Pte. Ltd., with offices at 70 Pasir Panjang Road, #03–71, Mapletree Business City II Singapore 117371 (iv) Google Cloud Japan G.K., with offices at Roppongi Hills Mori Tower, 10–1, Roppongi 6-chome, Minato-ku Tokyo (v) Google Australia Pty Ltd., with offices at Level 5, 48 Pirrama Road, Pyrmont, NSW 2009 Australia(vi) Google Cloud Canada Corporation, with offices at 111 Richmond Street West, Toronto, ON M5H 2G4, Canada (vii) Google LLC, with offices at 1600 Amphitheatre Parkway, Mountain View, California 94043
How We Use Your Information
We use the personal information you submit to operate, maintain, and provide to you the features and functionality of Brand Response Ltd services.
By providing Brand Response Ltd with your email address (including by “following,” “liking,” linking your account to Brand Response Ltd, etc., on a third party website or network), you consent to our using the email address to send you Brand Response Ltd -related notices, including any notices required by law, in lieu of communication by postal mail.
You also agree that we may send you notifications of activity on Brand Response Ltd to the email address you give us, in accordance with any applicable privacy settings. We may use your email address to send you other messages, such as newsletters, changes to features of Brand Response Ltd, or other information. If you do not want to receive such email messages, you may opt out at Brand Response Ltd unsubscribe page or by emailing email@example.com
Following termination or deactivation of your Brand Response Ltd account, Brand Response Ltd may retain your profile information and user content for a reasonable time for archival purposes. Furthermore, Brand Response Ltd may retain and continue to use indefinitely all information (including user content) contained in your communications to other users or posted to public or semi-public areas of Brand Response Ltd after termination or deactivation of your account.
Brand Response Ltd reserves the right, but has no obligation, to monitor the user content you post on Brand Response Ltd. We reserve the right to remove any such information or material for any reason or no reason, including without limitation if in our sole opinion such information or material violates, or may violate, any applicable law or to protect or defend our rights or property or those of any third party. Brand Response Ltd also reserves the right to remove information upon the request of any third party.
How We Share Your Information
Any personal information or content that you voluntarily disclose for posting to Brand Response Ltd website, such as user content, becomes available to the public, as controlled by any applicable privacy or website customization settings. If you remove information that you posted to Brand Response Ltd, copies may remain viewable in cached and archived pages, or if other users have copied or saved that information.
We will disclose your Personal Information where required to do so by law or in accordance with an order of a court of competent jurisdiction, or if we believe that such action is necessary to comply with the law and the reasonable requests of law enforcement or to protect the security or integrity of our Service.
How We Protect Your Information
Brand Response Ltd cares about the integrity and security of your personal information. We cannot, however, ensure or warrant the security of any information you transmit to Brand Response Ltd or guarantee that your information on the service may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. Your privacy settings may also be affected by changes to the functionality of third-party providers, such as social networks. Brand Response Ltd is not responsible for the functionality or security measures of any third party.
To protect your privacy and security, we take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to your email communications from Brand Response Ltd, at all times.
Compromise of Personal Information
Your Choices About Your Information
You may, of course, decline to submit personally identifiable information through Brand Response Ltd, in which case Brand Response Ltd may not be able to provide certain services to you. You can review and correct the information about you that Brand Response Ltd keeps on file by contacting us directly at firstname.lastname@example.org
Links to Other Web Sites
Third Party Websites and Resources
As a convenience to users, the website includes links to, and content from, other Internet sites and resources. However, given that monitoring the vast information disseminated and accessible via those sites and resources is impracticable and beyond Brand Response Ltd’s resources, such information cannot be guaranteed to be accurate, up to date or endorsed by Brand Response Ltd.
Your rights and how consent works
You have a choice about whether or not you wish to receive information from us. If you do not want to receive communications from us, then you can select your choices by ticking the relevant boxes situated on the form on which we collect your information.
Where we rely on your consent to use your personal information, you have the right to withdraw that consent at any time. This includes the right to ask us to stop using your personal information for direct marketing purposes or to be unsubscribed from our email list at any time. You also have the following rights:
(1) Right to be informed — you have the right to be told how your personal information will be used. This Policy and other policies and statements used on our website and in our communications are intended to provide you with a clear and transparent description of how your personal information may be used.
(2) Right of access — you can write to us to ask for confirmation of what information we hold on you and to request a copy of that information. Provided we are satisfied that you are entitled to see the information requested and we have successfully confirmed your identity. From 25 May 2018, we will have 30 days to comply.
(3) Right of erasure — as from 25 May 2018, you can ask us for your personal information to be deleted from our records. In many cases we would propose to suppress further communications with you, rather than delete it.
(4) Right of rectification — if you believe our records of your personal information are inaccurate, you have the right to ask for those records to be updated.
(5) Right to restrict processing — you have the right to ask for processing of your personal data to be restricted if there is disagreement about its accuracy or legitimate usage.
(6) Right to data portability — to the extent required by the General Data Protection Regulations (“GDPR”) where we are processing your personal information (i) under your consent, (ii) because such processing is necessary for the performance of a contract to which you are party or to take steps at your request prior to entering into a contact or (iii) by automated means, you may ask us to provide it to you — or another service provider — in a machine-readable format.
To exercise these rights, please send a description of the personal information in question using the contact details below.
Where we consider that the information with which you have provided us does not enable us to identify the personal information in question, we may ask you for (i) personal identification and/or (ii) further information.
Please note that some of these rights only apply in limited circumstances. For more information, we suggest that you consult ICO guidance — https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
You are further entitled to make a complaint about us or the way we have processed your data to the Information Commissioner’s Office (“ICO”). For further information on how to exercise this right, please see the guidance at https://ico.org.uk/for-the-public/personal-information. The contact details of the ICO can be found here: https://ico.org.uk/global/contact-us.
We are required to have one or more lawful grounds to process your personal information. Only 4 of these are relevant to us:
We will ask for your consent to use your information to send you electronic communications such as newsletters and marketing emails, for targeted advertising, and if you ever share sensitive personal information with us.
(2) Contractual relationships
Most of our interactions with subscribers and website users are voluntary and not contractual. However, sometimes it will be necessary to process personal information so that we can enter contractual relationships with people.
(3) Legal obligations
Sometimes we will be obliged to process your personal information due to legal obligations which are binding on us. We will only ever do so when strictly necessary.
(4) Legitimate interests
Applicable law allows personal information to be collected and used if it is reasonably necessary for our legitimate activities.
We will rely on this ground to process your personal data when it is not practical or appropriate to ask for consent.
In general, unless still required in connection with the purpose(s) for which it was collected and/or is processed, we remove your personal information from our records five years after the date it was collected. However, if before that date (i) your personal information is no longer required in connection with such purpose(s), (ii) we are no longer lawfully entitled to process it or (iii) you ask us to delete it we will remove it from our records at the relevant time.
In the event that you ask us to stop sending you direct marketing/other electronic communications, we will keep your name on our internal suppression list to ensure that you are not contacted again.
When we use your personal information, we will consider if it is fair and balanced to do so and if it is within your reasonable expectations. We will balance your rights and our legitimate interests to ensure that we use your personal information in ways that are not unduly intrusive or unfair in other ways.