Legal Basis for Processing Data
According to the definition of the Information Commissioners Office (ICO), Information Publications Ltd can be identified as a private sector organisation (all for-profit business).
Boating Communications Ltd utilises the lawful basis of Legitimate Interests under DPA and GDPR to process data and send out direct marketing communications under PECR/e-Privacy.
Our business is the provision of publishing online and printed editorial news and feature content and centres on selling content and marketing services to businesses associated to, or within, the business sector that we are involved in. The aim of Boating Communications Ltd is to provide business content to customers with whom we engage and provide marketing activity which has value and is beneficial to our customers.
Email is our main form of marketing activity and we provide an unsubscribe link for corporates and individuals to opt-out/object to the further processing of their data should they so choose.
We also use direct tele-sales, through which we allow the individual to reserve the right to notify us to not contact them again. We only market to businesses and persons within those businesses that we genuinely believe would be interested in our designated products and services.
The ICO states that ‘direct marketing covers the promotion of aims and ideals as well as the sale of products and services’, and GDPR states that ‘the processing of personal data for direct marketing purposes may be regarded as carried out for a legitimate interest’.
The ICO statement creates the framework for an appropriate legal basis for our marketing activities. As such Boating Communications Ltd believes that there is a legitimate interest compliance for the publishing of business content and the undertaking of marketing activities to facilitate such. The legitimate Interests compliance will be kept under review from time to time to meet with the statutory requirements of the ICO.
Regarding customers and industry contacts using our platforms and services, Boating Communications Ltd utilises the lawful basis of a contractual obligation to send regular updates and contact via email communications. This may variously include: daily, weekly or monthly content updates and any other relevant communications which have reference to the content provision options within the designated products and services provided.
Data we collect
The main information we initially collect are contact details, content requirement preferences, payment preferences and associated payment details used to administer accounts and payments. Information Publications Ltd may use this information to make contact to further discuss (possible) interest in ongoing product or service developments.
Contact is only made to those that agree and authorise themselves to be added to our marketing mailing list and to receive information about our products and services. They can opt out of being further contacted by us by using the unsubscribe link at the bottom of our emails or email us at email@example.com.
Use of IP Tracking
We currently use IP tracking technology to identify businesses visiting our site and the pages that are being used. This helps us analyse data and web page traffic. It also serves to determine interest in our business services and provide insight.
Boating Communications Ltd are fully committed to adherence to the General Data Protection Regulations (GDPR) following implementation on the 25 May 2018. In relation to our collection and processing of personal data, please see the below information.
This policy explains how Boating Communications Ltd uses the personal information collected.
Personal details we hold
Boating Communications Ltd holds two types of personal information which allow us to manage our service provision:
1. Customer provided information: customer contact details, content requirement preferences, payment preferences and associated payment details used to administer accounts and payments.
2. Customer contact records – Records of calls, emails and postal interactions with our website and customer centre are maintained for audit, training and service improvement purposes.
Length of time information will be held
In order to comply with the General Data Protection Regulations, your details will only be kept for the shortest time required or for the period required to meet our legal statutory obligations. This term may vary according to the type of data being held.
How to access your personal data
If you wish to see full details Boating Communications Ltd holds in connection with you, you will need to make a subject access request under the General Data Protection Regulations.
To initiate a subject access request, email: firstname.lastname@example.org
Keeping your details secure
Boating Communications Ltd has a service provision contract with Abacus e-media for the provision of all online services who provide the administration and ‘back office’ services for the Company. Information is stored in highly secure UK data centres where it is protected by the latest encryption and firewall technology. These systems are regularly audited and penetration tested by external security assessors to ensure your data is safe. We do not store entire credit/debit card numbers, nor do we keep records of the security code of customers’ credit or debit cards.
Personal information usage
We use information held in the following ways:
- To ensure that content provision is delivered in the most effective manner for our customers.
- To administer our site or subscription services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and (where required) survey purposes.
- To provide our customers with information, products or services that are either requested or which we believe may be of interest, satisfy the data provision preferences consented to, or wherein customers have consented to be contacted for such specific service provision.
- To carry out our obligations arising from any contracts entered into between you and us.
- To allow you to participate in interactive features of our service, when you choose to do so.
- To notify you about changes to our service, your subscription or our contract with you.
Wherein consent has been provided we may from time to time provide offers and content from third parties, to provide you with information about goods and services which may be of interest to you and we or they may contact you about these by post, email or telephone.
If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale to you.
If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you using methods appropriate to the data that you have submitted to us or the data we already hold.
If you do not want us to use your data in this way, then please ensure that you read the registration forms carefully to ensure that you do not provide your consent to receive third party information this way.
Please note, if you request a download or a content access invitation paid for and hosted by a third party, we will be required to pass your details to that third party to fulfil your request.
Collection of Data
Information Publications Ltd will be the data controller and the contact details for the company are:
Data Protection Officer: Nick Hopkinson
The data held is used for the purposes of customer service and administration, access to online content, subscription validity and expiry information and newsletter information requirements.
Collected data will be stored within a secure electronic records management systems, by our online platform provider Abacus e-media. Wherein a commercial transaction relating to subscriptions takes place that information is held by our payment services provider MasterCard Payment Gateway Services who are a service partner to Boating Communications Ltd and Abacus e-media.
The storage and system will be dependent on the nature of the information held and which service provider is holding the data. Boating Communications Ltd will store any correspondence from you in a correspondence recording system. Information stored by Abacus e-media will be held in the main back office systems attributed to Boating Communicatons Ltd.
Additional systems are used to process and store supporting information such as correspondence and telephone call recordings, and access to this information will be made available upon request.
Processing of Data
We may collect and process data in the following ways:
- Information that you provide by filling in forms on our sites - please note that these may be amended from time. This may include information provided at the time of registration or during site or service usage, subscribing to our services, posting material online or requesting further services. We may also ask you for information when you report a problem with our site.
- If you contact us directly, we may also keep a record of that correspondence. We will record time, date and value details of transactions you carry out through our site and of the fulfilment of any commercial transaction or your orders. Any billing, credit card or accounts information personal will not be held by Information Publications Ltd. Details of your visits to our site include, but is not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise.
- Personal data will be stored for a term in keeping with our statutory legal requirements, or for the shortest time necessary in order to manage the delivery of any commercial services between the parties, including but not exclusive to: content consumption, customer payments, account management and general enquiries.
Under the GDPR you have the following rights to request information from the company:
- Right of access to the data (Subject Access Request)
- Right for the rectification of errors
- Right to erasure of personal data (please note, this is not an absolute right)
- Right to restriction of processing or to object to processing
- The right to portability
Notification of data usage or requests
If we are to process the personal data we hold for a purpose other than that for which it was originally collected, then we will provide you with information on what that other purpose is prior to that further processing taking place. The extra information may include any relevant further information as referred to above. The right to object to that further processing is understood.
External partners and websites - Our site may, from time to time, contain links to and from the websites of our partners and service provision support networks. In the event that you follow a link to any of these websites, please be aware that these websites have their own privacy policies and we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
HOW TO CONTACT US
LODGING A COMPLAINT
You have the right to lodge a complaint with a supervisory authority (in the UK that is the Information Commissioners Office) www.ico.org.uk