Privacy Policy
At CLEO DIGITAL LTD, we are dedicated to upholding the privacy of individuals and ensuring full compliance with all Data Protection Legislation requirements. Our company formulates strategies to invest clients' media budgets across various channels, utilizing specialized insights, data, SEO, social, and influencer services.
SCOPE
- This policy pertains to visitors of our website and elucidates, among other aspects:
- The reasons behind processing your personal information
- The types of personal information we may gather from you
- How we acquire your personal information
- The legality of our personal information processing
- How we utilize your personal information
- Entities with whom we might share your personal information
- The duration we may retain your personal information
- Your rights concerning your personal information
GENERAL INFORMATION
What constitutes personal information?
Personal information encompasses any data that can identify or potentially identify an individual. Examples include:
- First and last names
- Mailing, email, and IP addresses
- Phone numbers
- Identification documents (e.g., passports and driver's licenses)
- Identity numbers (e.g., National Insurance and bank accounts)
- Career and educational records (e.g., CVs and qualifications)
- Contact details
Sometimes, personal information is referred to as "personal data." We collectively refer to the handling, collection, protection, storage, or any other use of your personal information as 'processing.'
You are not obligated to provide any personal information to us. However, failure to provide requested information may limit our ability to fulfill your requests.
COLLECTING (OBTAINING) YOUR PERSONAL INFORMATION
Here are examples of how you may supply personal information to us:
- Completing our website's contact form
- Emailing us through links found on our website
- Subscribing to our mailing lists on our website
- Applying for a job at Cleo Agency via our website, a third party (e.g., LinkedIn), or by emailing us
- Browsing our website, app, or platform
- Responding to our survey requests regarding you and your lifestyle
We may also receive information from other sources:
- Some of the aforementioned personal information may be obtained from third parties (individuals or organizations) or publicly available - sources, such as social networks, company websites, and public records.
- We may also receive personal information from third-party websites that you have authorized to share this information with us, including agency member platforms (e.g., The Recommended Agency Register, The Drum, Little Black Book, Lead Forensics), as well as recruitment agencies to which you have granted permission to share your details with us.
- We may also receive personal information from insight applications or companies with whom you have consented to share your information.
COOKIES
For information regarding the cookies and similar technologies we use, please refer to our cookies policy.
USE OF YOUR PERSONAL INFORMATION
Upon collecting your personal information, we may employ it for any of the following purposes, as described below or at the point of collection:
- Providing information, goods, or services you have requested
- Establishing contact with you
- Administering and managing our website, app, or platform
- Sending you newsletters or online publications
- Assessing potential employment opportunities with us
- Managing our relationship with you
- Creating and managing customer/user accounts
- Enhancing our business and services
- Analyzing data to gain insights into various groups of individuals (with your consent)
- Any other purpose for which your personal information has been provided to us, including those outlined under 'Collection of your personal information' above
- We do not collect personal information for sale to third parties.
USE OF YOUR PERSONAL INFORMATION FOR MARKETING
We will only provide you with marketing materials if you have previously given us your consent and when legally required.
If you choose to subscribe but later decide to unsubscribe, you can follow the instructions provided in our communications to you. If you opt-out, we may retain some of your personal information to honor your request and avoid sending further marketing materials.
LEGAL BASIS FOR PROCESSING YOUR PERSONAL INFORMATION
We rely on one or more of the following legal bases:
Consent: We may process your personal information after obtaining your consent. You have the right to withdraw your consent at any time.
Contract: We may process your personal information when necessary to deliver a contractual service to you or when you have requested us to take steps before entering into a contract (e.g., providing a quote).
Legal obligation: We may process your personal information to comply with a legal obligation.
Legitimate interest: We may process your personal information for our or another party's legitimate interests, provided these interests do not override your rights.
SHARING YOUR PERSONAL INFORMATION
We may share your personal information with third parties (other organizations or individuals) for:
The purposes for which the information was submitted
The purposes listed under 'Using your personal information' above
Agreements between us
We may also transfer or disclose personal data to third-party service providers offering identity management, website hosting and management, data analysis, data backup, security, and storage services. These third parties may employ subcontractors (sub-processors) with access to your personal data. Our policy is to only share personal information with third parties that are legally or contractually bound to protect it to the same standards as we do and will pass on those standards to their subcontractors. We may also share your personal information with third parties in connection with corporate transactions (e.g., mergers and/or acquisitions), which may result in the transfer of your personal information to a third party. Additionally, we may share your personal information with law enforcement, regulatory agencies, government bodies, professional organizations, and other third parties as required by and in accordance with applicable law or regulation. The third parties we routinely or regularly share your personal information with include:
External IT service providers
Other companies within our group
Professional advisers
TRANSFER OF YOUR PERSONAL INFORMATION OUTSIDE THE UK
Your personal information may be transferred outside the UK, but only under specific circumstances:
- To you
- To a recipient situated in a country providing an adequate level of protection for your personal information, such as an EU or EEA country
- To a recipient under a contractual agreement that meets UK legal requirements for personal information transfer, ensuring appropriate safeguards consistent with UK data protection standards are in place
- When your personal information has been anonymized
RETENTION (STORAGE) OF YOUR PERSONAL INFORMATION
We will retain your personal information only for as long as necessary for the purpose(s) for which it was collected or as required by law. To determine the appropriate retention period, we consider factors like the amount, nature, and sensitivity of your personal information, the potential risk of unauthorized use or disclosure, the purposes of processing, and whether we can achieve those purposes through alternative means, as well as legal requirements. Typically, we retain personal information for six years. In the case of survey respondents, we will archive your information 18 months after it is no longer needed. For more information, please contact us.
YOUR RIGHTS REGARDING OUR PROCESSING OF YOUR PERSONAL INFORMATION
You have the right to be informed about our collection and use of your personal information. Specifically, you may have the right to:
Withdraw your prior consent to our processing of your personal information
Request a copy of the personal information we hold about you
Ask us to update or correct your personal information if you believe it is inaccurate or incomplete
Request the deletion of personal information we hold about you or restrict its use
Object to our processing of your personal information
To exercise your rights, please contact us.
SECURITY
We are committed to safeguarding your personal information against accidental or unlawful destruction, loss, alteration, unauthorized access, or disclosure, and we have implemented widely accepted technology and operational security standards. Please be aware that we cannot guarantee the security of all personal information transmitted to or by us.
AUTOMATED DECISION MAKING
We do not use your personal information for automated decision-making or profiling.
CHILDREN
We understand the importance of protecting children's privacy and do not knowingly collect personal information about individuals under the age of 13.
CONTACT DETAILS
You can reach us through the following means:
Online: https://www.cleo.agency
Email: contact@cleo.agency
Postal Address: Cleo Digital Ltd Richmond House Walkern Road Stevenage SG1 3QP
YOUR RIGHT TO LODGE A COMPLAINT WITH THE ICO (UK ONLY)
If you have concerns about how we handle your personal information or believe we have not complied with data protection regulations, you may contact the Information Commissioner's Office (ICO), the UK's supervisory authority:
Online: https://ico.org.uk/make-a-complaint/
Live chat: https://ico.org.uk/global/contact-us/live-chat
Tel: 0303 123 1113
Please note that you should raise your complaint with the ICO within three months of your last meaningful contact with us.