Introduction
ActiveWin, henceforth referred to as “We” “Our” “Us” provides Marketing Services. In this policy “affiliate” “you” and “your” refers to the individual entity that has agreed to promote the brands we provide marketing services for, in accordance with this Privacy Policy.
This Privacy Policy is designed to help you understand how we collect, use and safeguard your information.
Data Controller
ActiveWin Marketing Ltd, Data Protection Officer, [email protected] Orega Serviced Offices, 76 King Street, Manchester, M2 4NH
Personal Information
We collect and process the following data from (and about) you:
- Your name, company name, address and contact details, including email address and telephone number;
- Payment details including Electronic transfer address, and payment method owner.
- A record of any correspondence between You and Us.
Personal information is collected for the following purposes
- To administer the opening, management, and maintenance of accounts.
- To enable ActiveWin to build an accurate profile of our client base and carry out statistical analysis.
- To contact you for purposes including (but not limited to) sales reports, training, provision of promotional resources, newsletters, and other correspondence.
- To monitor affiliate activity to ensure your compliance with the terms and conditions of the ActiveWins Affiliate Programme.
- To monitor and process payments in relationship to your involvement in the ActiveWIns Affiliate Programme.
- All telephone calls to and from ActiveWin office(s) may be recorded for training and security purposes.
We implement effective processes to identify, manage, monitor and report risks and internal control mechanisms. These controls include secure systems and networks, and clear processes for privilege access rights. All data is stored securely.
Legal Basis for Processing
Our lawful basis for processing personal data include:
- To fulfil a contract, we have with you.
- When it is our legal duty to do so.
- When it is in our legitimate interest.
- When you consent to it.
Who we share your personal information with
We may disclose your personal data to:
- ActiveWin employees
- contractors working with ActiveWin.
- regulators, and other legal authorities.
- the brands that you are promoting.
- auditors
- payment providers
- fraud prevention and compliance services
- third party marketing services
- potential purchasers or investors
- companies that you ask us to share your data with.
All processing of information will be governed by the appropriate data protection laws.
Marketing
We will not send promotional or direct marketing, inclusive of email, SMS, or automated calls, without first obtaining your specific consent.
The consent requires a positive Opt-In verbally or in writing; it must be clear and specific, granular, separate from other Terms and Conditions, name any third parties relying on the consent and be easily withdrawable.
Data Transfers outside the EEA
We will not transfer Personal Data to recipients in Third Party countries that are outside of the EEA, or are not currently recognised by EU law as having an adequate level of legal protection for the rights and freedoms of data subjects unless:
- a) The Processor is certified under the EU-U.S. Privacy Shield Framework.
- b) The existence of any other specifically approved safeguard for data transfers (as recognised under EU Data Protection Laws) and/or a European Commission finding of adequacy can be demonstrated.
Data Retention
You may request that your Personal Data be anonymised in the following circumstances:
- Where the Personal Data is no longer necessary in relation to the purpose for which it was originally collected/processed.
- When you withdraw consent, if consent is being used as the Legal Basis for Processing.
- If you object to the Processing and there is no overriding Legitimate Interest or Legal Obligation to continue the Processing.
- The Personal Data was unlawfully processed.
- The Personal Data has to be erased to comply with a legal obligation
We will only retain data for the necessary time to complete the task that the data was collected for, or to meet our legal obligations.
Subject Access Request (SAR)
You are entitled to a file a Subject Access Request (SAR) to obtain a copy of the personal information which we hold about you. If you wish to receive a copy of this information, please contact your account manager, or the DPO directly, and allow up to thirty calendar days for the information to be collated and provided to you, your identity will need to be confirmed.
Cookies
By using the ActiveWin website, you consent to our use of ‘cookies’. A cookie is a small piece of information sent by a web server to a web browser, which enables the server to collect information from the browser. We use cookies and the information gained from them to analyse site usage, with this information used accordingly to improve our content and site layout and to remember your onsite preferences.
If you prefer, you can disable cookies in your web browser. The ‘help’ menu on the menu bar of most browsers will have a functionality to disable cookies.
Right to Lodge a complaint
Please let us know if you are unhappy with how we have used your personal information. You also have the right to complain to the Information Commissioner’s Office.
