In marked contrast to many organisations, LASCIVIOUS MARKETING is fairly straightforward when it comes to personal data in the running of the business. So hopefully you’ll find this a shorter read than what you are used to elsewhere!
Anyway, as per the EU-wide General Data Protection Regulation (GDPR), the following information is provided.
48 WEST GEORGE STREET
Tel.: +44 (0)141 255 0769
Owner: Mr. Brian Gray
PURPOSES OF DATA PROCESSING
Provision of marketing services
Receiving emails from the website contact form and/or direct emails. Initial correspondence requires a name and valid email address. This may also contain brief project details or enquiries.
As with general consulting convention further discussion will invariably consist of additional project details which may disclose additional personal data.
Should an enquiry progress to a consulting engagement, then further details will be required, which will most likely comprise:
- Key project individuals
- Nature of project
- contact telephone numbers / email addresses
- any other details pertinent to the booking and provision of services
- banking details
Enquiries and subsequent client engagements and specific post-engagement correspondence are processed under the lawful basis of CONTRACT.
For some payments, client personal contact data will be transferred to PayPal and manually entered when creating client invoices. Please visit the PayPal website to familiarise yourself with PayPal’s own data protection and processing standards and safeguards. For other payments, bank transfer will be utilised.
Market / Marketing / Customer Research
Processing of research sample (pre-fieldwork) and post-fieldwork respondent data. Client customer details provided by client (whose own data processing under – likely – legitimate interest or consent), and processed by Lascivious Marketing under lawful basis of CONTRACT.
Erotic Trade Industry Research Panel
Lascivious Marketing is building an industry research panel in which panel members will participate in marketing research surveys and other research projects. Panel members voluntarily subscribe by means of double opt-in procedure (1st stage form sign up, followed by 2nd stage link verification sent by email) and processed under the lawful basis of CONSENT. Subscribers provide key information such as:-
- email address
- industry sector
Weekly newsletter: ‘Six of the Best’
Lascivious Marketing sends out weekly newsletters to subscribers. Registration is by means of double opt-in procedure (1st stage form sign up, followed by 2nd stage link verification sent by email) and processed under the lawful basis of CONSENT. Subscribers provide key information such as:-
- email address
- industry sector
Regular interviewing of erotic trade industry professionals for the Lascivious Marketing website. Contact details and personal texts to be used as content, and processed under the lawful basis of CONSENT.
Business Development / Industry networking
In the running of the company, data (name, email address, telephone number, postal address, company/organisation) may be obtained from external sources in order to make contact and introduce LASCIVIOUS MARKETING to target audiences. Such data will be processed under the lawful basis of LEGITIMATE INTEREST.
Emails received from prospects and clients in the running of the business, and PayPal invoice and payment notifications are held for a minimum of six years, in line with standard HMRC accounting requirements. Older enquiries and client details are maintained (under CONTRACT basis for tax and business records only)
Appropriate security measures are in place to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
Please be aware that while all reasonable efforts are made to keep personal data safe and secure, the internet itself cannot offer such guarantees, whether through accidental or malevolent acts. Therefore a cast-iron guarantee of protection cannot be given for any personal data that is transferred online. In all online correspondence and dealings with LASCIVIOUS MARKETING you hereby accept this risk.
Where there has been any suspected breach of security, procedures are in place to report and notify the appropriate individuals and authorities.
Information may be transferred to and processed and/or stored at a destination outside the European Economic Area (“EEA”) by organisations such as PayPal. Please visit their website for further details concerning data protection.
MailChimp mailings are tighly controlled, with MailChimp long holding to a ‘privacy by design’ mantra. Furthermore, an EU Data Processing Addendum is in place between The Rocket Science Group LLC (d/b/a ‘MailChimp’) and Lascivious Marketing, effective as of 24th May 2018.
Under existing data protection and GDPR legislation, several privacy rights are afforded. These include:
- The right to be informed
- The right of access
- The right to rectification
- The right to erasure
- The right to restrict processing
- The right to data portability
- The right to object
- Rights in relation to automated decision making and profiling
The right to be informed: You have the right to be informed how your personal data will be used, such as on this particular webpage and at other junctures, such as submitting initial contact form information.
The right of access: You have the right to know what information we hold about you and to ask, in writing, to see your records. Details of the records held on you will be provided to you as soon as possible and no later than one month – assuming the request is straightforward. Proof of identity may be required before data is released. Please get in touch using the website contact form if you wish to exercise this right.
The right to withdraw consent: Industry research panel involvement and ‘Six of the Best’ newsletters relies entirely on the basis of consent which can be withdrawn at any time. Requests to withdraw can either be through MailChimp ‘unsubscribe’ option or via Lascivious Marketing.
Right to object: You also have a right to object to Lascivious Marketing processing data where relying on it being within legitimate interests to do so (for example, to send you direct marketing by post). To do this, or to discuss this right further, please get in touch using the contact webpage.
Right to restrict processing: In certain situations you have the right to ask for processing of your personal data to be restricted because there is some disagreement about its accuracy or legitimate usage.
Right of erasure: In some cases, you have the right to be forgotten (i.e. to have your personal data deleted from our database). Where you have requested that we do not send you marketing materials we will need to keep some limited information in order to ensure that you are not contacted in the future.
Right of rectification: You have the right to have personal data held by Lascivious Marketing updated/rectified if you believe the existing information held is inaccurate. Get in touch via the website contact page.
Right to data portability: Where we are processing your personal data because you have given us your consent to do so or for the performance of a contract, you have the right to request that the data is provided to you to reuse across different services.
Perish the thought, but if you are genuinely dissatisfied with the way your data has been handled, please contact us using the contact webpage.
You are also entitled to make a complaint to the Information Commissioner’s Office – https://ico.org.uk/.