What this Policy Covers
This Privacy Policy covers the processing of personal data by ESB Connect Limited (“esbconnect”, “we”, “us” or “our” in this policy) when providing its services to its clients.
esbconnect is a digital marketing and technology platform company registered in the UK under company number 08235436. Our ICO registration number is ZA074763
To contact us please write to:
ESB Connect Limited, 38 Chancery Lane, London, WC2 1EN
or email: hello@esbconnect.com
esbconnect is committed to protecting and respecting your privacy. Within this Privacy Policy we will explain the basis on which personal data we collect from you or from public sources will be processed by us.
Where we decide the purpose or means for which this personal data is processed, we are the “data controller.”
We will comply with all applicable data protection laws, including the General Data Protection Regulation 2016/679.
You have the right to object to us processing your personal data for direct marketing purposes and you can unsubscribe at any time via this link: http://www.opt-me-in.com/unsubscribe/
What Information do we collect about you?
We collect and process the following data via esbconnect’s call centres, websites and landing pages which are owned and operated by esbconnect. If you contact us about our services, request a demo, request a call back or further information, download a free guide or complete a survey or competition via an owned website or centre the following data may be collected:
- Name;
- Employer Company & Company Details;
- Office Location (Country & City);
- Business Telephone Number;
- Business Email Address;
- Job Title.
- Number of employees
- Year incorporated
- Financial year end
Analytics on the website: Our website uses cookies and other mechanisms to collect and log analytical information this may include IP address and user agent, to help analyse use, to compile statistical reports on use of our website and to improve our website and marketing.
The following data may be collected:
• number of visitors to our website;
• pages visited while at the website and time spent per page;
• the device you are using to browse
• page interaction information, such as scrolling, clicks and browsing methods;
• websites where visitors have come from and where they go afterwards;
• page response times and any download errors; and
• other technical information relating to end user devices, such as IP address or browser plug-in.
We append information to your company details based on publicly available data, such as via Companies House. If you have moved job, we may keep a record of both your current and previous roles. We may also gather further insight via emailing you a survey or calling you.
In order to provide certain aspects of its services, esbconnect requires a business email address to be recorded against profiles in its database. If an email record does not exist, we may generate a business email address based on the email address structure understood to be implemented by the employer company.
We may also hold your personal email address and have linked this to your business profile. If we hold your personal email address, this would be based on consent and any marketing received to it would be consumer based content. To see our privacy policy here, please go to http://privacy.esbconnect.com/
The majority of the personal data we collect about you comes from publicly available sources such as from business and employment-oriented social networks, recruitment websites and company websites. A secondary source of data is information provided directly to us via a survey you have completed on one of our sites or whilst downloading a guide.
Why we collect your data?
We collect your data so that we can:
a) Send you marketing campaigns via email, postal or telephone relating to commercial organisations we believe will be relevant to you. You can unsubscribe at any time via the email or via this link: http://www.opt-me-in.com/unsubscribe/ . We will always clearly mark any communication sent or made by ourselves.
b) Supply commercial data about organisations to other organisations. The purpose of this processing is to enable businesses to manage their financial risks, protect against fraud, know who they are doing business with, meet compliance and regulatory obligations and better understand organisations, industries and markets.
c) We may also license or sell your professional business contact information to authorised resellers or organisation for marketing and data management purposes.
How we use it?
- To send you marketing information about our services or that of a client via email, direct mail, via a social media platform or via a call centre;
- to build our DMP (data management platform) intelligence to enable our clients to select audiences that are relevant to their marketing activities.
- to enable our clients to serve relevant display ads on social networks (such as Facebook, LinkedIn and Instagram) and other services;
- to enable our clients to enrich their existing customer relationship management records and receive timely updates of changes;
- to undertake research and compile statistical aggregated reports
- to supply other data management platforms
- to run our own marketing campaigns and promote our own services.
- to provide other companies with the data to run their own marketing campaigns
Grounds for processing
– Consent
On some occasions, esbconnect processes your data with your consent. Your consent may be obtained by third parties on esbconnect’s behalf. You have the right to withdraw such consent at any time and we will cease to process data after consent is withdrawn. You can do so here: http://www.opt-me-in.com/unsubscribe/
– Legitimate interest
esbconnect processes your personal data when it is in our, or our clients’ legitimate interest to do so and when these interests are not overridden by your rights.
Our and our clients’ legitimate interests include:
- having information about potential business customers organised in one searchable database
- having access to up-to-date and complete information
- being able to identify the individual that occupies a certain role within a B2B lead
- being able to identify individuals with a certain estimated net worth
- enabling clients to only reach out to relevant contacts
- being able to generate and contact potential B2B leads in order to undertake forms of B2B marketing
- having access to aggregated statistical insights for the purpose of understanding patterns and trends.
– Necessary because of a legal obligation
esbconnect may process your data to comply with our legal and regulatory obligations e.g., preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies.
– Necessary to fulfil an obligation under a contract
esbconnect may process your data where we have a contract with the individual and we need to process their personal data to comply with our obligations under that contract.
Who we share your data with?
We will share your information with the following:
Our companies
Access to personal data within esbconnect and our group of companies or any companies we buy or partner with in the future. The access will be restricted to those individuals who have a need to access the information for our business purposes.
esbconnect clients
We may share personal data with our clients as part of our service offering. This may be provided under a data license basis or in order to fulfil a contract. Clients may use the data to contact individuals on their business telephone, at their business email address, through other electronic mail or through targeted display ads on social networks or via direct mail in order to market products and/or services.
Please note that in making available the data to its clients, esbconnect is processing such data as a processor on behalf of the client, who is acting as the controller. Clients will likely have their own privacy policies and opt-out options, and we recommend you review them. Where esbconnect has made personal data available to its clients, the client privacy policy should list esbconnect as a data source.
Current clients include:
1. Acquiriz – https://www.acquirz.co.uk/legal-notice
2. UK Datahouse – https://ukdatahouse.com/cookie-and-privacy-policy/
Brands who use our services but who we do not release the data to can be found here. Please note this is not a full list but an example of the brands we are working with. We reserve the right to add to this list or withhold brands from displaying on this list. If esbconnect are sending a communication to you, we will include our details in the header and footer of the email.
Suppliers, subcontractors, service providers
We keep your information confidential, but may disclose it to suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this privacy policy. However, this is on the basis that they have agreed to safeguard this information.
This includes external third-party service providers, such as accountants, auditors, experts, lawyers and other outside professional advisors; IT systems, support and hosting service providers; technical engineers; data storage and cloud providers and similar third-party vendors and outsourced service providers that assist us in carrying out business activities.
Data management platform
A DMP is a technology platform used for collecting and managing data, mainly for digital marketing purposes. Esbconnect owns and operates their own DMP and clients can access the analysis which does not contain PI. We also supply other DMPs with data so that the DMP can generate audience segments, which are used by advertisers to target specific types of users in online advertising campaigns.
Government authorities
In addition, we may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).
Potential acquirers or investors
If we are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified via email, account message and/or a prominent notice on our website of any change in ownership or uses of this information, as well as any choices you may have regarding this information.
How to opt-out?
Simply click the link in the email or go here: http://www.opt-me-in.com/unsubscribe/
Or to opt-out via post, please write to: esbconnect, 38 Chancery Lane, London, WC2A1EN
To opt-out via email, please write to: data@esbconnect.com
Your Rights
In this section , we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
To exercise any of these rights, we first need to validate you are the data subject in question, so please complete a Subject Access Request here: http://mydetails.opt-me-in.com/ .
Once completed, we will return you a SAR report. From here, please reply with details of the right you would like to exercise. Please note that the right to erasure is not an absolute right.
You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data.
Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can request this by going to http://mydetails.opt-me-in.com/
You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims. We will never erase your email address, so we can maintain a record that we should not mail you.
In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to mail you.
To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
If you are not satisfied with the way we handle any complaint you make in relation to your personal information then you may be able to refer your complaint to the relevant data protection regulator which in the UK is the Information Commissioner’s Office whose address is Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal. If you wish to withdraw your consent, you can do so by CLICK HERE
Security
esbconnect is committed to keeping your personal data safe and secure from unauthorised access to or unauthorised alterations, disclosure or destruction of information that we hold. We will take all reasonable technical and organisational precautions to prevent the loss misuse or alteration of your personal data.
Our security measures include:
• hashing and encryption of our services and data;
• monitoring who accesses the database and identifying any abnormalities
• regular review of information collection;
• encryption of our services and data;
• restricted access of data to employees, contractors and agents; and
• internal policies setting out our data security.
Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.
International Data Transfers
We may from time to time use technologies that require us to transfer your data outside the European Economic Area (EEA).
Where we transfer your data outside of the EEA, we transfer the minimum amount of data necessary, anonymise it where possible and we have agreements in place with those parties which include standard data protection clauses to ensure that appropriate safeguards are in place to protect your personal data in accordance with this Privacy Policy and the European levels of data protection. If you would like to find out more about these safeguards, please contact us.
Use of Cookies
We use cookies and similar technologies, such as tags and pixels (“Cookies”) on both our websites and emails we send you. These are used to personalise and improve your customer experience and to provide you with relevant online advertising on websites and via email.
Cookies are small data files that allow us to store settings and identifiers on your desktop computer, laptop or mobile device.
Cookies help us to provide important features and functionality on our Websites and Mobile Apps, and we use them to improve your customer experience. For example, we use Cookies to do the following:
• Personalise our websites and Mobile Apps for you by remembering your preferences so that you can continue where you left off if you return to a site. This data is stored locally, and we do not store this data on our servers.
We also use cookies for Site Abandonment. This is where we place a script on a partner’s website and when you visit their website, our script looks to see if an esbconnect owned cookie exists on your browser. If it exists, it triggers an email to be sent on the behalf of the advertiser but we will be identified as the data controller and sender. These emails will only be triggered if you have accepted cookies on their site and we have a valid opt-in for you. These will be marketing messages from the owner of that website aimed at improving your interaction with their website.
We may also use cookies for trigger paths, this is where we send a marketing email that has been designated as relevant to individuals that have interacted with an email of ours that you have opened or clicked on.
Deliver Relevant Online Advertising
Cookies help us to deliver online advertising we believe is relevant to you on our websites, other organisations’ websites and through emails we send you.
Cookies used for this purpose are placed on your device by one of our websites or partner websites, emails we send you or on our websites by other organisations, and always with your permission. These Cookies store information about your online activity, such as your IP address, the website you arrived from and information about your purchase history or the content of your shopping basket. They may also contain an identifier that links to your email address.
These cookies enable us to control the frequency and the number of times you may see an advert on your different devices. The cookies also help our advertisers identify potential customers who they feel are relevant for their products.
This means that you may see our adverts or adverts from brands we work with on our websites and on other organisations’ websites. You may also see adverts for other organisations on our websites.
To help us to deliver online advertising that is relevant to you, we may also combine data we collect through Cookies in the browser of your desktop computer or other devices with other data that we have collected, for example what emails you have opened or the postcode you provided to us or through one of our partners when you opted-in.
Cookies can tell us if you have seen a specific advert, and how long it has been since you have seen it. This information allows us to measure the effectiveness of our online advertising campaigns and control the number of times you are shown an advert.
We also use Cookies to measure the effectiveness of our marketing communications, for example by telling us if you have opened a marketing email that we have sent you and if this email was advertising a partner, whether you have then clicked through onto the partner’s website and made a purchase.
Cookies we use:
Cookie / Purpose
Google Analytics: These cookies allow us to collect information about how visitors use the website. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. Click here for an overview of privacy at Google
Google Adsense: Google uses cookies to serve more relevant ads across the web and limit the number of times a given ad is shown to you. When you visit a website, view an ad, or click an ad supported by Google’s advertising services, Google may set a cookie on your browser. This advertising cookie will appear in your browser as coming from the domain “doubleclick.net”. Learn more about Googles Policies
Lotame Data management platform: for the purpose of gaining audience insights and enabling consented audience data to be activated on the below platforms. Lotame uses cookies and other identifiers to track online behavioural, demographic and technographic data; they don’t receive information such as your name and email. Lotame can also receive anonymous data segments that The Race sends, such as user IDs associated with people who have been registered members for a certain length of time. Lotame stores data on average for 9 months, and in special cases for up to 18 months. Lotame’s privacy policy: https://www.lotame.com/about-lotame/privacy/lotames-products-services-privacy-policy
LiveRamp (Acxiom Limited): When you use our website, we share information that we may collect from you, such as your email (in hashed, de-identified form), IP address or information about your browser or operating LIVERAMP CONFIDENTIAL 4 system, with our partner, LiveRamp Inc and its group companies (‘LiveRamp’). LiveRamp may drop a cookie on your browser or directly in our emails and match your shared information to their on- and offline marketing databases and those of its advertising partners to create a link between your browser and information in those other databases. Similarly, when you use our mobile apps, we may also share hashed and de-identified email addresses, mobile device ID, location data, and advertising identifiers with LiveRamp, which uses that information to create a link between your mobile device and its databases. This link may be shared by our partners globally for the purpose of enabling interest-based content or advertising throughout your online experience (e.g. cross device, web, email and in app etc.) by third parties unaffiliated with our website. These third parties may in turn link further demographic or interest-based information to your browser. You have the right to exercise your rights under GDPR including opting out of LiveRamp’s Cookie or Mobile Identifiers and can easily do so by clicking on this link: https://your-rights.liveramp.uk/home
your connection. You can at any time easily oppose the deposit of our cookie by clicking on this link: https://liveramp.uk/cookies-101/.
ESBConnect Limited: esbconnect’s cookies set an identifier linked to your email address this enables us to identify visitors to our advertising clients’ websites and send them a personalised email or serve them personalized ads via display, social, video or mobile. In addition to cookies we use other identifiers to track online behavioural, demographic and technographic data; To opt out of ESB Connect Email please CLICK HERE
You can use your browser settings to accept or reject new Cookies and to delete existing Cookies. You can also set your browser to notify you each time new Cookies are placed on your computer or another device. You can find more detailed information about how you can manage Cookies at the All About Cookies and Your Online Choices websites.
How to Contact us
If you have any questions, complaints or suggestions regarding this policy or our data practices, please email, call or mail us:
Email: data@esbconnect.com
Telephone: (+44) (0) 207459 4985
Mail: ESBConnect Ltd, The Cursitor Building, 38 Chancery Ln, London, WC2A 1EN
Changes to this Privacy Policy
ESB Connect will occasionally update this privacy policy. When we do, we will also revise the last updated date.
Last update: 23/12/2020
