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Privacy Policy

This privacy policy sets out how Pull Digital Limited (“we” or “us”) uses and protects any information that you give us when you use the website www.thepullagency.com.

We are committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy policy.

We may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes.

We collect, use and are responsible for certain personal information about you. When we process your personal information, we comply with the General Data Protection Regulation and the Data Protection Act 2018 and act as the “data controller” of that personal information.

What we collect

We may collect the following information if you provide it to us directly:

  • name and job title.
  • contact information including email address.
  • demographic information such as postcode, preferences and interests.
  • other information given in response to surveys and/or offers.
  • other information given if you contact us through our customer helpdesk. Calls to our helpdesk may be recorded.
 

We may collect the following information automatically:

  • information about your computer or mobile device including, where available, your IP address, the name of your ISP, your operating system, browser type and geolocation.
  • details of your interaction with this website (e.g. page views and clicks).
  • information from the use of cookies and web beacons. Please see the section below headed “How we use cookies” for more information about how that information may be collected and used.
 

What we do with the information we gather

We may use your information for any of the following purposes:

  • Website system administration.
  • Performing operational requests such as registration, login and authentication, password reset and recovery.
  • Performing analysis regarding how you use the website.
  • To improve our products and services.
  • To customise or personalise ads, offers and content made available to you based on your visits to and/or usage of our website or third party websites.
  • Providing and communicating with you about the website or your account.
  • Fulfilling your requests, including without limitation requests for newsletters and notifications.
  • Providing technical support for the website.
  • Responding to your enquiries.
  • Periodically sending you promotional emails about new products, special offers or other information which we think you may find interesting.
  • Contacting you to conduct surveys.
 

In most cases the legal basis for our use of your personal information is that you have given your consent and/or because it is necessary for the purposes of the legitimate interests we pursue (these legitimate interests include improving and maintaining our website, communicating important information to you, tailoring offers to you, identifying and developing new services for us to deliver). We will also use your personal information on the legal basis that it is necessary for us to comply with our legal obligations, for example, if we are required to disclose information to a law enforcement agency. We share certain personal information with third parties to provide advertising to you based on your interests.

We use a number of service providers to provide elements of the website. From time to time, some of these service providers may be based outside the European Economic Area (EEA) and we will transfer your personal information to them there. If we do, we will make use of standard contractual clauses which have been approved by the European Commission or we may adopt other means to ensure that adequate safeguards are applied to your personal information (e.g. Privacy Shield, Binding Corporate Rules, etc). You may obtain a copy of the documents we use to protect your Information when it is transferred outside the EEA by contacting us via email at the address set out below.

Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

How we use cookies

A cookie is a small text file placed on your computer or mobile device. Cookies help us to recognise your browser or device, maintain your preferences, provide certain features, and collect personal information about your online interactions with us, our content and our communications.

Some cookies are required to enable core site functionality. They are essential in order for you to use all the features of our site, for example, accessing secure areas or receiving content appropriate for your device. Other cookies enhance your experience by allowing web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We also use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website in order to tailor it to customer needs. We may use third party services such as Google Analytics for this purpose and those third parties may use their own cookies or similar technologies.

Cookies and other technologies are used to facilitate, manage, and measure the performance of advertisements displayed on the website or that are delivered by or through us. The website may use third party advertising networks to deliver targeted advertising to you. Those third parties may be able to track your browsing across sites, apps and social media sites.

Overall, cookies help us provide you with a better website by enabling us to monitor which pages and advertisements you find useful and which you do not. A cookie in no way gives us access to your computer.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Data retention

In broad terms, we will only retain your personal information for as long as is necessary for the purposes described in this Privacy Policy. This means that the retention periods will vary according to the type of personal information and the reason for which we have the personal information in the first place. For example, some personal information related to the provision of services to you will be kept for a number of years in order to comply with various finance and tax-related legal obligations. Other service-related personal information may be kept for a different period because it is in our legitimate interests to do so in order to provide an appropriate follow-up service.

We have a detailed internal retention policy that sets out varying retention periods for different categories of personal information depending on our legal obligations and whether there is a commercial need. After a retention period has elapsed, the personal information is securely deleted.

Controlling your personal information

You may choose to restrict the collection or use of your personal information in the following ways:

  • whenever you are asked to fill in a form on the website, if you do not want the information to be used by anybody for direct marketing purposes then do not tick the box giving your permission for marketing communications.
  • if you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by emailing us at info@thepullagency.com or writing to us at the address below. Also, any marketing emails we send you will include a link that allows you to unsubscribe from further marketing communications.
 

You have the right to object to the processing of personal information on the basis of our legitimate interests. Where we have asked for your consent to process personal information, you have the right to withdraw this consent at any time.

If you have unresolved concerns, you have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred. You may request details of personal information which we hold about you under the Data Protection Act 2018. You may ask us to correct it, erase it or restrict its processing, and to obtain the personal information you provide in a structured, machine-readable format. You also have the right to ask us to transfer some of this personal information to other organisations. If you wish to do so, please email info@thepullagency.com or write to:

Data Protection Officer
Pull Ltd
Broadford House
Broadford Park
Shalford, Surrey
GU4 8EP
 

If you object to our processing of your personal information, wish to withdraw your consent to processing or believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible at the above address. We will deal with your request promptly.

 

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