OUR COMMITMENT TO YOU
1. The Information We Collect and How We Use It
When you wish to access our site including for example to enter competitions or obtain products and services from us we obtain certain information from you such as your name, address, gender, date of birth, email address and telephone numbers. We may obtain this information from you in a variety of ways including:
- 1. Information that you provide by filling in forms on our site www.gurgl.co.uk or submitting as user content to our site or by use of the interactive services or otherwise. This includes information provided at the time of registering, subscribing to and using our services, posting materials or requesting further services.
- 2. If you contact us, whether by email, post, fax or telephone, or if we contact you, similarly we may keep a record of that correspondence.
- 3. We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
- 4. Details of transactions you carry out through our site.
- 5. Details of your visits to our site including, but not limited to, traffic data, location data, web logs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
- 6. If you enter into any of our competitions or promotions, we may ask for information about you and we will use it in connection with the competition.
- 7. Information you voluntarily provide to us: When you add a contacts data or create an email campaign with our services, we have and may access your contacts data and the information in your email. If a subscribed contact chooses to forward a copy of the email campaign to another contact, it will allow the subscribed contact to share your email content with individuals not on your campaign list. When a subscribed contact forwards an email, we do not store your subscribed contact’s email address or their contacts email address, and no one is added to any group as a result of the forwarded email. The user who created the email campaign only sees the number of times their email campaign has been opened, and other data relevant to the campaign, and does not have access to the email addresses used to forward or receive that forwarded content.
- 8. Information from your use of the service: We may receive information about how and when you use our services, store it in log files or other types of files associated with your account, and link it with other information we collect about you. This information may include, for example, your IP address, date, time, browser used, and actions you have taken within Gurgl. This type of information helps us to improve our Services for both you and for all our users.
We gather this information to allow us to tailor our products and services to you (so that you are offered suitable products and services) and to enable us to administer the website. We may also use this information in connection with contacting you about our products and services.
We may also use aggregate information and statistics for the purposes of monitoring website usage in order to help us develop the website and our services and may provide such aggregate information to third parties. These statistics will not include information that can be used to identify any individual.
From time to time we may provide your information to our customer service agencies for research and analysis purposes so that we can monitor and improve the services we provide. We or our agents and sub-contractors may contact you by post, e-mail or telephone, SMS and other messaging services or fax to ask you for your feedback and comments on our services and products.
We may also wish to provide you with information about other competitions, services or products we think may be of interest to you. You may be contacted by any of the above methods for this purpose. Your information will only be used you for this purpose if you have opted in to receive such communications.
We may also want to provide you with information from third parties we think may be of interest to you. You may be contacted by any of the above methods for this purpose. Your information will only be used you for this purpose if you have opted in to receive such communications.
We may also provide your information to carefully selected third parties whose products or services we believe may be of interest to you. You may be contacted by any of the above methods for this purpose. Your information will only be used you for this purpose if you have opted in to receive such communications.
If you wish us to amend the way in which we use your information or wish only to be contacted by methods (such as email) or opt out of receiving marketing communications altogether, please notify us by sending an e-mail to email@example.com or write to Privacy Manager at Gurgl at the above address.
We may also disclose your personal information if we are required to do so by law for example to regulatory and government agencies and as otherwise permitted by law.
3. How We Protect your Information
The Internet is not a secure medium. However, we have put in place various security procedures to protect your data. We must advise that despite the measures that we take, there is no guarantee that any e-mail sent by you to us at this site will be received by Gurgl, or that the message will remain confidential whilst in transit. You therefore accept that by acknowledging this situation that you do so at your own risk.
Gurgl requires a username and password to log in. You must keep your username and password secure, and never disclose it to a third party. The information in your CRM is sensitive, which means account passwords are encrypted, which means your passwords will never be seen. We cannot resent forgotten passwords either, we will only reset them.
5. Use and Disclosure of Personal Information
We may use and disclose personal information only for the following reasons:
- 1. Billing our Members: This includes sending you emails, receipts, invoices, notices of late payment, and alerting you if we need a different credit card number.
- 3. To Communicate with our Users about their Account with Gurgl and offer Customer Support.
- 5. To Protect the Rights and Safety of our Users and Third Parties, as well as our own.
- 6. To meet Legal Requirements: including but not limited to complying with valid discovery requests, court orders, valid subpoenas, and other appropriate legal mechanisms.
- 7. To Provide Support and Improve the Services we Offer: This includes our use of data that our users provide us with in order to enables our users to use the services to communicate with their subscribed contacts. This also includes, for example, aggregating information from your use of services or visit to our website and sharing this information with third parties to improve our services. This might also include sharing your own information or the information you provide us about your subscribed contacts with third parties in order to provide and support our services or to make certain features of the service available to you.
6. Data Collected for and by our Users
As you use our services, you may import into our system personal information you have collected from your contacts or other individuals. We have no direct relationship with your subscribers or any person other than you, and for that reason, you are responsible for making sure you have the appropriate permissions for us to collect and process information about these individuals. Consistent with the uses of personal information covered in section 5, we may transfer personal information of you or your subscribers to companies that help us promote, provide, or support our services or the services of our users. All service providers enter into a contract with us that protects personal information and restricts their use of any personal information consistent with this policy. As part of our services, we may use and incorporate into features information you have provided, we have collected from you, or we have collected about subscribed contacts. On rare occasions we may need to share this information, including subscriber email addresses, with third parties in line with the approved uses in section 5.
If you are a subscribed contact and no longer want to be contacted by one of our users, please unsubscribe directly from that user’s newsletter or contact the user directly to update or delete your data. If you contact us, we may remove or update your information within a reasonable time and after providing notice to the user of your request.
We will retain personal information we process on behalf of our users for as long as needed to provide our services or to comply with our legal obligations, resolve disputes, prevent abuse, and enforce our agreements.
7. Public Information and Third-Party Websites
- 1. Social Media Platforms and Widgets: Our website includes social media features. These features may collect information about your IP address and which page you are visiting on our website, and they may set a cookie to make sure the feature functions properly. Social media features and widgets are either hosted by a third party or hosted directly on our website. We also maintain presences on social media platforms including Twitter, Facebook, Instagram and LinkedIn. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.
8. Third Parties
We may disclose personal information to the following types of third parties for the purpose described in this policy:
- 2. Service Providers: Sometimes, we share your information with our third-party Service Providers, who help us provide and support our Services. For example, if it is necessary to provide you something you have requested (like enable a feature such as Social Profiles), then we may share your and/or your Subscribers’ Personal Information with a Service Provider for that purpose. Just like with the other third parties we work with; these third-party Service Providers enter into a contract that requires them to use your Personal Information only for the provision of services to us and in a manner that is consistent with this policy. Examples of Service Providers include payment processors, hosting services and content delivery services.
9. Content of Email Campaigns
When you send an email marketing campaign, it bounces from server to server across the internet. Along the way, server administrators can read what you send. Please do not use Gurgl to send confidential information.
10. Your Contacts Data
Your contacts data can be created in a number of ways, including by importing contacts, such as through csv or entering the data manually. Your distribution lists are stored on a secure Gurgl server. We do not, under any circumstances, sell your contacts data. If someone of your contacts database complains or contacts us, we might then contact that person. Only authorised employees have access to view your contacts data. You may export (download) your contacts database from Gurgl at any time.
If we detect abusive or illegal behaviour related to your contact database, we may share your contact database or portions of it with affected ISP’s or anti-spam organisations.
11. Sale of Business
If our business is sold or integrated with another business your details may be disclosed to our advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business.
12. Updating your Details
If any of the information that you have provided us changes, for example if you change your e-mail address or name, please let us know the correct details by sending an e-mail to firstname.lastname@example.org or by sending a letter to your Account Manager at Gurgl at our business address.
13. Your Consent
14. How to Contact Gurgl
15. Data Controller
Gurgl processes personal data both as a processor and controller as defined in the directive and the GDPR.
The Gurgl entity which you as a user entered an agreement with when using Gurgl’s platform, will be the controller of user data.
For respondent’s data, as outlined above in the ‘Collections of User data’ section.
For respondent’s data, the users will be the controller in accordance with directive and GDPR and Gurgl will be the processor.
Gurgl adheres to the directive of 1995 and the GDPR from May 25th 2018. Consequently, Gurgl processes all data provided by its users with accounts in its European Data Region, in the European Economic Area (EEA) only.
All data collected by Gurgl users through surveys will be stored exclusively in secure hosting facilities provided by Amazon Web Services. Gurgl has a data processing agreement in place with its provider, ensuring compliance with the directive. All hosting is performed in accordance with the highest security regulations. All transfers of data internally in the EEA is done in accordance with this data processing agreement.
16. Contact Information for the Data Controller
You can contact us at any time to:
- 1. Request access to information stored about you
- 2. Correct any information stored about you
- 3. Delete any information stored about you
17. Your Rights under GDPR
- 1. The Right to be Informed: All organisations must be completely transparent in how they are using personal data (personal data may include data such as a work email and work mobile if they are specific to an individual).
- 2. The Right of Access: Individuals will have the right to know exactly what information is held about them and how it is processed.
- 3. The Right of Rectification: individuals will be entitled to have personal data rectified if it is inaccurate or incomplete.
- 4. The Right to Erasure: Also known as ‘the right to be forgotten’, this refers to an individual’s right to having their personal data deleted or removed without the need for specific reason as to why they wish to discontinue.
- 5. The Right to Restrict Processing: An individual’s right to block or suppress processing of their personal data for their own purpose.
- 6. The Right to Data Portability: This allows individuals to retain and reuse their personal data for their own purpose.
- 7. The Right to Object: In certain circumstances, individuals are entitled to object to their personal data being used. This includes, if a company uses personal data for direct marketing, scientific and historical research, or for the performance of a task in the public interest.
18. EU Clients
For EU clients, Gurgl complies with the EU Data Protection Directive 95/46/EC framework as set forth by the European Union regarding the collection, use, and retention of personal data from European Union member countries and Switzerland, Gurgl has certified that it adheres to the requirements of notice, choice, onward transfer, security, data integrity, access and enforcement.
19. Access, Correction Deletion
We respect your privacy rights and provide you with reasonable access to the personal data that you may have provided through your use of the services. If you wish to access or amend any other personal data we hold about you, or to request that we delete any information about you that we have obtained from an integrated service, you may contact us as set forth in the ‘How to contact Gurgl’ section. At your request, we will have any reference to you deleted or blocked in our database.
You may update, correct, or delete your account information and preferences at any time by accessing your account settings page on the service. Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.
You may decline to share certain personal data with us, in which case we may not be able to provide to you some of the features and functionality of the service.
At any time, you may object to the processing of your personal data, on legitimate grounds, except if otherwise permitted by applicable law.
20. Data Retention
Gurgl does not own, control or direct the use of any of the client data stored or processed by a client or user via the service. Only the client or users are entitled to access, retrieve and direct use of such client data. Gurgl is largely unaware of what client data is being stored or made available by a client or user to the service and does not directly access such client data except as authorised by the client, or as necessary to provide services to the client and its users.
The client or user is the data controller under the directive for any client data containing personal data, meaning that such party controls the manner such personal data is collected and used as well as the determination of the purposes and means of the processing of such personal data.
Gurgl is not responsible for the content of the personal data contained in the client data or other information stored on its services (or its subcontractors’ servers) at the discretion of the client or user nor is Gurgl responsible for the way the client or user collects, handles disclosure, distributes or otherwise processes such information.