This privacy notice tells you what to expect when Brand Led Growth collects or processes personal data during the course of our commercial activities as a strategic marketing consultancy. Personal data is information that can be associated with or which relates to a person, and/or which could be used to identify a person.
In the course of our work we may undertake customer research and we are committed to protecting the privacy of everyone that participates in research with us, and to processing their personal data with due care across our organisation. To that end we have developed this notice in compliance with all applicable data protection regulations, and to demonstrate our firm commitment to your privacy. We endeavour to ensure that any personal data you give us remains private and is used only for the purposes outlined in this Privacy Notice. Brand Led Growth Ltd is the controller (as defined under data protection law) and responsible for your personal data. This version of our Privacy Notice was last updated on 13 February 2020.
1. About our privacy notice
This Privacy Notice applies to any individuals who participate in any market research surveys and focus groups we may run, including by way of telephone interviews, social media groups and in-person discussion groups. Brand Led Growth Ltd endeavours to ensure that any personal data you give us, whether via our Website, by telephone, by post, by email, in a survey or during a focus group session, or any other method of communication remains private and is used only for the purposes outlined in this Privacy Notice. By agreeing to participate in our market research surveys and focus groups, you acknowledge the processing and use of your personal data as outlined below.
2. Personal data we collect and process
The personal data required to apply to us for the purposes of participating in our market research surveys and focus groups include your name and email address. When submitting your personal data to us, we will process the following categories of personal data:
- Identity Data such as first name, surname, gender, date of birth, as well as recorded audio or audiovisual footage of your participation in our research group sessions.
- Contact Data such as address, e-mail address, telephone number.
- Profile Data such as your age, location, occupation, interests, preferences and feedback and other information which may be collected in the course of your participation in market research surveys or focus groups such as content or material you choose to submit, upload or transmit via social media platforms or Whatsapp groups, including but not limited to photos, videos, images, etc.
We may also collect, store and use the following more sensitive types of personal data (which shall be anonymised when we receive it):
- Information about your attitudes towards sexual habits and preferences as well as drugs;
- Information about your race or ethnicity;
- Information about your health, including whether you suffer from obesity.
Where we need to collect personal data by law, or so we can carry out your instructions, or where this is necessary under the terms of a contract we have with you (e.g. our terms of engagement) and you fail to provide that personal data when requested, we may not be able to carry out your instructions or perform the contract we have or trying to enter into with you. In this case, we may not be able to properly engage with you in relation to your participation in our market research surveys, focus groups and sessions and this may result in us having to terminate our contract with you, but we will notify you if this is the case at the time.
We also collect, use and have aggregated data such as statistical or demographic data for various purposes. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.
3. How we collect your personal data
If you apply to participate in our market research surveys, groups and/or meetings and/or if you participate in any such surveys, groups and/or meetings, you are likely to provide us with some or all of your Identity, Contact and Profile Data.
We may receive your Identity, Contact and Profile Data in some/all of the following ways:
- Via direct sources: for example, where such data is sent directly to us from you, whether by email, phone, letter, our website, external websites, online or paper surveys, during the course of research groups or discussions or other meetings, or some other form of communication; and/or
- Via third parties: for example, research respondent recruitment agencies, service providers (such as IT suppliers) including video and conference calling technology providers or agents.
4. How we use your personal data
We will only use your personal data when the law allows us to. We will use your personal data in the following circumstances:
- where you have provided your consent to us to use your personal data in a certain way;
- where necessary for the performance of a contract (for example, to allow you to participate in a survey or focus group for which you have registered);
- where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and
- where we need to comply with a legal or regulatory obligation.
We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your personal data. Please contact us using the contact details provided below if you need details about the specific legal ground we are relying on to process your personal data.
5. We use your personal data in the following ways:
- We will use your Identity, Contact and Profile Data in order to to maintain our records. This involves profiling. This is necessary for our legitimate interest to respond to your enquiries and to keep our records up to date.
- We will collect and use Identity, Contact and Profile Data during market research focus groups and sessions, including during the process of arranging such groups and sessions. This is necessary for our legitimate interest of running our business, to keep our records updated. This is also necessary for our performance of our contract with you.
- We will collect and use Identity, Contact and Profile Data for the purposes of preparing market research reports for our clients, in order to enable our clients to better provide goods and services to their customers. This is necessary for our legitimate interest of conducting our business as a market research and analytics company and undertaking market research on behalf of our clients.
6. How we us special categories of personal data
“Special categories” of personal data, such as information revealing your health, racial or ethnic origin or sexual habits require higher levels of protection. We may collect, use and have aggregated special categories of personal data on such as statistical or demographic data for various purposes. This data is anonymised before we receive it. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.
7. Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may also process where this is required or permitted by law.
8. Disclosure of personal data to others
Except as set out in this Privacy Notice, we do not disclose to any third party personal data that we collect or you provide to us. We may disclose your personal data to third parties expressly mentioned in this Privacy Notice and the following third parties:
- our clients who have engaged us to carry out market research surveys, groups and/or meetings in which you have been involved. In some cases, these clients may be present during a focus group session in which you participate. Your survey and focus group responses are not attributed to you in client reports unless you expressly consent to us doing so;
- any member of our group of companies, which means our subsidiaries, our ultimate holding company and its subsidiaries, where it is necessary to do so for the provision and administration of our services and your participation in our market research surveys and focus group sessions;
- professional advisors such as accountants, auditors, lawyers, insurers, and other outside professional advisors;
- third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Notice; and/or
- third party suppliers whom we engage to assist us with providing our services; for example, web hosting services (if this relates to online user accounts) or third party video sharing platforms, for the purposes of storing any recorded audiovisual footage of your participation in our research groups.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. Unless prevented by applicable law, we will notify you when your personal data may be provided to third parties in ways other than explained above, and you may have the option to prevent such sharing at the time that we notify you.
9. International data Transfers
We shall not transfer your personal data outside the EEA without your explicit consent.
10. Updating your personal data
It is important that the personal data we hold is accurate and current. Please keep us by using the Contact Us information below if any of your personal data changes during your relationship with us. It is your responsibility to keep your personal data up to date at all times.
11. Data security
We are committed to maintaining the security of personal data processed pursuant to this Privacy Notice. We maintain appropriate physical, procedural, organisational and technical security measures intended to prevent loss, misuse, unauthorised access, disclosure, or modification of personal data under our control. However, you recognise that no entity can keep personal data 100% secure. If you have reason to believe that any of your personal data is no longer secure, please notify us immediately by contacting us.
12. Data retention
We retain personal data for no longer than is allowed under data protection law and, in any case, no longer than such personal data is necessary for the purpose for which it is processed. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
We will retain any personal data which you provide to us in connection with specific research project by no later than 10 days after the date on which that project is completed. If we anonymise your data, we will keep a record of this.
13. Your legal rights
Under certain circumstances you have rights under applicable data protection law in relation to personal data, namely:
- Request access to your personal data a (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time if and to the extent we are relying on consent as the legal basis to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contactyou to ask you for further information in relation to your request to speed up our response. In order to exercise one or more of your rights in respect of your personal data, please contact us using the information provided in the Contact Us section below. We will respond to your request(s) as soon as reasonably practicable, but in any case within the legally required period of time. You have the right to make a complaint at any time to the Data Protection Commission, the Irish supervisory authority for data protection issues (www.dataprotection.ie). We would, however, appreciate the chance to deal with your concerns before you approach the Data Protection Commission so please contact us in the first instance using the information listed in the Contact Us section below.
14. Changes to our privacy notice
Any changes we may make to our Privacy Notice in the future will be posted on this page, you may also be notified by email. You should visit this page periodically to review any changes to the Privacy Notice.
15. Contact us
If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact us by email on firstname.lastname@example.org