Altitude Group PLC, (“Altitude Group PLC” or the “Company”) is committed to protecting the privacy of individuals who visit any of the Company’s Web sites (“Visitors”), individuals who register to use the Services as defined below (“Customers”), and individuals who register to attend the Company’s corporate events (“Attendees”). This Privacy Statement describes Altitude Group PLC’s, which includes Customer Focus, Promoserve, Technologo and AdProducts privacy practices in relation to the use of the Company’s Web sites and the related applications and services offered by Altitude Group PLC (the “Services”).
Altitude Group PLC complies with the U.S.-EU Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. Altitude Group PLC has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, please visit http://www.export.gov/safeharbor/
Altitude Group PLC is also registered with the UK Information Commissioner’s Office for Data Protection, please visit http://www.ico.gov.uk/
1. Web Sites Covered
This Privacy Statement covers the information practices of Web sites that link to this Privacy Statement, including: http://altitudeplc.com; http://www.ppda.co.uk; http://www.tradeonlysearch.com; http://www.customerfocus.com; http://www.promoserve.co.uk; http://www.technolgo.com; http://www.adproducts.com; http://artworktool.com/ (collectively referred to as “Altitude Group PLC’s Web sites” or “the Company’s Web sites”).
Altitude Group PLC’s Web sites may contain links to other Web sites. The information practices or the content of such other Web sites is governed by the privacy statements of such other Web sites. The Company encourages you to review the privacy statements of other Web sites to understand their information practices.
2. Information Collected
When expressing an interest in obtaining additional information about the Services or registering to use the Services, Altitude Group PLC requires you to provide the Company with personal contact information, such as name, company name, address, phone number, and email address (“Required Contact Information”). When purchasing the Services, Altitude Group PLC may require you to provide the Company with financial qualification and billing information, such as billing name and address, credit card number, and the number of employees within the organization that will be using the Services (“Billing Information”). Altitude Group PLC may also ask you to provide additional information, such as company annual revenues, number of employees, or industry (“Optional Information”). Required Contact Information, Billing Information, and Optional Information about Customers are referred to collectively as “Data About Altitude Group PLC Customers”, or in the case of Attendees, “Data About Altitude Group PLC Attendees”.
As you navigate the Company’s Web sites, Altitude Group PLC may also collect information through the use of commonly-used information-gathering tools, such as cookies and Web beacons (“Web Site Navigational Information”). Web Site Navigational Information includes standard information from your Web browser (such as browser type and browser language), your Internet Protocol (“IP”) address, and the actions you take on the Company’s Web sites (such as the Web pages viewed and the links clicked). For additional information about the collection of Web Site Navigational Information by Altitude Group PLC and others please read section 4 below.
In the course of signing up for and using Altitude Group PLCs Services, consulting with our support teams, sending us an email, buying our products or communicating with us in any way, you are voluntarily giving us information that we collect. That information may include either your or your end-users’ name, email address, IP address, phone number, postal address, in addition to other details that may include gender, location, occupation or other information of a demographic nature. In supplying this information, you consent to this information being collected, used, disclosed, transferred to Altitude Group PLC companies and stored by us, as described in our Terms and this Privacy Statement.
We also obtain personal information from your use of the Altitude Group PLC Services. When you upload end-user data in the Services, we may have access to the data. We receive information about how you use the Services and store it in log files or other types of files associated to your account and link it to other information we hold about you. This information might include the date of any activity, your browser and IP address as well as actions you have taken within the Services. This information helps us to improve the Services for all Customers.
3. Use of Information Collected
The Company uses Data About Altitude Group PLC Customers to perform the services requested. For example, if you fill out a “Contact Me” Web form, the Company will use the information provided to contact you about your interest in the Services.
The Company also uses data collected to help with Customer Support queries. The Company uses your information to resolve technical issues you encounter, to respond to your requests for assistance, and to repair and improve the Services.
The Company also uses Data About Altitude Group PLC Attendees to plan and host corporate events, host online forums and social networks in which event attendees may participate, and to populate online profiles for Attendees on the Company’s Web sites. Additional information on the Company’s privacy practices with respect to Data About Altitude Group PLC Attendees may be found in additional privacy statements on the event Web sites, as the case may be.
The Company may also use Data About Altitude Group PLC Customers and Data About Altitude Group PLC Attendees for marketing purposes. For example, the Company may use information you provide to contact you to further discuss your interest in the Services and to send you information regarding the Company, its affiliates, and its partners, such as information about promotions or events.
Altitude Group PLC uses Web Site Navigational Information to operate and improve the Company’s Web sites. The Company may also use Web Site Navigational Information alone or in combination with Data About Altitude Group PLC Customers and Data About Altitude Group PLC Attendees to provide personalized information about the Company. For additional information about the use of Web Site Navigational Information, please read section 4 below.
Legal bases for processing (for EEA users):
If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable EU laws. The legal bases depend on the Services you use and how you use them. This means we collect and use your information only where:
We need it to provide you the Services, including to operate the Services, provide customer support and personalized features and to protect the safety and security of the Services;
It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services and to protect our legal rights and interests;
You give us consent to do so for a specific purpose; or
We need to process your data to comply with a legal obligation.
If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the Services.
How long we keep information:
How long we keep information we collect about you depends on the type of information, as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.
Account information:
We retain your account information for as long as your account is active and a reasonable period thereafter in case you decide to re-activate the Services. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our Services. Where we retain information for Service improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyze personal characteristics about you.
Information you share on the Services:
If your account is deactivated or disabled, some of your information and the content you have provided will remain in order to allow your team members or other users to make full use of the Services. For example, we continue to display messages you sent to the users that received them and continue to display content you provided.
Managed accounts:
If the Services are made available to you through an organization (e.g., your employer), we retain your information as long as required by the administrator of your account. For more information, see “Managed accounts and administrators” above.
Marketing information:
If you have elected to receive marketing emails from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our Services, such as when you last opened an email from us or ceased using your Services.
4. Web Site Navigational
Cookies, Web Beacons and IP Addresses
Altitude Group PLC uses commonly-used information-gathering tools, such as cookies and Web beacons, to collect information as you navigate the Company’s Web sites (“Web Site Navigational Information”). This section describes the types of Web Site Navigational Information used on the Company’s Web sites and how this information may be used.
Cookies
Altitude Group PLC uses cookies to make interactions with the Company’s Web sites easy and meaningful. When you visit one of the Company’s Web sites, Altitude Group PLC’s servers send a cookie to your computer. Standing alone, cookies do not personally identify you; they merely recognize your Web browser. Unless you choose to identify yourself to Altitude Group PLC, either by responding to a promotional offer, opening an account, or filling out a Web form (such as a “Contact Me” or other Web form), you remain anonymous to the Company.
Altitude Group PLC uses cookies that are session-based and persistent-based. Session cookies exist only during one session. They disappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you close your browser or turn off your computer. Please note that if you disable your Web browser’s ability to accept cookies, you will be able to navigate the Company’s Web sites, but you will not be able to successfully use some of the services.
For more information on how we use cookies, please read our cookie information page
Web Beacons
Altitude Group PLC will at times use Web beacons alone or in conjunction with cookies to compile information about Customers and Visitors’ usage of the Company’s Web sites and interaction with emails from the Company. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular Web site tied to the Web beacon, and a description of a Web site tied to the Web beacon. For example, Altitude Group PLC may place Web beacons in marketing emails that notify the Company when you click on a link in the email that directs you to one of the Company’s Web sites. Altitude Group PLC uses Web beacons to operate and improve the Company’s Web sites and email communications.
IP Addresses
When you visit Altitude Group PLC’s Web sites, the Company collects your Internet Protocol (“IP”) addresses to track and aggregate non-personal information. For example, Altitude Group PLC uses IP addresses to monitor the regions from which Customers and Visitors navigate the Company’s Web sites.
Altitude Group PLC also collects IP addresses from Customers when they log into the Services as part of the Company’s “Identity Confirmation” and “IP Range Restrictions” security features.
5. Public Forums, Refer a Friend, and Customer Testimonials
Altitude Group PLC may provide bulletin boards, blogs, or chat rooms on the Company’s Web sites. Any personal information you choose to submit in such a forum may be read, collected, or used by others who visit these forums, and may be used to send you unsolicited messages. Altitude Group PLC is not responsible for the personal information you choose to submit in these forums.
Customers and Visitors may elect to use the Company’s referral program to inform friends about the Company’s Web sites. When using the referral program, the Company requests the friend’s name and email address. Altitude Group PLC will automatically send the friend a one-time email inviting him or her to visit the Company’s Web sites. Altitude Group PLC does not store this information.
Altitude Group PLC posts a list of Customers and testimonials on the Company’s Web sites that contain information such as Customer names and titles. Altitude Group PLC obtains the consent of each Customer prior to posting any information on such a list or posting testimonials.
6. Sharing of Information Collected
Service Providers
Altitude Group PLC may share Data About Altitude Group PLC Customers and Data About Altitude Group PLC Attendees with the Company’s contracted service providers so that these service providers can provide services on our behalf. Altitude Group PLC may also share Data About Altitude Group PLC Customers with the Company’s service providers to ensure the quality of information provided. All Service Providers are required to comply with GDPR. Unless described in this Privacy Statement, Altitude Group PLC does not share, sell, rent, or trade any information with third parties for their promotional purposes.
7. Altitude Group PLC Affiliates
The Company may share Data About Altitude Group PLC Customers with other companies in order to work with them, including affiliates of the Altitude Group PLC corporate group. For example, the Company may need to share Data About Altitude Group PLC Customers for customer relationship management purposes.
8. Business Partners
From time to time, Altitude Group PLC may partner with other companies to jointly offer products or services. If you purchase or specifically express interest in a jointly-offered product or service from Altitude Group PLC, the Company may share Data About Altitude Group PLC Customers collected in connection with your purchase or expression of interest with our joint promotion partner(s). Altitude Group PLC does not control our business partners’ use of the Data About Altitude Group PLC Customers we collect, and their use of the information will be in accordance with their own privacy policies. If you do not wish for your information to be shared in this manner, you may opt not to purchase or specifically express interest in a jointly offered product or service.
Altitude Group PLC does not share Data About Altitude Group PLC Attendees with business partners unless: (1) you specifically opt in to such sharing via an event registration form; or (2) you attend a Company event and have your attendee badge scanned by a business partner. Your information with business partners in the manners described above will be subject to the business partners’ respective privacy statements.
9. Billing
Altitude Group PLC uses a third-party service provider to manage credit card processing. This service provider is not permitted to store, retain, or use Billing Information except for the sole purpose of credit card processing on the Company’s behalf.
10. Compelled Disclosure
Altitude Group PLC reserves the right to use or disclose information provided if required by law or if the Company reasonably believes that use or disclosure is necessary to protect the Company’s rights and/or to comply with a judicial proceeding, court order, or legal process.
11. International Transfer of Information Collected
To facilitate Altitude Group PLC’s global operations, the Company may transfer and access Data About Altitude Group PLC Customers and Data About Altitude Group PLC Attendees from around the world, including the United States. This Privacy Statement shall apply even if Altitude Group PLC transfers Data About Altitude Group PLC Customers or Data About Altitude Group PLC Attendees to other countries. Altitude Group PLC meets the requirements of the framework as outlined by the U.S. Department of Commerce and the European Union for International transfers. For more information on the EU Safe Harbor Framework, please visit http://www.export.gov/safeharbor/.
12. Communications Preferences
Altitude Group PLC offers Visitors, Customers, and Attendees who provide contact information a means to choose how the Company uses the information provided. You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of the Company’s marketing emails. Additionally, you may send a request specifying your communications preferences to info@tradeonly.com. Customers cannot opt out of receiving transactional emails related to their account with Altitude Group PLC or the Services.
13. Correcting and Updating Your Information
Customers may update or change their registration information by contacting us by email. To update Billing Information or have your registration information deleted, please email info@customerfocus.com or call +44 (0) 844 880 2751. To discontinue your account and to have information you maintained in the Services returned to you, please email info@customerfocus.com or call +44 (0) 844 880 2751. Requests to access, change, or delete your information will be handled within 30 days.
14. Customer Data
Altitude Group PLC Customers may electronically submit data or information to the Services for hosting and processing purposes (“Customer Data”). Altitude Group PLC will not review, share, distribute, or reference any such Customer Data except as provided in the Altitude Group PLC Master Subscription Agreement, or as may be required by law. In accordance with the Altitude Group PLC Master Subscription Agreement, Altitude Group PLC may access Customer Data only for the purpose of providing the Services, preventing or addressing service or technical problems, at a Customer’s request in connection with customer support matters, or as may be required by law.
15. Security
Altitude Group PLC uses robust security measures to protect Customer Data from unauthorized access, maintain data accuracy, and help ensure the appropriate use of Customer Data. When the Services are accessed using Internet Explorer version 7.0 or later, Firefox version 2.0 or later, or Safari version 3.0 or later, Secure Socket Layer (.SSL.) technology protects Customer Data using both server authentication and data encryption. These technologies help ensure that Customer Data is safe, secure, and only available to the Customer to whom the information belongs and those to whom the Customer has granted access. Altitude Group PLC also implements an advanced security method based on dynamic data and encoded session identifications, and the Company hosts its Web sites in a secure server environment that uses firewalls, and other technology to prevent interference or access from outside intruders. Altitude Group PLC also offers enhanced security features within the Services that permit Customers to configure security settings to the level they deem necessary. Customers are responsible for maintaining the security and confidentiality of their usernames and passwords.
Because the Company uses the Services to maintain Data About Altitude Group PLC Customers and Data About Altitude Group PLC Attendees, this information, which is stored in the Services, is secured in the same manner as described above for Customer Data.
Altitude Group PLC has procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
16. Your Rights
Under the General Data Protection Regulation, you have a number of important rights.
In summary, those include rights to:
fair processing of information and transparency over how we use your use personal information
access to your personal information and to certain other supplementary information that this Privacy Statement is already designed to address
require us to correct any mistakes in your information which we hold
require the erasure of personal information concerning you in certain situations
receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
object at any time to processing of personal information concerning you for direct marketing
object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
object in certain other situations to our continued processing of your personal information
otherwise restrict our processing of your personal information in certain circumstances
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
email or write to us at Altitude Group PLC Privacy, Unit 4 Rhodes Business Park, Silburn Way, Manchester Old Road, Middleton Manchester, M24 4NE, United Kingdom
include enough information to identify you
provide proof of your identity and address
let us know the information to which your request relates, including any account or reference numbers, if you have them
To unsubscribe from any email newsletters or marketing campaigns, you can also click on the ‘unsubscribe’ button at the bottom of the email. It may take up to 24 hours for this to take place.
The Right to Complain
If you have questions or complaints regarding Altitude Group PLC’s Privacy Statement or associated practices, please contact us here.
The General Data Protection Regulation gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone at 0303 123 1113 or other channels as updated at https://ico.org.uk/global/contact-us/.
17. Changes to this Privacy Statement
Altitude Group PLC reserves the right to change this Privacy Statement from time to time. When changes are made, you will be informed via email.
18. Contacting Us
Questions regarding this Privacy Statement or the information practices of the Company’s Web sites should be directed to Altitude Group PLC Privacy by clicking here or by mailing Altitude Group PLC Privacy, Unit 4 Rhodes Business Park, Silburn Way, Manchester Old Road, Middleton Manchester, M24 4NE, United Kingdom.