This notice concerns the sharing of consumer marketing data with businesses. This is known as “Business to Consumer” (B2C). It explains how we use any personal information we hold about you, or that passes through our systems.
We are Emailmovers Ltd. (Emailmovers.)
We are a Data Processor in respect of brokered consumer data (B2C), acting under the instructions of our clients.
On the instruction of our Clients, Emailmovers Ltd receive data that is processed by Data OD Ltd (Data On Demand). Data on Demand combine information to create a Single Customer view, where other publicly available, profiled or modelled data may be included.
Newscore Media LLC supply data to Data OD Ltd who process the data and share it with Emailmovers Ltd’s Clients.
Data OD Ltd (Data On Demand)
Newscore Media LLC
Latch Media Limited
BlueVolt Marketing Ltd
We hold and process your data under contract to our clients and data suppliers. Our clients dictate how the data is to be used. This may include contracting us to store or de-duplicate the data. They may contract us to deliver emails to you on their behalf.
The personal data we hold on behalf of our clients may include your name, postal address, date of birth, email address, and landline and mobile telephone numbers. The data is held in separate per-contract files. We do not combine the data files into a database. We are assured that no sensitive information about you is held in these files.
Emailmovers act as a data processor for business to consumer (B2C) marketing data. We are an agent between our clients and Data On Demand. If we hold or process your data, it is as under contract to our client.
Data On Demand are a data aggregator. They source your data from Newscore Media LLC.
We do not share your information with anyone other than under contract with our Clients. Under the contract with our Clients, we may use sub-processors under contract to ourselves. For example, to carry out storage, email delivery and other services.
We process your information as a data processor under contract for our Client. Our lawful basis for this is that we have a legitimate interest in doing so. The Client dictates the processing, so their lawful basis or bases are applicable. These will be either:
Under this lawful basis, your information is only shared for marketing if you have given explicit consent. This means that you have made a positive action to opt-in and agree to Third Parties contacting you by email and/or post and/or telephone channels.
If you give permission to be contacted by advertisers via email, Emailmovers may help find relevant advertisers and support the email communication to you. Emailmovers does not sell this information outright to any advertiser. Any email you might receive will always be sent on behalf of the source to whom you have given your consent. It will always be identified as having originated from this source. This approach is known as “host emailing”. The sender represents the holder of your consent for such communications. Any email received will be clearly identified as having originated from the original data controller. Their details will also always be provided – name, address, telephone number.
When you have registered, applied or made an entry on a Newscore Media LLC operated website you will have been given the opportunity to agree to third party marketing. This marketing would be by email, post and telephone channels. You will have been given a separate choice for each channel.
Under this lawful basis, our clients have a legitimate interest in using direct marketing for their products and services. They may also have a legitimate interest in contacting you for non-marketing purposes. These could include credit and risk assessment and risk management, identification and fraud prevention, debt collection, asset recovery and asset reunification.
Keeping your information secure is important to us. We take all reasonable steps to protect it. We have procedures in place to securely protect your information from unauthorised access, use or disclosure in compliance with the relevant UK legislation. These include: The Privacy & Electronic Communications Regulations (2003) (aka PECR) and the Data Protection Act 2018 incorporating The General Data Protection Regulations (GDPR).
However, the transmission of information via the internet has security risks. We cannot be held responsible for any breach of security which is outside our reasonable control.
You may have data protection rights relating to the processing of your information.
As described above, for the Personal Information we collect and process about you, we act as a processor on behalf of our Clients. Our Clients have their own separate privacy policies. If you want to exercise any data protection rights that may be available to you under applicable law you should contact the relevant Client that is using our services. If you have questions or concerns about how your Personal Information is handled by Emailmovers as a processor on behalf of our Clients, you should contact the relevant Client.
If you no longer want to be contacted by one of our Clients through our services, please unsubscribe directly from that Client’s marketing correspondence. Alternatively, contact the Client directly to update or remove your data. If you contact us directly, we will refer you to Data On Demand, as our contract for the supply of data is with them.
Your data is collected by Newscore Media LLC and processed by Data On Demand. Your rights apply to this processing as well. You can exercise your rights to update your details, remove consent or object to processing using the information on their privacy policies. The link for these is given above.
You have the right to complain to the ICO by visiting their website at http://ico.org.uk/, or by telephoning 0303 123 1113, or by post at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.
Further information on other means of opting out of marketing.
The Edited Electoral Roll or Open Register
The open register, also called the edited register, contains the same information as the full register but is not used for elections or referendums. It is updated and published every month and can be sold to any person, organisation or company for a wide range of purposes. It is used by businesses and charities for checking names and address details; users of the register include direct marketing firms and also online directory firms.
You can choose whether or not to have your personal details included in the open version of the register; however, they will be included unless you ask for them to be removed. Removing your details from the open register will not affect your right to vote.
To opt-out of receiving marketing communication as a result of your being data shared on the Open Register you should visit https://www.gov.uk/get-on-electoral-register and update your preferences.
You can opt out of postal marketing by registering with the Mail Preference Service (MPS) at https://www.mpsonline.org.uk/. This is an industry wide service that is administered by the Direct Marketing Association and recognised by the Information Commissioner.
You can opt out of all telemarketing activity by registering their details with the Telephone Preference Service (TPS) at https://www.tpsonline.org.uk/tps/index.html. The TPS is similar to the MPS but is administered by the Information Commissioner.
Unlike Postal or Telephone channels, there is no industry-wide service to opt out of email marketing. Therefore, consumers should always review privacy policies and marketing opt-in check boxes when registering for services or purchasing products online. Where unwanted email marketing is received, consumers should unsubscribe or use spam filters to prevent future communications. You can visit https://www.tmps.online/ a service provided by Data OD Ltd to manage your marketing consent.
Marketing data is widely used to inform the advertising that is displayed when browsing online. Whilst digital marketers generally do not know the identity of the individual viewing a page, they are able to understand their likely characteristics based on their browsing behaviour or location in order to display a more relevant advert. If you would prefer not to receive targeted advertising in this way you can refer to the device or service instructions to restrict the processing.
Cookies are small files used by websites to recognise returning visitors and tailor content or advertising more effectively. Declining cookies when visiting websites will prevent those sites from displaying targeted advertising, whilst all modern browsers have a setting to clear cookies, which will delete all cookie data stored from previous website visits.
Cookies on Mobile devices
Cookies used for advertising do not generally work on mobile devices, however, advertisers can still recognise returning visitors both when browsing online and when using apps through the use of an ‘Advertising ID’. The Advertising ID is created by the mobile device, but can be reset at any time, thereby deleting all data held against it. Instructions on resetting Advertising ID’s will vary by device but can be found here:
Emailmovers will hold all data until such a point as media partners wish to withdraw their data from the service environment provided. This may result as a consequence of any data processing agreement expiring, management contract being not being renewed or conditions mandated by our retention policy taking effect. At such a time an appropriate data destruction certificate is issued confirming the deletion of all previously held data from Emailmovers systems.