This version is effective from: 11th May 2022
This Privacy Notice (“Privacy Notice”) sets out how the Institute of Practitioners in Advertising (“IPA”) in conjunction with the Incorporated Society of British Advertisers Limited (“ISBA”) processes your personal data in connection with our website at pitchpositivepledge.co.uk (“Site”) and the Pitch Positive Pledge Initiative (“Initiative”).
We will update this Privacy Notice from time to time to reflect any changes or proposed changes to our use of your personal data, or to comply with changes in applicable law or regulatory requirements. We may notify you by email of any significant changes to this Privacy Notice, but we encourage you to review this Privacy Notice periodically to keep up to date on how we use your personal data. If we update this Privacy Notice, we will update the effective date at the top of the page.
This Privacy Notice explains our approach to any personal data that we might collect from you or which we have obtained about you from a third party, and the purposes for which we process your personal data, solely in connection with the Initiative. This Privacy Notice also sets out your rights in respect of our processing of your personal data in connection with the Initiative.
The IPA is incorporated by Royal Charter established under the laws of England and Wales (company no: RC000884) with its registered office at 44 Belgrave Square, London, SW1X 8QS
ISBA is a company established under the laws of England and Wales (company no: 00068497) with its registered office at 12 Henrietta Street, London, WC2E 8LH.
Where ISBA and IPA are processing your personal data solely in conjunction with the Initiative, they will be considered joint controllers in respect of such processing. This means that both the IPA and ISBA are responsible for any personal data that either organisation collects or uses in connection with the Initiative.
However, to the extent IPA and/or ISBA process your personal data for their own independent purposes (i.e., in connection with your membership to their respective organisations), they shall do so as independent controllers. Please see their respective privacy notices above for more information about how they may process your personal data as independent controllers.
Where this Privacy Notice refers to “IPA” or “ISBA””, “we”, “us, “our”, this means one or both of the particular companies as the context requires.
If you have any questions about this Privacy Notice or want to exercise your rights as a data subject set out in this Privacy Notice, you can contact us using the following methods:
Send us an email at: The IPA - firstname.lastname@example.org .
Write to us at: The IPA, 44 Belgrave Square, London, SW1X 8QS.
Call us on: The IPA - 02072357020
We may collect and process different types of personal data about you for different processing purposes in connection with the Initiative. The types of personal data we collect depends on who you are and how you use our Site and/or your level of involvement in the Initiative, and includes the following:
First name; last name.
Email address; telephone number; any other personal data that you may provide when you register your interest in being contacted about the Initiative.
Contact preferences; the content of any forms you complete on the Site.
IP address; browser type and operating system; geolocation, to ensure we’re showing you the correct notices and information; any other unique numbers assigned to a device.
We collect and receive personal data using different methods:
Personal data you provide to us
You may give us your personal data directly, for example, when you register your interest in being contacted about the Initiative, contact us with enquiries, and complete forms on our Site or provide feedback to us.
Personal data we collect using cookies and other similar technologies
When you access and use our Site, we will collect certain Behavioural Data and Technical Data. We collect this personal data by using cookies and other similar technologies (see the “Insight, analysis and retargeting through Cookies” section below).
We collect and process personal data from the following people:
If you browse our Site, we will collect and process your personal data in connection with your interaction with us and our Site.
If you express interest in the Initiative, we may collect and process your personal data in connection with the Initiative.
People who contact us with enquiries
If you contact us with an enquiry through our Site or submit a complaint through our Site or would otherwise like to be involved in the Initiative, we will collect and process your personal data in connection with your interaction with us and our Site.
We use your personal data for the purposes set out in this section. If we wish to make any changes to these purposes, or if we wish to use your personal data for any purpose that is not listed in this section, we will notify you using the contact details we hold for you.
If you browse our Site or interact with a communication from us
Our legal basis for processing
Where the data we collect is strictly necessary for the purpose of providing the Site or to ensure that we provide access to our Site in a secure and effective way, we shall rely on performance of a contract to process the data we collect. However, where we process personal data for our own analytical or advertising purposes or so that we can make improvements to the Site, we shall rely on consent.
If you express interest in the Initiative and to operate the Initiative
If you express an interest in the Initiative, we will collect and maintain personal data that you submit to us in connection with the Initiative for the purpose of operating the Initiative. We may collect and process your personal data whether you are interacting with us on your own behalf or on behalf of any organisation you represent.
The personal data we process may include your Identity Data, Contact Data, and Profile Data. We process this information so that we can operate the Initiative and keep a record of interested individuals.
Our legal basis for processing
It is in our legitimate interest or a third party’s legitimate interest to use personal data in such a way to ensure the successful operation of the Initiative.
If you have a general question or need help with any issue concerning our Site or the Initiative
You are able to contact us (see the “How to contact us” section above) by email.
When you make an contact us in this way, we will collect and process your Identity Data, Contact Data and, if applicable, certain Profile Data, as well as any other personal data you volunteer that is relevant to your enquiry. If you have a technical issue concerning our Site, we may also collect and process Behavioural Data and Technical Data to help us diagnose the technical issues you are experiencing and to help us resolve them in an efficient way. We use this information to manage and respond to your enquiry.
Our legal basis for processing
It is in our legitimate interest to use your personal data in the ways described above to ensure that we are able to help you with your enquiry, provide a good standard of service, and improve our customer services.
If we send you marketing communications by email
We use your Identity Data, Contact Data, and Profile Data to send you (or the organisation you represent) marketing communications by email. Our marketing will include press releases and information about us, our Site, and our Initiative.
Our legal basis for processing
It is in our legitimate interest to use your personal data for marketing purposes, for example, to decide what marketing content we think may appeal to you.
It is in our legitimate interest to use your personal data to send our marketing to you by post.
However, in some situations we will only send marketing communications to you by email where you have consented to receive such content by email (for example, if you are a sole trader).
If we need to use your personal data to comply with our legal obligations or in connection with the administration of our business
We may use your personal data: (i) to comply with our legal obligations; (ii) to enforce our legal rights; (iii) to protect the rights of third parties; and (iv) in connection with a business transition such as a merger, reorganisation, acquisition by another company, or sale of any of our assets.
Our legal basis for processing
Where we use your personal data in connection with a business transition, to enforce our legal rights or to protect the rights of third parties, it is in our legitimate interest to do so. For all other purposes described in this section, we have a legal obligation to use your personal data to comply with any legal obligations imposed upon us, such as a court order.
We will not process any special (or sensitive) categories of personal data or personal data relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.
Where we are required to collect your personal data in connection with the Initiative, and you fail to provide that personal data when we request it, we may not be able to involve you in the Initiative.
Where our use of your personal data requires consent, you can provide such consent at the time we collect your personal data following the instructions provided, or by informing us using the contact details set out in the “How to Contact Us” section above.
This Privacy Notice only applies to personal data processed by us through your use of our Site and/or in connection with the Initiative. However, from time to time, our Site may contain links to third-party websites and services. We have no control over these websites and services and this Privacy Notice does not apply to your interaction with the relevant third parties.
When you use a link to go from our Site to another website (even if you do not leave our Site) or you request a service from a third party, your browsing and interactions on any other websites, or your dealings with any other third-party service provider, is subject to that website’s or third-party service provider’s own rules and policies. For example, our Site invites you to connect with us on social media platforms such as Facebook and Instagram. When you click on the links we provide to such third-party platforms, you will be transferred from our Site to the relevant third-party platform and the privacy notice (and other terms and conditions) of that platform will apply to you.
We do not monitor, control, or endorse the privacy practices of any third parties. We encourage you to become familiar with the privacy practices of every website you visit or third-party service provider that you use in connection with your interaction with us and to contact them if you have any questions about their respective privacy notices and practices.
We only share personal data with others when we are legally permitted to do so. When we share personal data with others, we put contractual arrangements and security mechanisms in place to protect the personal data shared and to comply with our data protection, confidentiality and security standards and obligations.
When processing your personal data, we may need to share it with third parties (including other entities within our group of companies), as set out in the table below. This list is non-exhaustive and there may be circumstances where we need to share personal data with other third parties.
Third-party suppliers who provide functionality, data processing, or IT services
We share personal data with third parties who support us in providing our Site and help provide, run, and manage our internal IT systems. Such third parties may also include, for example, providers of information technology, cloud-based software-as-a-service providers, identity management, website design, hosting and management, data analysis, data back-up, and security and storage services. The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal data may be stored in any one of them. We also share your personal data with third-party service providers to assist us with insight analytics. These providers are described in our Cookie Notice.
Third-party post/email marketing and CRM specialists
We share personal data with specialist suppliers who assist us in managing our contact database and sending out our post and email communications and account-related communications.
Law enforcement or other government and regulatory agencies and bodies
We share personal data with law enforcement or other government and regulatory agencies or other third parties as required by, and in accordance with, applicable law or regulation.
Other third parties
Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, or to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.
Where necessary in order to provide our Site and our services connected to the Initiative, we will transfer personal data to countries outside the UK and the EEA.
Non-EEA countries do not have the same data protection laws as the UK and the EEA. In particular, non-EEA countries may not provide the same degree of protection for your personal data, may not give you the same rights in relation to your personal data, and may not have a data protection supervisory authority to help you if you have any concerns about the processing of your personal data. However, when transferring your personal data outside the UK or the EEA, we will comply with our legal and regulatory obligations in relation to your personal data, including having a lawful basis for transferring personal data and putting appropriate safeguards in place to ensure an adequate level of protection for the personal data. We will take reasonable steps to ensure the security of your personal data in accordance with applicable data protection laws.
When transferring your personal data outside the UK or the EEA, we will, where required by applicable law, implement at least one of the safeguards set out below. Please contact us if you would like further information on the specific mechanisms used by us when transferring your personal data outside the UK or the EEA.
We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission and/or the UK Government (as applicable).
Where we use certain service providers, we may use specific standard contractual clauses approved by the European Commission and/or the UK Government which give personal data the same protection it has in Europe and/or the UK.
In respect of personal data that we process in connection with the Initiative, we may retain your personal data for up to three years from the date of our last interaction with you (and in compliance with our data protect obligations). We may then destroy such files without further notice or liability.
We are committed to keeping the personal data you provide to us secure and we have implemented information security policies, rules, and technical measures to protect the personal data under our control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. In addition, all our employees and data processors (i.e. those who process your personal data on our behalf) are obliged to respect the confidentiality of the personal data of all users of our Site and those who express interest in our Services.
Our Site is not intended for use by, or targeted at, minors and we do not knowingly collect personal data of minors. If we do collect personal data of minors, we will comply with all applicable laws and regulations relating to the processing of personal data of minors.
If you are under the age of 18, you must not use our Site and you must not provide us with any personal information. If we discover that we are holding the personal data of a minor, we will delete that information as soon as possible. Please contact us if you have reason to believe that a minor may have submitted personal data to us (see the “How to Contact Us” section above).
You have certain rights in relation to the personal data we hold about you. These rights include the right: (i) to obtain copies of your personal data; (ii) to have your personal data corrected or deleted; (iii) to limit the way in which your personal data is used; (iv) to object to our use of your personal data; (v) to transfer your personal data; (vi) not to be subject to decisions based on automated processing (including profiling); and (vii) to complain to a supervisory authority. If you would like to exercise any of these rights, please contact us using the details set out in the “How to Contact Us” section above.
Your right of access
If you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a copy of that personal data (along with certain other details). If you require additional copies, we may charge a reasonable fee for producing those additional copies.
Your right to rectification
If the personal data we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have shared your personal data with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you who we’ve shared your personal data with so that you can contact them.
Your right to erasure
You can ask us to delete or remove your personal data in some circumstances, such as where we no longer need it or where you withdraw your consent (where applicable). If we have shared your personal data with others, we will let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal data with so that you can contact them directly.
Your right to restrict processing
You can ask us to “block” or suppress the processing of your personal data in certain circumstances such as where you contest the accuracy of that personal data or you object to us processing it for a particular purpose. This may not mean that we will stop storing your personal data but, where we do keep it, we will tell you if we remove any restriction that we have placed on your personal data to stop us processing it further. If we have shared your personal data with others, we will let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we’ve shared your personal data with so that you can contact them directly.
Your right to data portability
You have the right, in certain circumstances, to obtain personal data you have provided to us (in a structured, commonly used, and machine-readable format) and to reuse it elsewhere or to ask us to transfer it to your chosen third party.
Your right to object
You can ask us to stop processing your personal data, and we will do so, if we are: (i) relying on our own or someone else’s legitimate interest to process your personal data, except if we can demonstrate compelling legal grounds for the processing; or (ii) processing your personal data for direct marketing purposes.
Your rights in relation to automated decision-making and profiling
You have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for the entering into, or the performance of, a contract between you and us.
Your right to withdraw consent
If we rely on your consent (or explicit consent) as our legal basis for processing your personal data, you have the right to withdraw that consent at any time. You can exercise your right of withdrawal by contacting us using our contact details in the “How to Contact Us” section above or by using any other opt-out mechanism we may provide, such as an unsubscribe link in an email.
Your right to lodge a complaint with the supervisory authority
If you have a concern about any aspect of our privacy practices, including the way we have handled your personal data, please contact us using the contact details provided in the “How to Contact Us” section above. You can also report any issues or concerns to a national supervisory authority in the Member State of your residence or the place of the alleged infringement. You can find a list of contact details for all EU supervisory authorities at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
As we are incorporated in the United Kingdom, our regulatory authority is the Information Commissioner’s Office (“ICO”). Contact details for the ICO can be found on its website at https://ico.org.uk.