Privacy Policy
Privacy Statement Summary:
This Privacy Policy (“Policy”) explains how your information is collected, used and disclosed by Tug Agency ( “We” or “Us" or “our”). This policy applies where we are acting as a Data Controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
We are committed to safeguarding the privacy of our website visitors and service users. We will never sell, share, or use your personal information other than as described here.
By using our website and agreeing to this Policy, you consent to our use of cookies in accordance with the terms of this Policy.
| Who will use my data? | Tug Agency |
| What for? | We will store and process your data in order to allow us to provide our multiple digital marketing services. We use Media Marketing to focus on reaching audiences through different types of media outlets, to optimize our client’s website, to provide our clients a proper influencer campaign management by sourcing the best influencers to align with our clients brand and target audience, to set up a display advertising, and to practice a multi-platform optimization, audience focused insights and developing data driven buyer personas and to provide a lead, acquisition and brand awareness activity. We use Marketing Technology to design and operate technology solutions with search engine optimization to increase a website visibility when people search for products or services, establishing bespoke data strategies and analytics solutions by using data & analytics, and using attribution and visualization. We use creative marketing to provide content strategy, creative campaigns, social media management, to provide a digital PR for brand increase awareness, and to increase the percentage of conversions from a website or mobile app by using convention rate optimization. If you contact us, we will respond to your inquiry and may also send you information that we think you will be interested in. This may include a range of related digital marketing services as stated above. As per our legal obligations, we might send details to relevant authorities or any other organisation that requires them by law. If you are a data subject who has been involved in one of our clients’ campaigns please contact the company involved directly for access to their privacy policy. |
| What will happen if I contact you? | For clients - If you contact us, we will collect your data via our website using our online forms and features website that rely on a personalised response, or where you ask us to respond to a query you have, or if you leave a comment on our blog. We will use your information for marketing related to our services and we might disclose your information to our relevant third parties so we can provide our services as a digital marketing agency. If you use our data capture form, we will send you information according to the preferences you submitted via our data capture form. In some cases we may rely on legitimate interest as our lawful basis, we have prepared a legitimate interest assessment to ensure we always act in accordance with your interests. We collect a limited amount of data, only to provide a digital marketing service that you’ve requested, and other information that we think you will be interested in. If you choose to use our services, we may collect more information from you and where necessary share your information with carefully selected third parties required to provide the services you have requested. We might also use your information to send you marketing emails about our services. For influencers - If you contact us as an influencer, we will collect your information so we can provide an influencer campaign management and influencer sourcing for our clients |
| How do we get your personal data? | We will collect your data if you:
We augment our records with publicly available information from social media platforms. However, where we collect data from sources such as social media, we only do this where the data is manifestly in the public domain and where the data subject would expect to be contacted about our professional services. We collect a limited amount of data, only to provide a digital marketing service that you’ve requested, and other information that we think you will be interested in. The data we collect via the methods identified above is used by Tug Agency only. Unless required to do so by law or to deliver services to you, we will not otherwise share, sell, or distribute any of the information you provide to us without your consent. |
| What data will be stored? | If you contact us via our contact form on our website, we will collect data such as:
We will store your personal details in order to provide our services as a digital marketing agency and run our company. This includes:
We will never use your data other than to provide our digital marketing services, in order to operate and develop our company, and we assure you that we’ve met our obligations in accordance with the GDPR. |
| What data will be shared? | We will only share data where strictly necessary to operate our company, meet our obligations and provide the services that we offer. We will not share your data with any third parties other than as required to fulfil our contracts and as described here. We may share your information with regulators or legal bodies that request it. We will only share any data that is particularly relevant to our process in order to provide the services that we offer. We will never sell your personal data to other companies / third parties. |
| How long? | Your data will be stored for up to 7 years following the last contact we have with you, after which time your data will be deleted. For more information, please refer to our Data Retention Policy. |
| Who can access my data? | We will never sell, share, or otherwise distribute your data to any other third party other than as described here. We will share your information with any regulator or legal body that requests it as well as any parties relevant to the application process. We ensure access is restricted to only those persons authorised by us to access your data. Access to your data is strictly controlled. For more information refer to our Information Security Policy. |
| Who do we share data with? | We only share your data with trusted and relevant companies which ensure an adequate level of protection and where there is a contract in place which include obligations in relation to the confidentiality, security and lawful processing of any personal data shared with them. For example, we share your personal data with trusted companies such as:
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| How is my data kept secure? | We will store your data on secure based servers which will be processed in our borders. We use industry standard security protocols/technology to secure your data. Where we do transfer your data outside of the borders, we will take all appropriate precautions to protect your data including establishing DPA/SCCs with any third party. |
We take your privacy seriously and will only use your personal information to provide the services you have requested from us and to send you information about services you may be interested in. We will never sell, share or use your personal information other than as described here.
About This Privacy Policy
This policy sets out how we will use and share the information that you give us. This policy describes your relationship with Tug Agency.
The General Data Protection Regulation (GDPR) describes how organisations must collect, handle, process, and store personal information.
These rules apply regardless of whether data is stored electronically, on paper or on other materials. To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully. GDPR is underpinned by eight important principles. These say that personal data must:
- Be processed fairly and lawfully
- Be obtained only for specific, lawful purposes
- Be adequate, relevant and not excessive
- Be accurate and kept up to date
- Not be held for any longer than is necessary
- Processed in accordance with the rights of the data subjects
- Be protected in appropriate ways
- Not be transferred outside our borders, unless that country or territory also ensures an adequate level of protection
We take these responsibilities seriously; this document describes our approach to data protection. This policy helps to protect us from data security risks, including:
- Breaches of confidentiality. For instance, information being given out inappropriately.
- Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.
- Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.
- Loss, damage, or other consequences of such a breach or security failure
Who We Are And How To Contact Us
Tug Agency is registered in the UK and is registered with the Information Commissioner's Office. The Data Protection Lead is Eoin O’Neill. You can contact us in any of the following ways:
Email: eoin.oneill@tugagency.com
Address: 1 Leonard Circus, Shoreditch, London, London EC2A 4DQ, GB
Telephone number: + 44 (0) 207 033 6933
Who this privacy policy applies to
This policy relates to data subjects of Tug Agency including clients, customers, employees, and all other individuals. Processing of your data is required in order to offer you our products and services. This policy applies to individuals who have shared their data with Tug Agency as either a customer, client, employee, supplier or in any other capacity.
It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the GDPR. This can include:
- Names of Individuals
- Contact details
- Postal addresses
- Email Addresses
- Telephone numbers
- Financial information
- Employment information
- Criminal convictions or pending legal actions against you
- Any other information relating to individuals as required to provide our services to you
What this policy applies to
This section describes the lawful basis for processing your data and applies to the information about yourself that you choose to provide us with or that you allow us to collect. This includes:
- The Information you provide when you contact us
- When you contact us in order to discuss using our services
- Information we collect about how you use the website
- Information relating to services we offer to you and other transactions including financial and other personal information required to complete these transactions
- Information that is given and stored as part of our ongoing relationship
- All information provided to us by you or data we acquire from third parties in connection with our digital marketing services
We do not collect or process sensitive data about you.
How your information will be used
We will only use your personal data for the purposes for which we collected it and as you would reasonably expect your data to be processed and only where there is a lawful basis for such processing, for example:
| Purpose/Activity | Type of data | Lawful basis for processing |
| To register you as a new customer | (a) Identity, (b) Contact (c) Financial | (a)Performance of a contract with you (b) Consent (c) In our legitimate interests |
| To process and deliver our services you request including digital signages, and to manage payments, fees and charges. | (a) Identity, (b) Contact, (c) Financial, (d) Transaction, (e) Marketing and Communications | (a) Performance of a contract with you, (b) Necessary for our legitimate interests to recover debts owed to us (b) Consent |
| To manage our ongoing relationship with you which will include notifying you about changes to our terms, services or privacy policy, to maintain our records | (a) Identity, (b) Contact, (c) Profile, (d) Marketing and Communications | (a) Performance of a contract with you, (b) Necessary to comply with a legal obligation, (c) Necessary for our legitimate interests to keep our records updated and to study how customers use our services (d) Consent |
| To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity, (b) Contact, (c) Technical | (a) Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise, (b) Necessary to comply with a legal obligation (c) Consent |
| To use data analytics to improve our website, services, marketing, customer relationships and experiences | (a) Technical, (b) Usage | (a)Necessary for our legitimate interests to define types of customers for our services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy (b) Consent |
| To make suggestions and recommendations to you about services that may be of interest to you | (a) Identity, (b) Contact, (c) Technical, (d) Usage, (e) Profile | (a)Necessary for our legitimate interests to develop our services and grow our business (b) Consent |
We may collect and process information about you, including your name, date of birth, address, contact details (including email address and mobile phone number), service details, purchase history and data collected as part of any finance application or payment (including previous addresses, employment details and bank account details). We may take personal information from:
- Information that you provide to us when visiting our website or using the contact mechanisms (including your email address, phone number, chat services, post etc...)
- Information that you provide to us when signing up to any distribution lists to receive correspondence from us
- Information relating to any services we provide you including any other transaction details made (including your address, telephone number and payment details)
- Information we collect from other sources such as the internet, social media, commercial databases, other companies, and other third parties
- Information we derive from information we collect about you - for example where we derive your email address from your name and company name combined
Personal data we receive will be used for the purposes it was provided, including:
- To respond to queries from you regarding coaching and leadership development
- To carry out our obligations arising from any contracts entered into between you and us including provision of services, and to respond to queries from you regarding those contracts
- To manage and administer the relationships between you and us
- To obtain feedback from you regarding us and our services.
- Managing data protection requests from clients, and other third parties
In accordance with your preferences, we may also use your personal information to provide you with information about services, promotions and offers that may be of interest to you. We may use your personal information in order to ascertain the services, opportunities, promotions and offers that are likely to be of particular interest to you. This document explains how you can change whether to receive this information. Please note that, even if you choose not to receive this information, we may still use your personal information to provide you with important services communications, including communications in relation to any purchases you make or services you use.
How to change your preferences
We operate in line with GDPR data protection guidelines. We respect your rights and will respond to any request for access to personal information and requests to delete, rectify, transfer, data and to stop processing. We will also advise you on how to complain to the relevant authorities. Any requests or objections should be made in writing to the Data Controller, or you can visit our website, call, or email us to contact us to change your preferences at any time
Scope of Agreement
By submitting your personal data on this site or as required for us to provide services to you, you are affirming your agreement for such information to be used in accordance with this privacy policy. You will be able to change your preferences at any time by the methods described as prescribed in this document.
We may from time to time use your information for marketing, account management or relationship management purposes. The main purpose of this is to provide you with information about services which we think may be of interest to you and/or to maintain any existing relationship we may have with you.
Opting out at a later date
Where you give your consent for us to process your data, for example when you agree to us sending you marketing information or where you agree to us processing financial data, you can contact us to amend or withdraw your consent at any time. You can also choose to object to processing and request deletion of your data. We respect all user rights as defined in GDPR. If you have any comments or wish to complain please contact us.
How we store and process your data
Your data will be collected, stored, and processed primarily in the locations where our subsidiaries are registered, where we transfer your data outside the borders, we will ensure we take appropriate precautions to protect this data. Your data will normally be stored for up to 7 years to ensure we have records of service, payments, contracts and other interactions we have with you. For details on retention periods please see our Retention Policy.
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 you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us. If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.
We may be legally obliged to disclose your personal information without your knowledge to the extent that we are required to do so by law; in connection with any ongoing or prospective legal proceedings; in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk); to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
You will only receive marketing communications from us if you have:
- Requested information from us
- Used our services previously
- If you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications
- Where we believe you will be interested in our services and we have a valid legitimate interest to process your information
- You have not opted out of receiving marketing emails
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Our obligations
We are a Data Controller. In relation to the information that you provide to us, we are legally responsible for how that information is handled. We will comply with the GDPR in the way we use and share your personal data. Among other things, this means that we will only use your personal data:
- Fairly and lawfully
- As set out in the legislation and this policy
- To the extent necessary for these purposes
- We will take steps to ensure your data is accurate and rectify data as necessary
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw 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 contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Third Parties
We may have to share your personal data with the parties set out below for the purposes described in this document:
- Service providers who provide IT and system administration services. For example: Samsung and Curry’s
- Third parties including equipment providers, and other third parties as required to run our business
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, credit scoring, banking, legal, fraud protection, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
- Third parties to whom we sell, transfer, or merge parts of our business or our assets.
- Other companies as required to provide our services to you and to operate our company
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We will report any breaches or potential breaches to the appropriate authorities within 24 hours and to anyone affected by a breach within 72 hours. If you have any queries or concerns about your data usage, please contact us.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Cookies
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added, and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. We use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
As well as your ability to accept or reject cookies, we also require your permission to store cookies on your machine, which is why when you visit our site, you are presented with the ability to accept our terms of use, including the storage of cookies on your machine. Should you not accept, then you are free to leave our website, at any time.
Legitimate Interests
Under the GDPR, we are also permitted to share some information with third parties who use such data for non-marketing purposes (including credit and risk assessment and management, identification and fraud prevention, debt collection and returning assets to you).
Contacting us, exercising your information rights and Complaints
If you have any questions or comments about this Privacy Policy, wish to exercise your information rights in connection with the personal data you have shared with us or wish to complain, please contact Eoin O’Neill at:
Email: eoin.oneill@tugagency.com
Address: 1 Leonard Circus, Shoreditch, London, London EC2A 4DQ, GB
Telephone number: + 44 (0) 207 033 6933
We will process data protection requests within 30 days, SAR responses are usually free, but we reserve the right to charge for excessive or unfounded requests. We fully comply with Data Protection legislation and will assist in any investigation or request made by the appropriate authorities.
If you remain dissatisfied, then you have the right to apply directly to the Information Commissioner for a decision. The Information Commissioner can be contacted at:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
www.ico.org.uk
