- 01273 282111
- hello@breakthroughcomms.co.uk
Breakthrough Communications, Mocatta House, Trafalgar Place, Brighton, BN1 4DU
© Breakthrough Communications & Strategies Limited 2021
Breakthrough Communications & Strategies Limited (“Breakthrough Communications”) are specialists in helping Town and Parish Councils improve communication with their communities.
Breakthrough Communications & Strategies Limited is the data controller of your personal data. We are committed to protecting and respecting your privacy and will comply with all applicable data protection laws in all our dealings with your personal data. As data controllers, we want you to feel both informed and empowered when it comes to the handling and usage of your personal information. In this privacy notice, we explain how and why we collect and use personal data, which is information relating to an identified or identifiable living person. We will only use your personal information lawfully in accordance with the General Data Protection Regulations (‘GDPR’), UK Data Protection Act 2018 and Privacy and Electronic Communications Regulations (‘PECR’).
We process personal data for a variety of reasons. How we collect the data, our lawful basis for processing and using the data, as well as disclosure, and retention periods are set out below.
When you visit our website, we collect anonymous data from our cookies. This means that we can see number of users, page views and visits within a selected timeframe, but we cannot link this information back to you as an individual.
If you sign up to receive content or downloads from us, or if you provide us with your contact details if you fill out any of our surveys or feedback forms following training sessions, webinars or other sessions, you may receive relevant communications from us. You can unsubscribe or opt-out from our emails at any time. Every email we send you will have an ‘unsubscribe’ link in it.
We may collect and process, and you may supply, the following data:
Information about you and your council and your role at the council, such as your name, your council’s name, your postal address, your preferred contact name(s), telephone numbers, email address and IP addresses;
Additional information related to your council that is provided by you when filling out forms on our website or when registering to access our free or paid-for services, or when purchasing products or services from us, or when taking part in our free webinars, or when filling out feedback forms after completion of a training course or workshop or through other forms;
If you contact us, we may keep a record of that correspondence;
Details of commercial transactions you carry out through our site, and with us directly, and of the fulfilment of your orders;
Details of your visits to our websites and emails received including, but not limited to, traffic data, location data, web logs and other communication data, whether this is required for our own billing purposes or otherwise;
We may also receive names, email addresses and other relevant contact details of parish and town councillors. These are only collected if they’re supplied by data subject when registering to access our free or paid-for services or when filling out feedback forms after completion of training course;
Other information about the council’s operations may be collected and supplied by the data subject when we carry out work for the client on the basis of Contract;
Alternatively, data about your council may be obtained on the basis of Legitimate Interest for the purposes of marketing and prospecting, obtained from public data sources.
In addition, we may also collect any information about your computer, including where available your IP address, operating system and browser type, for system administration and to prevent fraudulent access to our member-only areas.
Marketing and prospecting
Research
Processing data for sales and contractual purposes
Processing data for own financial record keeping, where contracts exist
Legitimate interest
Consent
Contract
We contact councils directly or make use of contact data where they have engaged with us, in order to help councils better connect with their communities. We have also assessed our business interests in carrying out marketing activities and we have considered the impact the collection and use of personal data could potentially have on individuals’ rights. We have concluded that we have a reasonable legitimate interest for processing personal data where needed.
Any Legitimate Interests pursued by us, or third parties we make use of, are as follows: contacting councils where we genuinely believe there to be a good and relevant opportunity for us to work with them and the sending of direct marketing communications through a variety of means. We do not collect “special categories” of personal data, as defined by GDPR.
We will process your personal data specifically for the purposes identified. You may withdraw consent at any time by contacting us.
Like most companies, we use a range of software tools to manage our day to day operations, as well as to assist our work that we carry out for our customers and prospective customers, and to improve the experience customers and prospective customers receive from us. The following third parties may therefore receive and process your personal data, as part of our processing activities:
TypeForm (EU Adequacy Decision Basis) More details at: https://help.typeform.com/hc/en-us/articles/360029580771-What-is-GDPR-
Xero (EU Adequacy Decision Basis) More details at: https://www.xero.com/uk/campaigns/xero-and-gdpr/
Facebook (Various contractual agreements). More details at: https://www.facebook.com/business/gdpr
ActiveCampaign (Various contractual agreements). More details at: https://www.activecampaign.com/legal/gdpr-updates/gdpr-overview
Zapier (Various contractual agreements). More details at: https://zapier.com/help/account/data-management/gdpr-compliance-at-zapier
Zoom (Various contractual agreements). More details at: https://zoom.us/gdpr
Trello (Various contractual agreements). More details at: https://help.trello.com/article/1118-trello-and-gdpr-our-commitment-to-data-privacy
Google GSuite (Various contractual agreements). More details at: https://cloud.google.com/security/gdpr
Calendly (Various contractual agreements). More details at: https://calendly.com/pages/dpa
BombBomb (Various contractual agreements). More details at: https://bombbomb.com/gdpr/
Vimeo (Various contractual agreements). More details at: https://vimeo.com/privacy
Squarespace (Various contractual agreements). More details at: https://www.squarespace.com/dpa
Kajabi (Various contractual agreements). More details at: https://kajabi.com/policies
Better Proposals (Various contractual agreements). More details at: https://betterproposals.io/about/privacy
Stripe (Various contractual agreements). More details at: https://stripe.com/en-gb/privacy
We will process and store personal data for no more than 3 years, unless you continue to engage with us directly or by virtue of contracts of sale being in place, or for the storage of financial records, in which case relevant data may be stored for up to 6 years.
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
Right of access – you have the right to request a copy of the information that we hold about you.
Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
Right of portability – you have the right to have the data we hold about you transferred to another organisation.
Right to object – you have the right to object to certain types of processing such as direct marketing.
Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
Right to judicial review: in the event that we refuse your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.
All of the above requests will be forwarded on should there be a third party involved in the processing of your personal data.
In the event that you wish to make a complaint about how your personal data is being processed by us, or how your complaint has been handled, you have the right to lodge a complaint directly with us by getting in contact at hello@breakthroughcomms.co.uk.
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Breakthrough Communications, Mocatta House, Trafalgar Place, Brighton, BN1 4DU
© Breakthrough Communications & Strategies Limited 2021
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