Introduction
Welcome to privacy policy (‘Policy’) for local-marketing-reports.com and customfeedback.com.
We respect your privacy and are committed to protecting your personal data. This Policy will inform you as to how we look after your personal data, including when you visit our website (regardless of where you visit it from), or when you order or use our services, and tells you about your privacy rights and how the law protects you.
We will never sell your personal data to a third party.
Please use the Glossary to understand the meaning of some of the terms used in this Policy.
GDPR Compliance
In order to be compliant with the implementation of the GDPR we have updated this Privacy Policy and revised our use of personal data in line with the most recent guidance from the Information Commissioner’s Office (ICO).
Important information and who we are
Purpose of this policy
This Policy aims to give you information on how we collect and process your personal data, including through your use of this website, and any data you may provide through this website, or when you contact us or sign up to our newsletters, commission or order a product or service, or take part in a survey.
This website is not intended for children under 16 and we do not knowingly collect data relating to children.
It is important that you read this Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Policy supplements the other notices and is not intended to override them.
Changes to this policy and your duty to inform us of changes
This version was last updated in January 2020 and may be subject to further revisions.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
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.
The data we process
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and process different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes: first name, last name, username or similar identifier, title, photos or other images.
- Contact Data includes: billing address, delivery address, email address and telephone numbers, and any social media accounts used.
- Financial Data includes: bank account and payment card details.
- Transaction Data includes: details about payments to and from you and other details of products and services you have ordered or commissioned.
- Technical Data includes: internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access these websites.
- Profile Data includes: any username and password to access systems, commissions or orders made, your interests, preferences, feedback and survey responses.
- Usage Data includes: information about how you use your marketing agency’s websites, products and services.
- Marketing and Communications Data includes: your preferences in receiving marketing from your marketing agency and any third parties made known to you and your communication preferences.
We also collect, use and process aggregated Data such as statistical or demographic data. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.
We do not collect any Special Categories of Personal Data about you or any information about criminal convictions and offenses.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with your marketing agency and you fail to provide that data when requested, we may not be able to perform the contract (for example, to provide you with services).
How is your personal data collected and processed?
We use different methods to collect and process data from and about you including through:
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Direct interactions. You may give your marketing agency your Identity, Contact and Financial Data by filling in forms or by corresponding with by post, phone, email, social media or otherwise. This includes personal data you provide when you:
- commission or order products or services (for example, by telephone, email or via websites);
- create an account on a website or system;
- subscribe to publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey;
- make a general inquiry about products or services; or
- give feedback.
- Automated technologies or interactions. As you interact with websites or social media accounts, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookie Policy for further details.
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Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
- analytics providers such as Google and Hotjar based inside or outside the EU;
- advertising networks, such as Google Ads or Facebook, based inside or outside the EU; and
- search information providers, such as Google, based inside or outside the EU.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as PayPal and Braintree, based inside or outside the EU and HM Revenue & Customs (HMRC).
- Technology providers including support and inquiry ticketing systems, client relationship and marketing platforms and communications providers based inside or outside the EU.
- Identity and Contact Data from publicly available sources.
- Technical Data from the following parties:
Sub-processors
To support us in delivering its Services, we may engage third party service providers to assist us with our data processing activities. When we work with these service providers in our capacity as a data processor, the third-party service provider is our sub-processor (“Sub-processor”).
Our business needs may change from time to time. For example, we may remove a Sub-processor to consolidate and minimise our use of Sub-processors. Similarly, we may add a Sub-processor if we believe that doing so will enhance our ability to deliver our services.
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Category |
Personal Data |
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Professional Services |
We may share your details with professional service companies such as accountants or accounting software. |
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Payment Service Providers |
We may share your details with companies that provide us with payment services. |
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Technical Service Providers |
We may share your details with providers we use to provide computing services. |
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Email Marketing Software |
We may share your details with email marketing software providers to allow us to send emails to customers. |
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Communication Services |
We may share your details with companies who provide us with communication services such as a live chat. |
We will not share your data with third parties for the purposes of any marketing without your consent unless otherwise specified in this privacy notice.
Some of our applications allow users to configure integrations with third party services. When using any of these integrations, you may share your data with the organisations who operate these services. You should review their own privacy information with regard to how they will treat this information once it has been provided.
How we use your personal data
We will only use your personal data when the law allows us to or under the terms of a contract we have with your marketing agency. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform a contract we are about to enter into or have entered into.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending marketing or third-party direct marketing communications via email or text message, which you have expressly consented to receive. You have the right to withdraw consent to marketing at any time by contacting us or by clicking ‘unsubscribe’ in any communication you receive from us.
Purposes for which we will use your personal data
We have set out below a description of all the ways we may process your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
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Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
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To register you as a customer or account holder |
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To process and deliver a service or order including:
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To manage our client’s relationship with you which may include:
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To enable you to take part in a prize draw, competition or complete a survey |
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To administer and protect these websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
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To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising served to you |
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To use data analytics to improve products/services, marketing, customer relationships and experiences |
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To make suggestions and recommendations about goods or services that may be of interest to you |
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Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
Surveys & promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
We may send you product or service renewal reminders close to the anniversary of taking up a product or service or other communications we are obliged to send under a legal or contractual obligation.
You may receive marketing communications from us if you have expressly requested information from us about our services, or purchased goods or services, or made an inquiry, or if you provided us with your details when you entered a competition or registered for a promotion. We will not, however, send you generic marketing unless you have expressly consented to receive it.
Third-party marketing
We will seek your express opt-in consent before we share your personal data with any company outside of the BrightLocal group of companies for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time or by following the opt-out or unsubscribe’ links in any marketing message sent to you or by contacting us.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service commission or order, warranty registration, product/service experience or other transactions, or where we need to keep your contact details or make contact with you for contractual performance or legitimate interest purposes.
Cookies
You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.
Change of purpose
We will only use your personal data for the purposes for which we are entitled to process it.
Please note that we will only process your personal data for another purpose where this is required or permitted by law.
Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table above (Purposes for which we will use your personal data).
- Internal Third Parties as set out in the Glossary or elsewhere in this Policy.
- External Third Parties as set out in the Glossary or elsewhere in this Policy.
- Specific third parties listed in the Glossary or elsewhere in this Policy.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may process your personal data in the same way as set out in this Policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our own third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
International transfers
In order to perform our services, and where authorised, we may transfer your personal data outside the European Economic Area (EEA).
Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we seek to ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to third parties that have signed our own Data Processing Agreement to safeguard and secure your personal data, or which are located in countries deemed to provide an adequate level of protection by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use international service providers, we are invariably bound by their own Data Processing Agreements, usually in a form approved by the European Commission, and which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use service providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring personal data out of the EEA.
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 personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We seek to use third-party technology providers that are ISO27001 certified or equivalent (SOC II) where practical.
Retention
How long will you process my personal data for
We will only retain your personal data for as long as we retain a lawful basis for processing it.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax and legal liability purpose, but we also keep this information to make it easier for customers to make new, follow-on or repeat service orders.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to the processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
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.
What we may need from you
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.
Time limit to respond
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.
Who we are
BrightLocal Ltd is the owner of these websites and runs them on behalf of Think Local SEO Ltd.
If you have been directed to this Policy as a result of your interaction with Think Local SEO Ltd then Brightlocal acts as the processor for data protection purposes and your marketing agency is the controller.
If you are using services as a result of a direct interaction with Brightlocal then we will be the controller for data protection purposes in which case the Brightlocal privacy policy found here will apply.
In the first instance please contact Think Local SEO Ltd with any questions about this policy or our usage of your data.
If necessary you can contact BrightLocal at the details below:
BrightLocal, 2nd Floor, Blenheim House, 120 Church Street, Brighton, BN1 1UD
Email: privacy@brightlocal.com
Glossary
You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.