Stratton Affiliates acknowledges that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our customers, subscribers, and website visitors and will only collect and use personal data in ways that are described here, and in a way that is consistent with our responsibilities and your rights under the law.
1. Information About Us
Stratton Affiliates is registered brand under Toplable Investments ltd. a limited company registered in Cyprus under company number ΗΕ381418, whose registered address is 5 Andrea Zappa
Honey Court, Ground Floor Potamtos Germasogeias
Limassol 4040 Cyprus
We are regulated by the Information Commissioner’s Office.
2. What Does This Policy Cover?
3. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 5, below.
4. What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
- The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
- The right to access the personal data we hold about you. Part 10 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 11 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling. Part 6 explains more about how we use your personal data, including automated decision-making and profiling.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
5. What Personal Data Do You Collect?
We may collect some or all of the following personal data (this may vary according to your relationship with us):
- Email address;
- Business name;
- Job title;
6. How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:
- Providing and managing your account.
- Supplying our products or services to you. Your personal details are required in order for us to enter into a contract with you.
- Personalising and tailoring our products or services for you.
- Communicating with you. This may include responding to emails or calls from you.
- Supplying you with information by email that you have opted-in to (you may unsubscribe or opt-out at any time by emailing firstname.lastname@example.org or clicking the “unsubscribe” button in any email we send you.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email with information, news, and offers on our products or services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
We use the following automated system for carrying out certain kinds of profiling. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the GDPR gives you the right to do so. Please contact us to find out more using the details in Part 11.
- The following automated profiling may take place:
- If you have opted in to receive cookies from our website (strattonaffiliates.com) then, depending on your interaction with our website, we may target you with targeted text ads on Google or Bing search results pages and/or targeted display ads, served via the Google Display Network on websites which have opted to display such ads.
7. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
- Cookies will be retained for a maximum of 540 days, unless they are reset by, for example, a further visit to our website;
- Email addresses will be retained for as long as we consider them useful for marketing purposes, or until a valid removal request is received.
8. How and Where Do You Store or Transfer My Personal Data?
Where practicable we will only store or transfer your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. When data is stored within the EEA, that means that your personal data will be fully protected under the GDPR or to equivalent standards by law.
We may transfer your data to the United States of America (the “US”). We will only transfer your data to a third party based in the US if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar levels of data protection to those in Europe. More information is available from the European Commission.
Please contact us using the details below in Part 11 for further information about the particular data protection mechanism used by us when transferring your personal data to a third country.
- We only retain personal data for as long as is necessary.
- Access to personal data is restricted to company employees for whom it is necessary to have such access.
- We ensure we have a record of exactly what personal data we are retaining and processing.
9. Do You Share My Personal Data?
We may share your personal data with other companies in our group for marketing purposes. This includes subsidiaries.
We may sometimes contract with the following third parties to supply services to you on our behalf. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold.
- Google. We may share your personal data for online marketing purposes.
- Facebook. We may share your personal data for online marketing purposes.
- Twitter. We may share your personal data for online marketing purposes.
- Microsoft. We may share your personal data for online marketing purposes.
- LinkedIn. We may share your personal data for online marketing purposes.
- MailChimp. We may share your personal data to add you to any mailing lists that you have opted into.
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 8.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
10. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 28 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
11. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:
Email address: email@example.com.
Postal Address: 5 Andrea Zappa Honey Court, Ground Floor Potamtos Germasogeias Limassol 4040 Cyprus.
12. Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.