Privacy Policy

This Privacy Policy applies between you, the user of our Website, (‘user’, ‘you’ or ‘your’),  and TAH Marketing Ltd (‘we’ or ‘us’) as the owner and provider of the Website. We take the privacy of your information very seriously. This Privacy Policy applies to our use of any and all Data (defined below) collected by us or provided by you in relation to your use of our website.

Please read this Privacy policy carefully and contact us if you have any questions using the contact details set out below. 

  1. Definitions and interpretation
    1. In this Privacy Policy, the following definitions are used:

Data

Collectively all information that you submit to us via our website. This definition incorporates, where applicable, the definitions provided in the EU General Data Protection Regulation 2018 (GDPR) and any further definitions provided for in the Data Protection Act 2018;

DPA 2018

The Data Protection Act 2018 as amended from time to time;

We, us or our

Refers to TAH Marketing Ltd, incorporated in England and Wales with registered number 12977581 whose registered office is at Warren Mobile Home Park, Bickenhill Lane, Birmingham, B37 7EY;

User, you or your

Any third party that accesses / uses the App and or Website and is not either (i) employed by us and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to us and accessing the App in connection with the provision of such services;

Website

The website at https://tahmarketing.com 
    1. In this Privacy Policy, unless the context requires a different interpretation:
      1. the singular includes the plural and vice versa;
      1. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;
      1. a reference to a person includes, insofar as the context permits, firms, companies, government entities, trusts and partnerships;
      1. “including” is understood to mean “including without limitation”;
      1. reference to any statutory provision includes any modification or amendment of it;
      1. the headings and sub-headings do not form part of this Privacy Policy.
  1. Scope 
    1. This Privacy Policy applies only to the actions of you and us with respect to the use of our Website, or otherwise when you register to enter our Competitions. It does not extend to any websites, forums, apps or other online resources that can be accessed from the Website including, but not limited to, any links we may provide to social media websites.
  1. Data collected
    1. We collect personal Data directly from you via other communications between us when you make enquiries with us or engage with our services and, to a more limited extent, when you visit the Website. We may collect the following Data, from you:
      1. Your personal details, such as your name and email address (so that we can contact you where we are lawfully able to do so in accordance with this policy and identify you when you set up an account with us) (Contact Data);
      1. Information relating to your use of the Website to help it function correctly, details of competitions you enter, your usage preferences, the mobile platform or service provider you use and your browser (Functional Data);
      1. Usage information to enable us to tailor our services to you and improve our services generally, including information about how you interact with  the Website and our services, your IP address and unique devices identifiers and the time and date of your usage of the Website (Usage Data);
      1. Banking and financial details to enable you to use our services and which may include your bank account and card details and other information via Paypal, and other similar platforms (Financial Data);
      1. Your account login details, such as your username and password (it is your responsibility to keep these safe) (Account Data).
      1. In addition, we may monitor your use of the Website through the use of cookies and similar tracking devices (Cookie Data). For example, we may monitor how many times you visit, which pages you go to, traffic data, and the originating domain name of a user’s internet service provider. This information helps us to build a profile of our users. Some (but not all) of this data will be aggregated or statistical, which means that we will not be able to identify you individually. Please see further the section on ‘Use of cookies‘ below.
  1. Our use of data
    1. For purposes of the GDPR and the DPA 2018, we are the “controller” of Data. This means that, under the DPA 2018 and the GDPR, we may control and process your personal data in accordance with this policy and the law. 
    1. We will only retain your Data for only so long as is needed in accordance with our retention policy. Ordinarily, this is six and a half years from the point at which you deactivate your account, unless you consent to receive marketing materials, in which case we shall retain your Personal Data until such a time as the business ceases to operate, or you withdraw your consent to be contacted.
    1. Unless we are obliged or permitted by law to do so, and subject to any third party disclosures specifically set out in this policy, your Data will not be disclosed to third parties, save for the purposes and on the occasions identified this policy. 
    1. All personal Data is stored securely in accordance with the principles of the GDPR. For more details on security see the clause below (Security).
  1. Our obligations to you
    1. As the ‘controller’ of your personal information, we will ensure that the personal information we hold about you is:
      1. 5.1.1.used lawfully, fairly and in a transparent way.
      1. 5.1.2.collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
      1. 5.1.3.relevant to the purposes we have told you about and limited only to those purposes.
      1. 5.1.4.accurate and kept up to date.
      1. 5.1.5.kept only as long as necessary for the purposes we have told you about.
      1. 5.1.6.kept securely.
  1. Legal basis for use of your Data
    1. We can only process your personal information where we have a legal right to do so under the DPA 2018 or the GDPR. Generally, we rely on the following grounds:
      1. 6.1.1.Article 6(1)(a) – processing is conducted with your consent to process personal data for specified purposes
      1. 6.1.2.Article 6(1)(b) – processing is necessary for the performance of our contract to provide services to you, or for preparing to enter into such a contract with you
      1. 6.1.3.Article 6(1)(c) – processing is necessary for us to demonstrate compliance with the law
      1. 6.1.4.Article 6(1)(f) – to process your personal data in pursuit of our legitimate interests
    1. Below, we have set out the particular types of Data that we collect, the reasons for this and the legal basis for doing so:

Type of Data

Reasons for Processing

Legal Basis

Contact Data, Functional Data, Financial Data Account Data

To enable us to set up your account, to provide services to you and allow you to make purchases through our Website

As part of our contract with you

Contact Data

To communicate with you about your account, deal with questions or concerns you may have

As part of our contract with you

Contact Data

To record communications with you for the purposes of training and improvement of our services 

Legitimate interests 

Contact data

To periodically send you written communications about updates to the services, our terms of use, this Privacy Policy or technical issues with the Website

As part of our contract with you 

Contact Data

To send you offers and promotions that may be of interest to you

Consent

Contact Data, Functional Data

To send you details of competitions or other aspects of our services that may be of interest to you

Legitimate Interests

Contact Data, Financial Data Account Data

Internal record keeping

Legitimate interests

All types of Data, particularly Usage Data

Improvement of our products / services, including using your Data for research purposes so that we can better understand our services and how they are used and perceived for the purposes of making improvements 

Legitimate interests

Contact Data

Contact for market research purposes which may be done using email, telephone, or mail. Such information may be used to customise or update the App

Consent

All types of Data

To deter, prevent, or detect any activities conducted in breach of the our General Terms and Conditions

Legitimate interests 

Contact Data, Usage Data

To make sure we offer our services to eligible persons

Legal obligation

All types of Data

Crime detection, prevention, and prosecution

Legitimate interests 

Contact Data, Account Data

To verify your identity 

As part of our contract with you

Contact Data, Functional Data, Account Data

To communicate with you about your use of the Website and our services.

As part of our contract with you

Financial Data

To receive payments from you and to manage these in accordance with your choices 

As part of our contract with you

Account Data

To manage, monitor, assess risks in connection with and regulate our contractual relationship with you (for example, by limiting or prohibiting access where you breach our terms of use)

Legitimate interest 

Contact Data

To enable us to receive and respond to questions and comments from you

As part of our contract with you

All types of Data

To identify, investigate and expose suspected unlawful, fraudulent or improper activity connected with our Website. This may involve disclosure of information, which may include personal Data, to the appropriate authorities 

Compliance with the law; legitimate interests

All types of Data

To inform third party marketing or advertising agencies, or third parties who want to market or advertise their products and services

Consent
  1. Third party websites and services
    1. We may, from time to time, employ the services of other parties for dealing with certain processes necessary for the operation of the Website. The providers of such services do not have access to certain personal Data provided by Users of the Website.
  1. Links to other websites and apps
    1. The Website may, from time to time, provide links to websites and other apps. We have no control over such websites and apps; we are not responsible for the content of these websites or apps. This policy does not extend to your use of such websites or apps. You are advised to read the Privacy Policy or statement of other websites and apps prior to using them. Your use of third party websites and apps is at your own risk.
  1. Change of business ownership and control 
    1. We may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of TAH Marketing Ltd. Data provided by users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the Data for the purposes for which it was originally supplied to us.
    1. We may also disclose Data to a prospective purchaser of our business or any part of it. This may include where we sell part of our business, or our assets, including personal data.
    1. In the above instances, we will take reasonable steps with the aim of ensuring your privacy is protected.
  1. Direct Marketing
    1. We have a policy of ‘privacy by design’, and your Data will not be used for the purposes of direct marketing, unless you specifically request to receive such materials. TAH Marketing Ltd will not share your data with third parties without specific consent from you for marketing purposes. We will not contact you for the purposes of direct marketing unless you have asked us to do so. However, if you have asked us to do so and later your change your mind, you can opt-out at any time with no hassle. To do this, just let us know. See further ‘Your rights‘ below for details about how to contact us.
  1. Transferring your information outside of Europe 
    1. 11.1.We may store your Data temporarily on our cloud service operated by [NAME]. We have taken appropriate steps to satisfy ourselves that your Data will be secure during this process; your data maybe stored in one or more international data centres, meaning that your data may be stored temporarily outside of the European Economic Area. If you have any concerns about this, please contact us using the details below.
  1. Sharing Data with third parties
    1. 12.1.We will only share your Data with third parties if you have given express consent for us to do so or there is a legal basis for doing so. In certain circumstances, it may be in our legitimate interests to pass your Data to a third party for certain limited reasons. These third parties will only process your personal Data on our instructions and we will ensure that adequate measures are in place to ensure that your personal Data is only processed where it is lawful and secure to do so, although we are not directly responsible for the actions and inactions of such third parties. This may include:
      1. 12.1.1.Our website provider to enable us and them to deliver their service to us, carry out analysis and research on demographics, interests and behaviour of our users and supporters to help us gain a better understanding of them to enable us to improve our services. This may include connecting Data we receive from you to Data available from other sources. Your personally identifiable Data will only be used where it is necessary for the analysis required, and where your interests for privacy are not deemed to outweigh their legitimate interests in developing new services for us.
      1. 12.1.2.Our professional advisors and agents for the purposes of advising and representing us in any matter connected with your account or your use of our Website upon which we legitimately consider that advice or representation is needed. 
      1. 12.1.3.We share transaction data with [PAYMENT MERCHANT] and other similar platforms (including Financial Data), but only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
      1. 12.1.4.Law enforcement agencies including government or regulatory bodies, lawful authorities, or other authorised third parties in order to comply with laws, regulations, court orders, or other legal obligations or to assist in an investigation, to protect and defend our rights and property, or the rights or safety of third parties, to enforce our Terms of Use, this Privacy Policy, or agreements with third parties, or for crime-prevention purposes.
      1. 12.1.5.Affiliates and Partners. This includes companies within our group in order to improve services and for advertising and marketing purposes but also includes our business partners for the purposes of improving, promoting or personalising our services.
      1. 12.1.6.Advertising agencies. Where you have consented to us doing so, we may use your personal Data for the purposes of providing targeted advertising to you. This may include the sale of your Data and disclosing your Data to companies involved in interest-based advertising, including web, mobile app and other advertising. This advertising consists of third party ads that are personalised and displayed on our Website and through other channels. 
      1. 12.1.7.Prize Providers. Where we offer a prize, being a product, experience or service, provided by a third party, we may need to provide that third party with your contact details so that they can provide the prize to you and communicate with you about any matter concerning the prize. This is necessary to enable us to perform our contract with you. If you win a prize, and there is a reason why you do not want us to pass your details to the third party prize provider, you have the right to object to us providing such details to the prize provider, but where you do so this may lead to you waiving your right to receive the prize. For more information, please see the section below headed Your rights. 
  1. Functionality of the Website
    1. It is important that the information we hold about you is accurate in order for us to comply with our legal obligations and to provide you with the best possible service. We therefore ask that your personal Data is up to date at all times. You may update your personal Data from within your account on our Website, or by using the contact details set out in this Privacy Policy.

 

    1. To use all features and functions available on the Website, you may be required to submit certain Data, particularly Cookie Data. You may restrict your internet browser’s use of Cookies. For more information see the clause below (Cookies).
  1. Your rights
    1. You have the right to ask for a copy of any of your personal Data held by us (where such Data is held), as is your right to access under GDPR and the DPA 2018. There will be no charge for this provision (except where requests are repetitious or unreasonable), and we will provide the data within 30 days of receipt of your request.
    1. You have various rights under the GDPR and the DPA 2018, including the following rights:
      1. 14.2.1.Right to object: If we are using your data because we deem it necessary for our legitimate interests to do so, and you do not agree, you have the right to object. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases). Generally, we will only disagree with you if certain limited conditions apply.
      1. 14.2.2.Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example, providing you with services), or consent to market to you, you may withdraw your consent at any time.
      1. 14.2.3.Data Subject Access Requests (DSAR): Just so it’s clear, you have the right to ask us to confirm what information we hold about you at any time, and you may ask us to modify, update or delete such information. At this point we may comply with your request or, additionally do one of the following:
        1. 14.2.3.1.we may ask you to verify your identity, or ask for more information about your request; and
        1. 14.2.3.2.where we are legally permitted to do so, we may decline your request, but we will explain why if we do so.
      1. 14.2.4.Right to erasure: In certain situations (for example, where we have processed your data unlawfully), you have the right to request us to “erase” your personal data. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases) and will only disagree with you if certain limited conditions apply.

      1. 14.2.5.Right of data portability: If you wish, you have the right to transfer your data from us to another data controller. We will help with this – either by directly transferring your data for you, or by providing you with a copy in a commonly used machine-readable format. 
      1. 14.2.6.Right to lodge a complaint with a supervisory authority: You also have the right to lodge a complaint with your local supervisory authority, details of which can be found below. 
    1. 14.3.Any requests to exercise any rights in connection with your Data, must be made in writing to the Data Protection Officer through our postal address, to TAH Marketing Ltd Warren Mobile Home Park, Bickenhill Lane, Birmingham, B37 7EY, or by email: herne05@aol.com
    1. 14.4.We may ask you to provide us with proof or your identity. Please do not be offended; this may occur even if we know you. It is a requirement of the GDPR or DPA 2018 in some cases.
  1. Security
    1. Data security is of great importance to us, and to protect your Data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure Data collected via our Website. To use all features and functions available on the Website, you may be required to submit certain Data. 
    1. If password access is required for certain parts of the Website, you are responsible for keeping your password and other Account Data confidential.
    1. We endeavour to do our best to protect your personal Data. However, transmission of information over the internet, or via wifi, is not entirely secure and is done at your own risk. We cannot ensure the security of your Data transmitted to the Website and your use of the Website is generally at your own risk.
  1. Cookies
    1. Our Website may place and access certain Cookies on your computer. We use Cookies to improve your experience of using the Website and to improve our range of services. We have carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.
    1. All Cookies used by the Website are used in accordance with current and applicable UK and EU laws.
    1. Before the Website places Cookies on your computer, you will be presented with a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling us to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.
    1. This Website may place the following Cookies:
      1. 16.4.1.Strictly necessary cookies: These are Cookies that are required for the operation of the Website. They include, for example, Cookies that enable you to log into secure areas of the Website, if any. 
      1. Analytical/performance cookies: They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.
      1. Functionality cookies: These are used to recognise you when you return to our Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region), although these features may not be available all the time. 
    1. You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser.
    1. You can choose to delete Cookies at any time; however, you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.
    1. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.
  1. Children
    1. We do not knowingly collect personal Data online from persons under 16. If you become aware that a person under the age of 16 has provided us with Personal Data without parental consent, please contact us using the details below. If we become aware that a child under 16 has provided us with personal Data without parental consent, we will take steps to remove the Data and cancel any relevant account.
  1. General 
    1. You may not transfer any of your rights under this Privacy Policy to any other person. We may transfer our rights under this Privacy Policy where we reasonably believe your rights will not be affected.
    1. If any court or competent authority finds that any provision of this Privacy Policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.
    1. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
    1. This Privacy Policy will be governed by and interpreted according to the law of England. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English courts.
  1. Changes to this Privacy Policy
    1. We reserve the right to change this Privacy Policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website, and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations.
  1. Automated decision making
    1. We may, from time to time, use systems to make automated decisions based on your personal Data where we are operating a live prize draw or a similar event that supports automated decision making. This helps us to make sure our decisions are quick and fair.
    1. We use automated decision making in the following situations:
      1. Live prize draws: we use algorithms to fairly select prize winners based on entrants details;
      1. Detecting fraud: we use your personal information to help decide and detect if your account may be being used for fraud or money-laundering. If we think there is a risk of fraud, we may block or suspend the account;
      1. Opening an account: when you open an account with us, we check that the product or service is relevant for you, based on what we know. We also check that you meet the conditions needed to open the account.
    1. Data protection law seeks to safeguard individuals against harm that may arise from decision-making – including profiling – that takes place without human intervention. You have the right not to be subject to a decision when it is based on the automated processing of your personal information and it has a legal effect or a similarly significant effect on you.
    1. Please note that the right does not apply when the processing is:
      1. necessary for entering into or for the performance of a contract with you; 
      1. when it is authorised by law; or
      1. when it is based on your explicit consent.
  1. Contact Details
    1. If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to the Information Commissioner’s Office (ICO) by contacting them on 0303 123 1113 or visiting https://ico.org.uk/.
    1. Our Data Protection Officer is (NAME) and you can contact them at (EMAIL) or by writing to (ADDRESS)