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Our commitment to your privacy

Privacy policy.

Here at FINALLY AGENCY Ltd we are committed to protecting and respecting your privacy. We have taken active steps to ensure that we are fully GDPR compliant. This privacy policy will inform how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

If you have any questions regarding this policy and our privacy practices, please send an email to julie@wearefinally.co.uk or write to Julie Gilson, 19-21 St Dunstan’s Street Canterbury Kent CT2 8BH.

Alternatively, you can telephone 01227 378720.

This policy explains:

  1. How do we collect information from you?
  2. What type of information is collected from you?
  3. How is your information used?
  4. Purposes for which we will use your personal data
  5. How we will contact you?
  6. What is prior consent?
  7. How long is your information kept for?
  8. How we’ll protect your information?
  9. How are links to other websites managed?
  10. International Transfers
  11. Your rights in relation to your information
  12. How to complain?
  13. Review of this policy

1. How do we collect information from you?

We obtain information about you when you use our website (e.g. may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise), receive our emails and meet with us in person. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.

2. What type of information is collected from you?

The personal information we collect could include your name, job title, address, phone number, email address. When your visit our website, your IP address and information regarding what pages are accessed and when could also be gathered. This information may also be gathered when we meet with you, through email or when you complete an online form. As the information will enable us to tailor our services to you. If you decide not to provide this, we may not be able to offer the appropriate products and services to you from the outset.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

3. How is your information used?

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.

• 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 obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

4. Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use 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.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new client
  • (a) Identity
  • (b) Contact
Performance of a contract with you
To process and deliver services to you including:
  • (a) Manage payments, fees and charges
  • (b) Collect and recover money owed to us
  • (a) Identity
  • (b) Contact
  • (c) Profile
  • (d) Usage
  • (e) Marketing and Communications
  • (a) Performance of a contract with you
  • (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
  • (a) Notifying you about changes to our terms or privacy policy
  • (b) Asking you to leave a review or take a survey
  • (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 products/services)
To enable you to partake in a prize draw, competition or complete a survey
  • (a) Identity
  • (b) Contact
  • (c) Profile
  • (d) Usage
  • (e) Marketing and Communications
  • (a) Performance of a contract with you
  • (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (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
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
  • (a) Identity
  • (b) Contact
  • (c) Profile
  • (d) Usage
  • (e) Marketing and Communications
  • (f) Technical
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
  • (a) Technical
  • (b) Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
  • (a) Identity
  • (b) Contact
  • (c) Technical
  • (d) Usage
  • (e) Profile
  • (f) Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our business)

 

5. How we will contact you?

If you are a client of FINALLY AGENCY Ltd, we will contact you at the agreed intervals (i.e. monthly and quarterly) to honour the services set out in our Service Level Agreement – for instance, to provide a web analytics report. We may also contact you in between the agreed intervals if, for any reason, we believe that there is a compelling reason to do so i.e. with details of the other services which you would benefit from or with information regarding your account.

If you are not an existing client of FINALLY AGENCY Ltd, we may still contact you for marketing purposes by post, email and phone if you have given your prior consent or if we believe that you will have a legitimate interest in the services that we offer. You can change your marketing preferences at any time by contacting us by email or post, using the address supplied above.

 

6. What is prior consent?

Prior consent means that you are happy to receive any and all marketing correspondence from us via post, telephone and/or email. It can only ever be given by the direct recipient of our correspondence. In the case of a group email address or general telephone number, the person requesting the opt in will be assumed as the owner of this means of communication.

Prior consent can be given by ticking an opt in box on our marketing preferences form, available online or offline. If consent is offered verbally or in writing, we will opt you in at your request. At this stage, you will be asked how you wish to be contacted (e.g. via email, telephone or post). Consent will be refreshed at regular intervals by FINALLY AGENCY Ltd.

You can ask us to stop sending you marketing messages at any time by contacting us at any time. 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 purchase, warranty registration, product/service experience or other transactions.

7. How long is your information kept for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

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 purposes.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we will anonymise 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.

8. How we’ll protect your information?

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. 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.

At FINALLY AGENCY Ltd, we operate a clean desk policy so any physical copies of your information (e.g. business cards, telephone messages) will be locked away at the end of the working day.

9. How are links to other websites managed?

Our website may contain links to other websites run by other organisations. This privacy policy applies only to our website‚ so we encourage you to read the privacy statements on the other websites you visit. We cannot be responsible for the privacy policies and practices of other sites even if you access them using links from our website.

In addition, if you visited our website via a link from a third party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that website and recommend that you check their own privacy policy.

10. International Transfers

If we transfer your personal data out of the UK, we 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 countries that have been deemed to provide an adequate level of protection for personal data.

Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

11. Your rights in relation to your information

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

  • 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 your 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 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 your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: 
  • If you want us to establish the data's accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • 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. 
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 
  • Request 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. 
  • Right to 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.

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 could 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 could 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.

12. How to complain?

If you believe that we are not holding your information correctly or are unhappy at any dealings with us regarding your information, you may complain to the Information Commissioners Office. You can do this via their website https://ico.org.uk/concerns or by calling 0303 123 1113.

13. Review of this policy

We keep this policy under regular review.

This policy was last updated: November 2023.