Privacy Policy

Welcome to whiteballoon’s

Privacy Policy

LAST UPDATED 04/03/23

whiteballoon respects your privacy and is committed to protecting your personal data. This policy will inform you as to how we look after your personal data when you visit our website and tell you about your privacy rights and how the law protects you. Please use the Glossary to understand the meaning of some of the terms used in this policy.

It is important to us that you understand that as an individual user (rather than a business user ‘Provider’), unless expressly requested by you, we will not use your personal data for marketing, and that any information which you may enter into the Planning Tools section of our website remains private and will not be accessed by us.

1. Important information and who we are

Purpose of this privacy policy

This policy aims to give you information on how whiteballoon collects and processes your personal data through your use of this website, including any data you may provide through this website when you register with us or purchase a product or service.

It is important that you read this policy together with any other privacy policy or fair processing policy 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 other notices and privacy policies and is not intended to override them.

Data Controller

Whiteballoon Ltd is the data controller and responsible for your personal data (referred to as “whiteballoon“, “we”, “us” or “our” in this policy). Whiteballoon is a registered company in the UK; our company registration reference number is 11403713. Our address is The Nexus Building, Broadway, Letchworth Garden City, Hertfordshire, England, SG6 9BL.

If you have any questions about this policy or our privacy practices, including any requests to exercise your legal rights, please contact us at [email protected].

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our policy under regular review. Please see the top of this page for the date it was last updated. Historic versions can be obtained by contacting us. 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 includes 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 policy of every website you visit.

2. The data we collect about you

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 transfer 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 and date of birth.
Contact Data includes email address and telephone numbers.
Profile Data includes your username and password, feedback and survey responses.
Communications Data includes your communication preferences.
General User Information about your computer and your visits such as your IP address, location, browser, operating system and other such data points.

Please note that we do not have access to, or collect, any information that may be entered by you using our Planning Tools, which are password-protected.

In addition, for business users who may have a listing on our site, we may also collect:

Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
Usage Data includes information about how you use our website and services.
Marketing Data your email address and other contact details, as well as your preferences in receiving marketing from us and any third parties.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

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.

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 you, and you fail to provide that data when requested, we may not be able to provide you with the services offered on our website. In this case, we may have to cancel our services you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us. This includes personal data you provide when you:
create an account on our website;
subscribe to our service or publications;
request marketing to be sent to you; or
give us feedback or contact us.
Automated technologies or interactions. 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. Please see our cookie policy for further details.

4. How we use your personal data

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 have your consent to do so
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.

See below to find out more about the types of lawful basis that we will rely on to process your personal data.

Purposes for which we will use your personal data

Below is a description of how we may use your personal data, and the legal bases we rely on to do so. 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.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	(a) Identity (b) Contact	(a) Performance of a contract with you (b) Necessary for our legitimate interest (to enable you to use our planning tools on our site)
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 (c) Sharing relevant business updates that may be of interest to you	(a) Identity (b) Contact (c) Profile (d) Communications	(a) Your consent (b) Performance of a contract with you (c) Necessary to comply with a legal obligation (d) Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)
To enable you to partake in a survey	(a) Identity (b) Contact (c) Profile (d) Communications	Necessary for our legitimate interests (to study how users and providers use our 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	Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy). Should we use your data for profiling activities, this will involve encryption of the data where possible.
To use data analytics to improve our website, services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

For Individual Users

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We will not use your Identity Data to send you marketing communications unless you have specifically given us your consent to do so, for example when you sign up to our newsletter. You may withdraw your consent at any time by using the ‘unsubscribe’ prompt at the base of our emails, or by contacting us at [email protected].

For Business Users ‘Providers’

Generally, we will use your personal data in accordance with any contractual obligations. We may also rely on legitimate interest as a legal basis for processing your personal data in relation to marketing and advertising. We may include profiling activities within this to find similar businesses and organisations to yours that may be interested in using our services. You are able to update your preferences at any time by contacting us at [email protected].

Cookies

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 collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

Whilst we are a UK based business we do use SAAS providers which may use globally based servers to store and manage data. As a result your data may be shared internationally through service providers that we use to assist us with our business operations. Any such service providers will be working for us as Data Processors and will not use your Personal Data for their own business operations, including marketing activity, at any time.

To minimise any risk we ensure that all service providers are fully vetted before we engage in business with them. We assess this risk regularly to provide ongoing care and diligence in handling your personal data. All our service providers are engaged within a contractual basis.

We may share your personal data with the following third parties:

Service providers acting as processors, who provide IT and system administration services.

These include:

MailChimp – Email Marketing Provider
Stripe – Payment Processing Provider
WordPress – Website Platform
Siteground – Hosting Provider
Cloud Flare – Hosting Operations
Names Co – Business Email Provider
F2B Digital – Our Website Developers
Directorist – Onsite Listing Services
WooCommerce – eCommerce Platform
HubSpot – Database Facilities

Professional advisers acting as processors, based in the United Kingdom and including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
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 use 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 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.

6. Data 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 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.

7. Data retention

How long will you use my personal data for?

When you give us consent to use your data, we will continue to process your data until you choose to withdraw your consent. When your data is collected and used under the lawful basis of legitimate interests, 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 business information for six years. In general for marketing purposes we will retain and use your data for 5 years. In some circumstances you can ask us to delete your data: see Your legal rights 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. Your legal rights

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

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 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 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.

9. Glossary

Lawful Basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.