Effective date: 15th October 2024
Last updated: 15th October 2024

  1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy policy: This privacy policy is designed to inform you about how Affluent Audiences collects and processes your personal data when you interact with Affluent Audiences and its website, digital platforms, products, and services.

To ensure you are fully aware of how and why we use your data, please read this privacy policy alongside any other privacy notices we may provide at specific times when we are collecting or processing your personal data. This privacy policy complements our other privacy policies and does not replace them.

Data Controller: Affluent Audiences (“AA,” “Affluent Audiences,” “We,” “Us”) is a sole trader operating in England and Wales under the name Nichola McMorrough.

Contact Details: The Data Protection Officer (DPO) for Affluent Audiences is responsible for overseeing any inquiries regarding this privacy policy and our privacy practices. If you have questions about this privacy policy or wish to exercise your legal rights, please contact us using the details below:
Full name of legal entity: Affluent Audiences
Email address: DPO@affluentaudiences.co.uk
Postal address: Data Protection Officer, Affluent Audiences, Calveley Farmhouse, Long Lane, CW6 9LH, United Kingdom

The Information Commissioner’s Office (ICO) is the regulator for personal data processing in the United Kingdom and serves as the supervisory authority for data protection matters. You have the right to file a complaint with the ICO at any time (www.ico.org.uk).

However, we would appreciate the chance to address your concerns first and will strive to resolve any issues or complaints you may have.

Changes to the privacy policy and your duty to inform us of changes: We regularly review our privacy policy. This version was last updated on 15th October 2024. We recommend checking this privacy policy frequently for any updates or changes.

It is crucial that the personal data we hold about you is accurate and current. Please inform us if your personal data changes during your relationship with us.

Third-party links: Our websites and digital platforms may feature links to third-party websites, plug-ins, and applications. Clicking on these links or enabling these connections may allow third parties to collect or share data about you. We do not control these third-party sites and are not responsible for their content, security, or privacy policies. We advise you to review the privacy and security policies of any website or social media service you visit and/or join.

  1. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, refers to any information about a living individual that can identify that person. It does not include data from which identity has been removed (anonymous, aggregated, or de-identified data). We may collect, use, store, and transfer various types of personal data about you, grouped as follows:

We may collect information about you, including your:

  • Identity: (e.g., name, age, location, nationality, citizenship)

  • Contact details: (e.g., business contact information, email address, postal address, phone number)

  • Profiling: demographics and lifestyle (e.g., education, professional or employment-related information, investment history, family and professional affiliations, interests, personal wealth ownership details, reputational background information, or involvement in litigation)

  • Social Media: (e.g., social media handles and posts)

  • Purchase History and known transactions: (e.g., products or services purchased from us or our affiliates and partners, or other publicly known purchases such as yachts, real estate, art, and collectibles)

  • Usage Data: (e.g., information about how you use our websites, products, and services)

  • Marketing and communications data: (e.g., preferences for receiving marketing from us and our third parties, your communication preferences, correspondence with us, including related emails and messages sent through our online platforms, and feedback surveys)

Aggregated or De-Identified Data: We may also collect, use, and share aggregated data such as statistical or demographic data. While aggregated data may be derived from your personal data, it is not considered personal data under the law since it will not reveal your identity, and is therefore not governed by this privacy policy.

Special Categories of Data: We do not collect any Special Categories of Personal Data about you, which includes information about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, health information, and genetic or biometric data. We also do not collect information regarding criminal convictions and offenses.

Children: Our websites and digital platforms are not intended for children, and we do not knowingly collect data from children. If we become aware that we have collected information from a child without parental consent verification, we will delete that information.

  1. HOW IS YOUR PERSONAL DATA COLLECTED?

We utilize various methods to collect data from and about you, including:

  • Direct interactions: You may provide us with your personal information by filling out forms or communicating with us via post, phone, email, SMS/MMS, direct messaging, or other means. This includes data you provide when you:

    • Inquire about or purchase our products and services

    • Attend our events

    • Create an account on or visit our website

    • Subscribe to our services or publications

    • Request marketing materials

    • Enter a competition, promotion, or survey

    • Provide feedback or contact us

  • Automated technologies or interactions: As you engage with our websites and digital services, including social media platforms, we will automatically collect technical data about your equipment, browsing actions, and patterns. This personal data is gathered through cookies and similar technologies. We may also receive technical data about you if you visit other websites that use our cookies.

  • Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources, including:

    • Public Registers

    • Trade and Industry references

    • Professional directories

    • Print and broadcast media

    • Company websites

    • Technical data from third parties like analytics and search information providers

    • Advertising networks

    • Events agencies

    • Information providers or “data brokers”

    • Identity and contact data from publicly available sources and data brokers

    • Information freely available through public internet searches

  1. HOW WE USE YOUR PERSONAL DATA

We utilize and otherwise process the information categories outlined above for the following business purposes. Please be aware that we may process your personal data without your knowledge or consent when required or permitted by law.

PURPOSE/ACTIVITY

  1. To provide our products, services, online platforms, or interactive features; to manage accounts and relationships with clients, including providing information, products, and services.

TYPE OF DATA:
a) + b) Identity, Contact, Profiling: demographics and lifestyle, Social media, Purchase history, Usage data

EEA/UK LAWFUL BASIS FOR PROCESSING, INCLUDING BASIS OF LEGITIMATE INTEREST:

a) Performance of a contract with our clients
b) Necessity for our legitimate interests (e.g., keeping our records updated and growing our business)

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PURPOSE/ACTIVITY

  1. To inform you about changes to our terms or Product Privacy Notice.

TYPE OF DATA:
Identity, Contact, Purchase history, Usage data

EEA/UK LAWFUL BASIS FOR PROCESSING, INCLUDING BASIS OF LEGITIMATE INTEREST:

Necessity to comply with a legal obligation

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PURPOSE/ACTIVITY

  1. To suggest and recommend similar items to those you have inquired about or that may interest our clients, or, where legally permitted, to send promotional materials from us or our affiliates and trusted business partners.

TYPE OF DATA:
Identity, Contact, Profiling: demographics and lifestyle, Social media, Purchase history, Usage data

EEA/UK LAWFUL BASIS FOR PROCESSING, INCLUDING BASIS OF LEGITIMATE INTEREST:

Necessity for our legitimate interests (to operate and grow our business)

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PURPOSE/ACTIVITY

  1. To enhance our products and services, ensuring that content is presented in the most relevant and effective way; to administer our products and services, including troubleshooting, data analytics, testing, research, and statistical purposes; to maintain the safety and security of our products, services, business, and users.

TYPE OF DATA:
Identity, Contact, Profiling: demographics and lifestyle, Social media, Purchase history, Usage data

EEA/UK LAWFUL BASIS FOR PROCESSING, INCLUDING BASIS OF LEGITIMATE INTEREST:

Necessity for our legitimate interests (to run, protect, and grow our business, to provide IT services, ensure network security, prevent fraud, study user interactions, and develop products)

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PURPOSE/ACTIVITY

  1. To adhere to applicable laws and regulations, and to protect or exercise our legal rights or defend against legal claims.

TYPE OF DATA:
Identity, Contact, Profiling: demographics and lifestyle, Purchase history, Usage data

EEA/UK LAWFUL BASIS FOR PROCESSING, INCLUDING BASIS OF LEGITIMATE INTEREST:

Necessary to comply with a legal obligation

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PURPOSE/ACTIVITY

  1. To assess what we believe you may want or need, or which products, services, and offers may be relevant for you. You will receive marketing communications from us if you have requested information or purchased from us and consented to receive marketing, where required.

TYPE OF DATA:
Identity, Contact, Profiling: demographics and lifestyle, Social media, Purchase history, Usage data

EEA/UK LAWFUL BASIS FOR PROCESSING, INCLUDING BASIS OF LEGITIMATE INTEREST:

Necessity for our legitimate interests (to run, protect, and grow our business, and inform our communications strategy)

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PURPOSE/ACTIVITY

  1. Profiling and analysis for strategic brand development for us or our clients.

TYPE OF DATA:
Identity, Contact, Profiling, demographics and lifestyle, Social media, Purchase history

EEA/UK LAWFUL BASIS FOR PROCESSING, INCLUDING BASIS OF LEGITIMATE INTEREST:

Necessary for our legitimate interests (to operate our business and develop marketing material)

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PURPOSE/ACTIVITY

  1. Profiling and identifying influencers, Royals, and VIPs.

TYPE OF DATA:
Identity, Contact, Profiling, demographics and lifestyle, Social media, Purchase history

EEA/UK LAWFUL BASIS FOR PROCESSING, INCLUDING BASIS OF LEGITIMATE INTEREST:

Necessary for our legitimate interests (to operate our business and create marketing material)

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PURPOSE/ACTIVITY

  1. Cultivating relationships with influencers.

TYPE OF DATA:
Identity, Contact, Profiling, demographics and lifestyle, Social media, Purchase history

EEA/UK LAWFUL BASIS FOR PROCESSING, INCLUDING BASIS OF LEGITIMATE INTEREST:

Necessary for our legitimate interests (to operate our business and create marketing material)

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PURPOSE/ACTIVITY

  1. To retain a record of company history.

TYPE OF DATA:
Identity, Contact, Purchase history

EEA/UK LAWFUL BASIS FOR PROCESSING, INCLUDING BASIS OF LEGITIMATE INTEREST:

Necessary for our legitimate interests (to operate our business and create marketing material)

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PURPOSE/ACTIVITY

  1. To capture images and/or videos for marketing and promotion across all media, including AA’s printed publications, presentations, promotional materials, advertising of AA’s goods or services, or on the AA website or within video montages, training materials, newsletters, and blogs, unless you object.

TYPE OF DATA:
Identity, Contact, Social media

EEA/UK LAWFUL BASIS FOR PROCESSING, INCLUDING BASIS OF LEGITIMATE INTEREST:

Necessary for our legitimate interests (to create marketing material and grow our business)

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Where legally required and no other valid legal basis exists to process your information, we will obtain consent (for instance, to provide marketing information in line with applicable law), which can be withdrawn at any time by you. Withdrawing consent does not affect the lawfulness of processing based on consent before withdrawal.

If we need to collect information by law or under a contract with you and you fail to provide the requested data, we may not be able to fulfill the contract we have or are trying to enter into (e.g., to provide you with services).

  1. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the following parties for the purposes outlined in Section 4, ‘How we use your personal data’:

  • Internal third parties: such as other companies owned by the same holding company as Affluent Audiences

  • External third parties: such as partners, service providers acting on our behalf, professional advisers, and regulatory bodies

  • Third parties to whom we may sell, transfer, or merge parts of our business or assets. Alternatively, we may seek to acquire or merge with other businesses. If a change occurs in our business, the new owners may utilize your personal data in accordance with this privacy policy.

We require all third parties to respect the security of your personal data and to process it in compliance with the law. We do not permit our third-party service providers to use your personal data for their own purposes and only allow them to process your personal data for specified purposes per our instructions.

  1. INTERNATIONAL TRANSFERS

We may transfer and store your information on servers located outside your country of residence. Some entities (like third-party vendors) to which we disclose information may be located outside the EEA, including in countries that may not offer the same level of data protection as your home country. We take appropriate measures to ensure that such personnel and third-party vendors adhere to confidentiality obligations, implementing measures such as standard data protection contractual clauses to safeguard transferred information.

  1. DATA SECURITY

We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, accessed in an unauthorized manner, altered, or disclosed. Additionally, access to your personal data is restricted to employees, agents, contractors, and other third parties who have a legitimate business need to know. They will only process your personal data based on our instructions and are bound by confidentiality obligations.

We have established procedures to address any suspected personal data breaches and will notify you and any applicable regulators of a breach when legally required to do so.

  1. DATA RETENTION, SECURITY, AND INTEGRITY

Information will be retained only for as long as reasonably necessary for the purposes outlined above and in accordance with our retention policies and applicable laws. As we provide information products and services to our customers, we will maintain data in our secure database until we determine it is no longer useful to our customers, while considering data minimization principles and our legal obligations.

We maintain reasonable security measures to protect information from loss, theft, misuse, unauthorized access, disclosure, alteration, or destruction. We also have procedures in place to ensure that such data is reliable for its intended use and remains accurate, complete, and current.

Please be aware that no data storage system or transmission over the Internet or any other public network can be guaranteed to be 100 percent secure, accurate, complete, or current. Note that information collected by third parties may not have the same security protections as information you submit to us, and we are not responsible for the security of such information.

All employees, contractors, and data processors (i.e., third parties processing personal data on our behalf) are required to maintain confidentiality regarding such data and may not use it for any purpose other than performing the services requested.

  1. YOUR LEGAL RIGHTS

Under data protection law, you have rights, including:

  • Your right of access: You can request copies of your personal information, known as a "data subject access request," which allows you to receive a copy of any personal data we hold about you.

  • Your right to rectification: You can request that we correct any inaccurate personal information or complete information you believe is incomplete. We may need to verify the accuracy of new data you provide. In many cases, you can amend personal data directly.

  • Your right to erasure: You can request that we delete your personal information under certain circumstances, such as when there is no valid reason for us to continue processing it. You also have the right to request deletion of your personal data if you have successfully exercised your right to object to processing, or if we have processed your data unlawfully or are legally required to delete it. However, we may not always be able to comply with your erasure request for specific legal reasons, which we will notify you of when applicable.

  • Your right to restriction of processing: You can ask us to limit the processing of your personal information under certain circumstances, such as if you want us to verify its accuracy, if our processing is unlawful but you wish to retain the data, or if you need the data to establish, exercise, or defend legal claims, even if we no longer need it.

  • Your right to object to processing: You can object to the processing of your personal information in certain cases. In some situations, we may demonstrate compelling legitimate grounds for processing your information that override your rights and freedoms.

  • Your right to data portability: You have the right to request that we transfer your personal information to another organization, or to you, under certain circumstances.

Request to withdraw consent: You can withdraw consent at any time if we rely on consent to process your personal data. If you withdraw consent, we may not be able to provide certain products or services to you. We will inform you if this is the case when you withdraw your consent.

You are not required to pay any fees to exercise your rights. If you make a request, we have one month to respond.

How to exercise your rights:
To exercise any of these rights, please contact us by post or email at the following addresses:
Chief Privacy Officer
Affluent Audiences
Calveley Farmhouse
Long Lane
CW6 9LH
United Kingdom
Email: dpo@affluentaudiences.co.uk

We may need to verify your identity before processing a request. We will make every effort to address your questions and concerns.

You also have the right to lodge a complaint directly with the Regulator concerning the processing of your personal data—the Information Commissioner in the UK or the regulatory body in your country of residence. You can contact the UK Information Commissioner at the link provided or in writing at:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk

For other regulatory bodies, this information is readily available.