privacy
Privacy Policy & DPA
We are committed to protecting and respecting privacy. This Privacy Policy should be read in conjunction with our Terms and Conditions and applies to your use of our Service and Site. The same definitions apply.
This Privacy Policy has two sections. Part A relates to your own personal data submitted to us in the course of our business, including your use of our Site and Services, which we decide how to process (i.e. where we are the Data Controller). Part B (Data Processing Addendum or “DPA”) relates to personal data relating to others that you submit to us or we collect to process on your behalf (i.e. where we are your Data Processor).
Part A: Privacy of Your Own Personal Data (CoverageBook.com as Data Controller)
Introduction
Personal data is information that allows someone to identify or contact you e.g. your name, address, telephone number, email address, as well as any other information about you that is associated or linked to such information (‘your Information’). This Privacy Policy sets out the basis on which we may collect, use, process and store your Information that we collect or that you provide to us by any direct or indirect means. Our Site contains privacy panels and information which determine how we will collect and process your Information. Please read the relevant sections of our Site when you submit any Information to us. This Privacy Policy explains our practices regarding your Information and how we will treat it. By submitting any of your Information to us through either our Site or Services or otherwise, you are agreeing to the terms of this Privacy Policy and you expressly consent to the collection, use and disclosure of your Information in accordance with this Privacy Policy and you represent and warrant that you have all rights necessary to submit your Information. Please do not submit to us any personal data relating to you or any other data subject unless you have the right to do so.
Help
If you need any help or assistance in relation to the use of our Site, please contact support@coveragebook.com and we will do our best to get back to you promptly. For any questions about this Privacy Policy, your personal data, or to make a data protection complaint, please contact us at privacy@coveragebook.com (see “Data protection complaints” below).
Information We May Collect from You
We may collect and process the following Information about you:
- Information that you provide or input when you subscribe and use the Services, when you fill out forms on our Site and otherwise by corresponding with us or interacting with us via or in connection with our Site or Services.
- Contact details that you provide to us.
- Any documents, content, communications and electronic files that you upload or import to or transmit through our Site.
- Information that you permit us to access and import from third party websites or storage locations.
- If you contact us or we contact you, by email, telephone, web forms or otherwise, we may keep a record of that correspondence.
- We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
- Details of your visits to our Site including, but not limited to, traffic data, location data, weblogs, and other communication data, and the resources that you access.
- When you access our Site from a computer, mobile phone, or other device, we may collect information from that device about your browser type, location, and IP address etc.
- Searches that you perform via the Site and Services (therefore, be aware of this if you include any personally identifiable information in your searches).
IP Addresses, Cookies and Analytics
Our servers may collect your Information including data about your computer or device, including where available your IP address, operating system and browser type, to assist us in the provision of the Site and Services, for system administration and to report aggregate anonymised information.
We use cookies and similar technologies on our Site. Strictly necessary cookies are always active because the Site cannot function properly without them. We only set analytics, advertising/marketing and preference cookies, including third-party services such as Google Analytics after you have given your consent through our cookie banner.
You can review the full list of cookies, and change or withdraw your consent at any time, on our Cookie Policy page. You may also refuse or delete cookies through your browser settings; if you do, some parts of our Site may not function as intended.
How We Use Your Information
We use your Information in the following ways:
- As reasonably required in order to provide our Site and Services to you and to carry out our obligations arising from our Site and Services.
- To help identify you as a user on our systems.
- For customer services purposes.
- To help us develop the Site and Services and to make them more useful to you.
- To allow you to participate in interactive features of our Site and Services.
- To provide you with news and information about our Services, third party sites and other information that we think may be relevant to you.
- To ensure that content from our Site and Services is presented in the most effective manner for you and for your computer.
- To notify you about changes to our Services.
Legal Basis of Processing
We shall only be entitled to process your Information as above to the extent that at least one of the following applies:
- You have given consent to the processing of your Information;
- Processing is necessary for the performance of a contract to which you are party;
- Processing is necessary for compliance with a legal obligation;
- Processing is necessary in order to protect your vital interests;
- Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority;
- Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.
Disclosure of Your Information
We may disclose your Information subject to the same restrictions as contained in this Privacy Policy to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 736 of the UK Companies Act 1985. We may also disclose your Information to third parties:
- When we subcontract the running of our Site or any part of it to a third party (including but not limited to Third Party API Providers);
- In the event that we sell or buy any business or assets;
- If we or substantially all of our assets are transferred to or acquired by a third party;
- If we are under a duty to disclose or share your Information in order to comply with any legal obligation.
Retention of Your Information
We will endeavour not keep your Information for longer than necessary in order to facilitate your use of our Site and Services. If you wish to delete your content or your account, we will delete the content we hold in relation to you on request. In addition, content that you have submitted to our Third Party API Providers may still be in use and so there may be some ongoing use of your Information.
Your Rights
You have a number of rights as a data subject as summarised below:
Access
You have the right to obtain confirmation as to whether or not personal data concerning you are being processed and to access your Information and details of how we process it.
Rectification
We will rectify any errors in the Information we hold on request.
Erasure
You may erase your Information from our systems in certain situations.
Data Protection Complaints
If you believe we have not handled your personal data in line with the UK GDPR, you have the right to make a complaint directly to us. We encourage you to contact us first so that we can try to resolve any concerns quickly.
Part B: Data Processing Addendum (“DPA”) (CoverageBook.com as your Data Processor)
Processing by Us
You hereby instruct us to process Subscriber Personal Data as reasonably necessary for the provision of the Site and Services and in compliance with our Terms and Conditions, which incorporate this DPA.
Processing of Subscriber Personal Data
Where processing of personal data relating to others controlled by you (“Subscriber Personal Data”) is to be carried out on your behalf, appropriate technical and organisational measures shall be implemented by us in compliance with Data Protection Laws.
Compulsory Processor Terms Pursuant to Article 28(3) GDPR
Details of the subject-matter and duration of the processing, the nature and purpose of the processing, the type of personal data and categories of data subjects are set out below.
In respect of any processing of Subscriber Personal Data we shall:
- Process Subscriber Personal Data only on your documented instructions;
- Ensure that persons authorised to process Subscriber Personal Data have committed themselves to confidentiality;
- Take all measures required pursuant to Article 32 GDPR (Security of processing);
- Assist you by appropriate technical and organisational measures, insofar as this is possible, for the fulfilment of your obligation to respond to requests for exercising data subjects’ rights laid down in GDPR.
- At your choice, delete or return all Subscriber Personal Data after the end of the provision of services relating to processing;
Appendix 1: Details of Processing of Subscriber Personal Data
Parties: (1) CoverageBook Limited and (2) the Subscriber.
Categories of Data Subjects: All users of our Site and Services, mobile applications and other features provided by us which may include:
- Site users
- PR and advertising agencies
- Brand owners/your clients
Categories of Personal Data: All personal data processed in the normal use, management and development of our Site and Services including:
- Names
- Addresses
- Email addresses
- Contact details
- Passwords (hashed)
- Profile information provided by users
- Usage data
- Preferences/personalisation details
- Evidence of opt-ins/contact permissions and other privacy consents/unsubscribe requests
Sensitive Data: No sensitive data to be processed/transferred.
Nature of Processing: To provide the Services.
Purpose of Processing, Data Transfer and Further Processing: To provide the Services.
Duration of Processing/Retention of Data: For the term of the contract between us and you or until such time as we no longer process Subscriber Personal Data on your behalf.
Appendix 4: List of Subprocessors
Applicable to both Modules 2 and 3 of the SCCs. The following Subprocessors have been authorised to process Subscriber Personal Data.
| Name | Purpose | Location | Privacy policy/DPA |
|---|---|---|---|
| AWS | Application Management | USA | Link |
| Google G-Suite | Email provider and documentation | USA | Link |
Changes to Our Privacy Policy
Any changes we may make to our Privacy Policy in the future will be posted on this page and, where we consider appropriate, we may notify you by e-mail in advance of their application. They shall become binding on you on publication on our Site. Any continued use of our Site and/or Services shall constitute your deemed acceptance of such changes.
Contact
Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to privacy@coveragebook.com.