Privacy Policy

Last Updated: 26 May 2021

Empower Agency (referred to as “we” throughout this policy) are committed to protecting and respecting your privacy and keeping personal information secure. This policy applies to our website and digital presences, including empower.agebncy (and its subdomains). All of these websites are referred to as ‘our website’ in this policy.

This policy (together with our Terms of Use and Anti-Spam Policy, our Cookie Policy and any other documents that they refer to) sets out:

• details of the personal information that we may collect from you;
• information about how we use your personal information;
• information about the limited way we share your information with our partners;
• information about how we store your information; and
• information about your rights.

Please read this policy carefully to understand our views and practices regarding your personal data and how we will treat it.

Some key points to note:

• Our websites use cookies – learn more
• We use analytics tools to track user behaviour on our website
• We use third party email services providers who will have access to your data

Who is this policy addressed to?

For the purpose of data protection legislation including the General Data Protection Regulation (‘GDPR’), the data controller of your personal data is Empower Agency Ltd of 69 Coborn Road, London E3 2DB (registered at Companies House with company number 08538616 and trading as Empower Agency).

When we refer in this policy to ‘you’, we are referring to a customer of our services, or a person visiting our website.

Information we may collect from you

We may collect and process the following data about you:

• Information that you provide to us. You may give us your information by filling in forms on our website or by corresponding with us by email, phone or otherwise. This includes information you provide when you register to use our service, respond to any surveys that we send to you to complete, and when you contact us for any reason. When you register for our services we will ask for a range of information we need to collect in order to provide our services. If you contact us, we may keep a record of any information contained in the correspondence.
• Data for the purposes of advertising and targeting – see the ‘Advertising and targeting’ section below.

How we use your personal information

We use information held about you for the following purposes:

• to provide you with information or services that you request from us, including responding to any requests for assistance with the service;
• to send you newsletters about our service and notify you about any changes to the service;
• to carry out our obligations arising from any contracts entered into between you and us;
• to administer our site and for internal operations, including troubleshooting;
• to help optimise and develop our service, for example through statistical analysis and research on your use of our service;
• as part of our efforts to keep our website safe and secure and to monitor actual or suspected fraudulent activity;
• to carry out targeted advertising (see the ‘Advertising and targeting’ section below).

Advertising and targeting

We use third-party providers to display adverts for our services on other websites. We, alongside these third-party providers, may use cookies and other similar tracking technologies, such as web beacons, to show you targeted adverts for Empower based on your browsing activity. We may also share your email address with Facebook or Google in a protected (hashed) form for similar targeting purposes. See our list of processors and sub-processors and our Cookie Policy for further information on the data we share with our third-party providers.

Cookies and tracking technologies

Our website uses cookies to distinguish you from other users of our website. The majority of these cookies are required to provide our service and so that we can personalise the service offered. We may also cookies and other similar tracking technologies, such as web beacons, for advertising and targeting purposes. See our Advertising and targeting section for further details.

Where we store your personal data

The account details and IP address that we collect from you are stored on our servers inside the UK and European Economic Area (“EEA”). All the personal data we collect from you may be processed by our staff, or those of our ESPs and other service providers (see our list of processors and sub-processors) operating outside the UK and EEA. Such staff may be engaged in, among other things, the fulfilment of your services, and the provision of support services. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. Please contact us if you would like more details on the appropriate safeguards we employ to require that these providers process your data with due respect for its privacy.

Security

All information you provide to us is stored on our secure servers.

We take security very seriously, and ‘privacy by design’ is baked into our engineering and product development principles but, as with any online service, despite our use of leading security tools and techniques, the personal data we hold about you can never be 100% immune from unauthorised access.

Disclosure of your information

We may disclose your personal information to any company under the same ownership as us.

We may disclose your personal information to selected third parties, including:

• in the event that we sell or buy any business or assets, the prospective seller or buyer of such business or asset;
• if Empower Agency or substantially all of its assets are acquired by a third party, to the relevant third party;
• business parties and subcontractors for the purposes of providing the Empower Agency services;
• analytics providers that assist us in the improvement and optimisation of our website; and
• law enforcement agencies or regulatory bodies; or other third parties for fraud detection and prevention. We will only do this is if we are legally required to do so.
• We may also disclose your personal information to third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Use and Anti-Spam Policy and other agreements, or to protect the rights, property, or safety of Empower Agency, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud detection and protection and credit risk reduction.

Retention of your personal information

The periods for which we keep your information depend on why your information was collected and what we use it for. We will not keep your personal information for longer than necessary for our business purposes or for legal requirements.

Legal basis for processing

We are required to state the legal basis on which we undertake processing of your personal information. We will only use your information where:

• we have your consent to do so; or
• we need to process the personal information to perform services for you under our terms and conditions of service.
• We have a legitimate interest in engaging in the provision of our EmailOctopus service and in offering products and services of value to you. Please contact us if you would like to learn more about our assessment of our legitimate interests in processing data.
• We are processing the data to meet a legal requirement.

Any consent you provide may be withdrawn at any time by emailing us.

Your rights

You have the right to request access to personal data that we may process about you.

You have the right to require us to correct any inaccuracies in your data, free of charge. If you wish to exercise this right, you should:

• put your request in an email to us;
• provide us with enough information to identify you (e.g. name and email address); and
• specify the information that is incorrect and what it should be replaced with.

You can access, correct, update or request deletion of your personal information at any time, either through your online account or by contacting us.

Deletion of data will be carried out on the understanding that removal of some information (e.g. email address) may negatively affect your ability to use Empower Agency’s services.

We cannot delete any invoices, as these are kept for tax purposes.

You can request that we restrict processing of your personal information, object to processing of your information or request portability of your personal information. For these requests please contact us. We will comply with your request where your rights have been exercised in accordance with applicable laws.

If we have collected and processed your personal information with your consent, then you can withdraw that consent at any time. To be clear, we may still continue to process your data if we have a different legal basis for doing so (for example, if we are required by law to do so, or we need to do so for the purposes of fulfilling our obligations to you under our terms and conditions of service).

You also have the right to ask us to stop processing your personal data for direct marketing purposes. You can do this via email. If you wish to exercise this right via email, you should:

• put your request in writing (an email with a header that says ‘Unsubscribe’ is acceptable);
• provide us with enough information to identify you (e.g. email address); and
• if your objection is not to direct marketing in general, but to direct marketing by a particular channel (e.g. email or telephone), please specify the channel you are objecting to.

Changes to privacy policy

We keep our privacy policy under regular review. If we change our privacy policy we will post the changes on this page, notify you, and place notices on other areas of the site, so that you may be aware of the information we collect and how we use it at all times.

Complaints

If you have any questions or comments regarding our use of your data, please contact us by email. If you make a complaint to us and think we have not dealt with it to your satisfaction, you may send your complaint to the Information Commissioner for investigation. For more information on the Information Commissioner, and how to make a complaint, please visit their website.

Our contact details

We welcome your feedback and questions. If you wish to contact us, please send an email to ben@empower.agency