Privacy Policy

 

GoTo Digital Marketing Limited (“GoTo”) takes your privacy and the protection of your personal data very seriously. Any reference to “we”, “us” or “our” in this policy is a reference to GoTo, and any reference to “you” or “your” is a reference to the visitor to our websites or the individual person who provides us with personal data through our services.

 

This policy explains what information we gather about you, how we use that information, what we use that information for and who we may share that information with. It also sets out your rights in relation to any information about you that we may hold or process.

 

This policy applies to information that we collect about visitors to this website and those that decide to use the services we provide (this website and our services are the “GoTo Site”).

 

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

 

1. Who we are and what we do

 

GoTo Digital Marketing Limited is the controller and responsible for the GoTo Site, except as specifically noted elsewhere in this policy. GoTo Digital Marketing Limited is a company incorporated in England and Wales with company number 08980112 with registered office at 8 Greencoat Place, London SW1P 1PL.

 

GoTo provides information about the products or services shown on the GoTo Site and enables you to connect with providers of those products or services (“Providers”) if you consent to the connection and you provide the information we require to make Provider connections. At your request, we make these connections by collecting relevant information from you, typically through an online form on the GoTo Site and/or by phone, and sharing it with Providers.

 

You will be given the opportunity to consent to the sharing of your data with Providers. If you consent, Providers may use the data we share to contact you with information about the products or services that they provide. You are under no obligation to buy or use the Provider offerings. Before we share your data with a Provider, we require them to sign a contract that, among other things, sets out the Provider’s obligations regarding the use of your data, which will be consistent with terms of this policy, such as to protect your data and not to share it with other parties without your consent. For details, see section 5 (Sharing your data with third parties).    

 

2. Third party links
 

The GoTo Site may include 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. Any third-party links referred to on the GoTo Site are not managed by GoTo and, when you follow links to third-party sites, this policy no longer applies, and you should ensure that you review and understand the privacy policy of that site before use.

 

3. The information we collect about you
 

We use different methods to collect data from and about you including through direct interactions. For example, you may provide us with your personal data by filling in forms or by corresponding with us by post, phone, email, electronic messaging services or otherwise.

 

You can browse the GoTo Site without entering any personal data; however, we use cookies to provide functionality to the GoTo Site and may use them to create custom and look-alike audiences and to deliver our services to Providers. Cookies do not contain your name, address, phone number, email address, or anything that enables us to determine your actual identity, but they collect some personal data, such your cookie or mobile advertising ID, sites that your device visited and the time, and your device’s IP address. See section 6 for more information about how we use cookies.

If you choose to request information about a product or service which is being advertised on the GoTo Site or any of the products or services we or a Provider (as defined above) offers, you will be asked to provide us with personal data through a request form. Information we collect may include: your name, email address, telephone number and postcode, and details about the product or service in which you are interested. We may also call you to clarify or supplement the information you provide.

 

Providers may return data to us about you or your engagement with them or their products or services, which we may use to assist them in fulfilling the Purpose described below. The Providers’ data also may include information about your interaction with the Providers, such as whether you made a purchase, which we may use in our marketing or to improve our services.

 

We may use data from Providers and other data we lawfully collect from and about you to create custom and look-alike audiences, which we may use to market new or additional services to you and others who have interests similar to yours. To create custom and look-alike audiences, we use data we have obtained from and about you and other users of our services that have attributes similar to yours, which is associated with a pseudonymous identifier in lieu of information that can be used to identify you. A custom audience is a pseudonymous audience of our users. A look-alike audience is an audience of other persons created in Facebook or other platforms that shares attributes similar to yours. We use these audiences to market products and services to you on Facebook and other platforms. If you object to our use of your data to create custom and look-alike audiences, please notify us using the instructions in section 13 at the end of this policy.         

 

In certain circumstances, to process your request, we may request that you provide us with certain sensitive personal data (as defined in the applicable data protection laws from time to time) in which event we will only collect and process such data where we have obtained your explicit consent.

 

We endeavour to only collect the minimum amount of information necessary to fulfil your request. However, some of the information that we ask you to provide is mandatory for the operation of the GoTo Site, and if you do not provide it, we may not be able to action your request.

 

4. How we will use the information about you

 

When you provide your personal data to us, then subject to your rights described in section 12, we may use it for any of the purposes described in this policy, including, but not limited to:
 

(a) where it is necessary for our/your legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;

 

(b) to administer and manage the GoTo Site, including: to continue to improve the user experience on the GoTo Site; and to conduct benchmarking and data analytics, for example, determining the usage of the GoTo Site and sorting and analysing your data for this purpose;

 

(c) to conduct quality and risk management assessments;

 

(d) to monitor compliance with the GoTo Site’s terms of use and this policy;

 

(e) where we need to comply with a legal/regulatory obligation; and/or

 

(f) any other purposes for which you have provided your personal data to GoTo, including, where you have provided your consent, using such personal data for the purposes set out in section 5 below.

 

5. Sharing your data with Providers

 

When you provide your personal data to us, such as through a form on the GoTo Site, you will receive a notice asking you to consent to GoTo sharing such personal data with Providers of the products or services related to your enquiry (for example, if you provide your personal data to receive quotes from Providers of the products or services specified on the GoTo Site), and to allow GoTo and the Providers to use your data for the Purpose (as defined below).

 

GoTo and the Providers will only use your data for contacting you via phone, email, SMS or post from time to time for the purpose of marketing Providers’ products and/or services to you that, by providing your personal data on the GoTo Site, you have expressed an interest in receiving (the “Purpose”). You have the right to opt-out of any of GoTo’s or the Providers’ marketing communications using the opt-out methods provided by GoTo or the Providers and, unless expressly stated otherwise and having obtained the necessary consents from you, GoTo and the Providers will only contact you for the Purpose.

 

The Providers have agreed and have provided the necessary confirmation and warranties to GoTo that they will only use your personal data where you have provided your consent on the GoTo Site and that they will only process your personal data for the Purpose and in accordance with this policy, GoTo’s instructions and applicable laws. For the purpose of this policy and the processing by Providers in relation to the Purpose, each Provider is a data controller and, therefore, you should, in the event that you wish to exercise any of your legal rights in relation to your data (including those set out in paragraph 12) held by a Provider, consult the privacy policy of the relevant Provider.

 

6. Cookies and other information-gathering technologies

 

The GoTo Site uses cookies. Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. These cookies allow us to distinguish you from other users of the GoTo Site which will help us to provide you with an enhanced user experience when you use the GoTo Site and allows us to continuously improve the GoTo Site. You can set your browser to refuse all or some browser cookies, or to alert you when the GoTo Site sets or accesses cookies. We have provided more information about managing your cookie settings below. If you disable or refuse cookies, please note that some parts of the GoTo Site may become inaccessible or not function properly.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set, visit www.aboutcookies.org or www.allaboutcookies.org.

For detailed information about how to manage cookies on popular browsers, visit:

Google Chrome

Microsoft Edge

Mozilla Firefox

Microsoft Internet Explorer

Opera

Apple Safari

To find information relating to other browsers, visit the browser developer's website. For information on controlling your preferences on mobile devices, visit the Network Advertising Initiative’s mobile choices guide.

 

To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.

 

7. Security of your personal data

 

We adhere to highly stringent security measures to protect your personal data from misuse, loss or alteration. Only persons who have agreed to protect and keep confidential your personal data in line with this policy and our practices relating to data protection and confidentiality have access to your personal data you provide to us.

 

We take all appropriate measures to protect personal data; however, as any transfer of data over the internet is not completely secure we cannot guarantee absolutely the security of data transmitted to us over the internet. 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.

 

8. Data retention

 

In general, 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, governance or reporting requirements.

 

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, having regard to the applicable legal, regulatory, tax, accounting, governance or other requirements. 

 

Where you have provided consent to use your personal data, we will retain your data for six months from the date you make your enquiry so that we can provide our services or process requests from you or Providers. In addition, unless you opt-out of receiving marketing communications from us, we will retain your data for that purpose until such time as you have not engaged with our marketing communications for six consecutive months.  

 

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 of our relationship with you.

 

In some circumstances you can ask us to delete your data (see your legal rights in section 12 and instructions for contacting us in section 13).

 

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.

 

9. Transfer of personal data

 

When necessary and lawful for our processing, your personal data may be transferred to and stored outside of the United Kingdom. This includes countries outside of the European Economic Area (“EEA”) which may not have local laws which specifically provide protection for personal data. Where your personal data is collected within the EEA and transferred out of the EEA, it will only be transferred where: the recipient is located in a country which provides an adequate level of protection; and/or, an agreement is in place which includes contractual clauses that are of a standard approved by the European Commission for the purposes of transferring personal data outside of the EEA.

 

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

 

In accordance with this policy, we may transfer or disclose the personal data we collect to subcontractors and to their third-party contractors and their subsidiaries and affiliates. This may be necessary for administrative, security, storage and management purposes and to process the information for the reason it has been submitted on the GoTo Site and we will, where it is necessary to share your personal data in this way, ensure that there are necessary data protection and confidentiality protections in place with such third-party affiliates.

 

10. Applicable law and lawful basis for processing

 

The terms of this policy, its subject matter and its formation are governed by English law. You and we both agree that the courts of England and Wales will have exclusive jurisdiction except where applicable laws prohibit this agreement.

 

Under GDPR, we are a data controller with respect to your personal data, except where specifically noted otherwise in this policy. GDPR requires controllers to have a lawful basis for processing personal data, such as the data subject’s consent or the controller’s or processor’s legitimate interests. With respect to data we have received with your consent, consent is our basis for processing data (including when we are a processor for a third-party controller that has obtained consent from you). All other processing of personal data described in this policy is in our legitimate interests, provided they are not overridden by your data protection interests or fundamental rights and freedoms. In all cases, our processing of your personal data is subject to your legal rights described in section 12.    

11. Changes to this policy

 

We keep this policy under regular review and may update it from time to time. Please check these terms regularly to ensure you understand the terms that apply at that time. The date of the last update is noted at the end of the policy.

 

12. Your legal rights

 

Under the EU General Data Protection Regulation, you have a number of rights in respect of your personal data. In summary, these rights are to:

 

(a) 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.

 

(b) 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.

 

(c) 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 applicable 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.

 

(d) 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.

 

(e) 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.


(f) 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.

 

(g) 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 or processing that we may perform as a data processor for other data controllers. 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.

 

To exercise your rights described above and elsewhere in this policy, please follow the instructions in section 13 below.

13. Contact us

 

We welcome your views about the GoTo Site and this policy. If you would like to contact us with any queries, comments or with a request concerning your rights under section 12 please send an email to hello@gotodigital.com or send a letter to 8 Greencoat Place, London SW1P 1PL and we will endeavour to respond to your request in a timely manner.

 

 

Last updated: 06 March 2019