We collect the following types of information:
Contact details including name, address, and in some cases date of birth, email, landline telephone number, mobile telephone number, hobbies & interests, insurance renewal information is obtained from trusted data partners.
Company Directors Companies House
Electoral Register Open Electoral Register
Council Tax Property Values Valuation Office
Crime Statistics Official Statistics
Corporate Statistics You Gov
General Statistics Office of National Statistics
Living Cost Survey Information National Statistics Food Survey
Property Sold Values Land Registry
Open Data from HM Government Open Data from HM Government
Anonymised Vehicle Data Anonymised Vehicle Data
Open Source Data Open Source Data
Suppression data is used by us to prevent unwanted 3rd party marketing by Post, Telephone, SMS and Email
Mailing Preference Service database which we use to mark records as not wanting to receive Postal Marketing
We use Deceased Suppression to prevent unwanted marketing to deceased loved ones and thereby causing upset. Deceased Data is obtained from National Deceased Register
Information on people that have moved is obtained from Data Partners and a National Address Change Database
The The Preference Centre Suppression Database is used to record people who have opted out of receiving all forms of marketing
The Telephone Preference Service database which we flag records as not wanting to receive any Marketing calls
Client Input Data - This is data that our clients have presented to us for us to carry out enhancements for accuracy and marketing purpose as well as Data Suppression where asked
We are collecting your data to enable us to carry out our own marketing to you of our own products and services as well as products services and offers from others that we feel may be of interest to you.
We will also share your data for commercial gain, including Revenue Collection with third parties. These organisations will have a relationship with you or it may be used where they have a lawful reason, which may include these organisation's own legitimate interest.
Use includes tracing of individuals, verification and/or validation of the identity of individuals for the purposes of, but not limited to, anti-money laundering regulations, national security, crime prevention and detection, anti-fraud processes, asset recovery and asset reunification.
Your data will also be used for the purpose of analysis or to create a data product. In this case your information is aggregated in line with the ICO code of practice and anonymously used for marketing purposes.
We will share your data with the Marketing Service Providers specialist Marketing Agencies & Data Brokers listed who will use it to create products and services to help organisations better understand the likely characteristics of their customers, communicate with them more effectively and find others like them across a range of marketing channels.
This may mean that you receive advertising that is more relevant to you via direct mail or when you visit a website.
Additionally under data protection laws we are permitted to share some information where the reason for doing so is legitimate and isn't outweighed by the effects on the relevant individuals. On the basis, to help make advertising more relevant to you and full of offers that we hope you'll find relevant.
We provide the types of information detailed in the above section - The information we collect, hold and process to our Clients for the purpose of carrying out our and their business.
Some of our Clients we provide this information to so they can carry out their business as Marketing Service Providers and Marketing Agencies & Data Brokers.
We will also add your data to other data to create GEO and Wealth profiles which are based on postcode. This type of information is anonymised and does not directly relate to the consumer however it is a reflection of the postcode area
Listed below are companies that we provide our data to for their own or their clients marketing purposes as well as data broking and debt recovery and tracing.
The consent you provided for any information you have previously shared with us or any third parties will be renewed at the time you give your consent for any new information sharing unless you indicate otherwise by contacting us.
If you do not wish for your data to be used this way please see the section - Your rights & Choices to unsubscribe.
BlueSky Media LLC
Bridge Marketing LLC
Carphone Warehouse may pass your details on to your mobile network for an upgrade check and if eligible, we will retain your data for a future call about an upgrade offer.
Direct Data Services (DDS) Ltd
Email Marketing PVT Ltd
Equinity Data Ltd
Global Telemarketing Services BV
- LFS Claims - Who operate in PPI Claims Management
Modern Business Solutions LLC
The Ark (CM) Ltd
We Breathe Media Ltd
Zeta Global LLC
We will share your data with the Marketing Services Providers listed below, who will use it for a variety of direct marketing purposes. Marketing Services Providers carry out data profiling. They will combine your data with data they get from other sources (including public sources) and use it to create “predictive models”. Marketing Services Providers use these models to try to predict behaviour and preferences (e.g. how likely you are to buy a holiday online or take a particular type of holiday) or likely circumstances (e.g. whether you are eligible for a particular credit card).
In sharing your data with Marketing Services Providers, we rely on a lawful ground called ‘legitimate interest’, as our business depends on our ability to partner with third parties who process personal data for marketing-related reasons.
Marketing Services Providers will also try to match and then link your data with data that they receive about you from other sources, to make sure that the data they hold about you is correct (e.g. to check whether you have recently moved address).
They share your data, including the profiled data they have created about you, primarily to:
Help organisations better understand the likely characteristics of their customers (and find others like them) Improve the relevancy and appropriateness of an organisation’s marketing to its customers (e.g. offers, its products and services) and help them communicate with their customers more effectively offline and online. This may mean that you receive tailored advertising via direct mail or when you visit a website.
To understand more about the use of your data by Marketing Services Providers, and to find out how to exercise your data protection rights in relation to their use of your data (including how to opt-out), please click through to the websites of the companies below:
Blueberry Wave Ltd
Bridge Marketing LLC
Cloud Digital Communications Ltd
Data OD Ltd
- Data OD Ltd / Data On Demand
- TwentyCI Limited
- Emailmovers Limited
- Virgin Media
- Lloyd James Media Group
DBS Data Ltd
Equiniti Data Ltd
GB Group Ltd
Ideal Media Today Ltd
Intelligent Communications Ltd
Newscore Media LLC
Omnis Data Ltd
- Lloyd James Media Limited
- UK Changes
- Virgin Media
- Bulb Energy
- ESB Energy
- Octopus Energy
- Utilita Energy Limited
- A1 Comms (phones.co.uk) - offering mobile phone, broadband and digital TV offers.
The Ark (CM) Ltd
Edit. St Ives Group
If you do not wish for your data to be used this way by then please see the section - Your rights & Choices to unsubscribe.
We will use your information for marketing purposes as well as modelling, analysis, segmentation or suppression and any other purpose that enables us to gain understanding on how we can provide a better marketing service for you and our clients.
- to provide you with information about the products and services we offer
- to provide you with a more personalised service
- to conduct market research
- to run prize draws and promotions
- to pass on to selected companies to provide you with other offers and promotions
- to share with selected third parties for marketing communications, market research and to profile and extend their databases by appending additional information to any existing information they may already hold on you as their customer
- to facilitate communication between yourself and others
We use Open Source data to add additional information to our database and enable us to create profiles to create an overview of the areas in which people live and thereby enhance the marketing activity to be more relevant. This is anonymised data.
If you do not wish for your data to be used this way then please see the section - Your rights & Choices to unsubscribe or the specific company concerned.
We are also permitted under the Data Protection Act to share some information with third parties who use such data for non marketing purposes including credit risk management, debt collection, online linkage, profiling, identity verification, enforcement, fraud prevention, returning assets to you and tracing, this would include the data you provide to us today, in the past or at any time in the future.
Profiling enables organisations to better understand who their customers are so they can make their marketing communications more relevant.
We use some of the information you provide to match with our clients data so that they will better understand the characteristics of their customers, such as age, hobbies and interests. This only happens when you are on our database and you are a customer of our client.
We do not give them specific information about you but we will tell them how many of the customers are male/female or live in a certain city.
We also help identify whether or not you have similar attributes to a typical customer of our client so they can target you with offers of goods and services tailored to you.
We will never profile you on the basis of ethnicity, religion, politics or health as these are not valid reasons for which you should be targeted for marketing purposes and nor do we collect this information.
We also do not make automated decisions about you which have a negative impact on your rights.
Marketing Services Providers we share your data with can also use profiling to target you for marketing purposes.
If you do not wish for your data to be used this way then please see the section - Your rights & Choices to unsubscribe.
This is where you have consented to a specific organisation contacting you for specific reasons, using a communication channel or channels which you have agreed to. When we Cloud Digital Communications Ltd contact you we will be doing so for marketing purposes. When we ask you for your consent for another organisation, we will do so by giving you the opportunity to tick a box online or answer a question on the phone to confirm your consent.
You can always change your mind at any time and withdraw your consent for a specific channel or even globally by following this link Click Here
•We obtain consent for our brands to contact you by telephone where your number is registered on the Telephone Preference Service (TPS) or by email and SMS.
•To pass your contact details to named third parties where the Privacy and Electronic Communications Regulation (PECR) applies such as email marketing or where your telephone number is registered with the TPS.
•To pass your contact details to named third parties where your postal address is registered with the Mailing Preference Service (MPS).
•Where our client has specifically asked us to gain your consent to pass on your details.
•All cookies & similar technologies which do not meet the "strictly necessary" exemption under PECR.
GDPR (Recital 47) explicitly recognises the processing of personal data for direct marketing purposes as a legitimate interest.
As a direct marketing business we process personal information for various legitimate business purposes which include some or all of the following:
To enhance our services for the benefit of our customers including verification and validation
To help make the communication more relevant and contextual
To better understand how our customers interact with our services
To provide direct marketing communications which we think will be of interest to you
To determine the effectiveness of our and our clients promotional campaigns
To identify and prevent fraud
These legitimate business purposes relate to the following activities:
Direct Marketing - Postal and telephone marketing by both Cloud Digital Communications Ltd and other third parties, but in either case communications will be in relation to products or services which we believe are of interest to you based upon information which you have provided us.
Profiling - We will profile your information for marketing purposes to help our clients deliver marketing communication that is more relevant to you (for more information, please refer to the profiling section)
ID Protection & Tracing - This is in relation to appropriate agencies which could help protect your identity and prevent fraud.
We process your data in the following ways:
For our own marketing purposes.
To pass on your personal information to our clients for marketing purposes who will then send postal marketing to you, (except where you are registered with the MPS) or contact you by telephone (except where you are registered with the TPS).
Marketing will only ever be from organisations operating within the industry sectors , Charity, Financial, Holidays and Travel, Insurance, Legal, Lifestyle, Media, Motoring, Shopping, Family and Home and Companies.
To call you where your telephone number is not registered on the TPS.
To process your personal information for the purposes of customer analysis, non-automated profiling and direct marketing, to help us with our activities and to provide you with the most relevant information as long as this does not harm any of your rights and interests.
To pass to our clients for use including tracing of individuals, verification and/or validation of the identity of individuals for the purposes of, but not limited to, anti-money laundering regulations, national security, crime prevention and detection, anti-fraud processes, asset recovery and asset reunification. More information on this can be found in the Credit References and other Agencies section.
To determine the effectiveness of our clients promotional campaigns and advertising, and to develop our products, services, systems and relationships with you.
Processing your information to protect you against fraud when using our website, and to ensure our websites and systems are secure.
To pass on your details to companies to help their clients tailor products and services which best suit your needs. They will also use your data for fraud prevention.
For all types of processing, we apply various measures to carefully protect your privacy rights. In considering the most appropriate legal basis, Cloud Digital Communications Ltd conduct Legitimate Interest Assessments which are detailed evaluations of each type of data processing activity to ensure that we have balanced the need of the processing against the rights of the individual to ensure minimal privacy impact.
Your personal information may be processed by staff operating outside of the UK who work for us or for one of our suppliers or third party partners, suppliers or clients.
We work with Data Partners and suppliers such as Call Centres in the UK, EU, USA, Philippines and India, who call you on our behalf to conduct surveys on our behalf.
The Call Centres act as processors under strict instructions from ourselves. We monitor the calls they make to ensure quality is controlled and we inspect their premises and systems to check that security and data protection standards are of the highest quality.
We also send data to data partners and clients who operate overseas, primarily in the United States, Philippines, India and South Africa but under strict contract rules that ensure your personal details are only processed under the same laws that we operate under here in the UK by using one of these safeguards:
Transfer data to a non-EEA country whose data protection laws have been approved by the Europeans Commission as providing adequate protection for data subjects’ rights.
Putting in place a contract with the recipient that means they must protect data to the same standards as the EEA. This is known a Model Contract Clauses.
Transfer data to organisations that are part of EU-US Privacy Shield. This imposes stronger obligations on U.S. companies to protect Europeans’ personal data. The Privacy Shield requires the U.S. to monitor and enforce more robustly, and cooperate more with European Data Protection Authorities.
The law does not put a time limit on the length of time we can hold your personal data, Cloud Digital Communications Ltd will only retain your data for as long as it is required for the purposes for which it was collected for as long as it remains accurate and up-to-date and most importantly, for as long as long as you are happy for us to do so.
You can withdraw your consent globally and also opt out from receiving marketing messages via specific method by registering this with The Preference Centre Click Here.
Your personal information that has been collected will be held by us for a maximum period of twenty years from the most recent date of permission.
We refer to this as activity as engagement or notification recency and our data retention policy considers the purpose, the legal basis under which it is processed and also the most recent engagement. If consent is given again then the period of retention will commence again from that date.
Where we process your data under consent we will stop using it for marketing purposes after five years.
Where we rely on legitimate interests we will continue to process your data for ten years, subject to receiving notification from ourselves that we hold your information.
We will stop using your data for this purpose after ten years.
Tracing and Credit Reference
This purpose plays an important function of protecting individuals, we will retain your data for twenty years. However, we will retain only basic name, date of birth and contact information for this purpose.
In addition, when completing lifestyle questions you may provide us with information such as the make and model of your car or the newspaper you read. Where information such as this has less use over time, it will be removed sooner than the retention periods detailed above.
It is important that the personal data we hold and process is accurate and up-to-date. Therefore, we regularly refresh the database against suppression lists and remove those who no longer wish to be contacted.
We will hold suppression data as long as it is necessary to ensure that we cannot market to you, supply your personal data or receive it into our systems for processing.
You have a number of rights under GDPR
B. Right of access - You have the right to contact us verbally or in writing to request details of the information we hold about you. You can withdraw consent in the following ways:
In writing to: Data Protection Office, The Preference Centre Ltd, 13th Floor, City Tower, Piccadilly Plaza, Manchester, M1 4BT
By email to:
or By telephone on: 0161 513 2343
C. Right of rectification - You have the right to ask us to rectify information that we hold about you if it is inaccurate or incomplete.
D. Right to erasure - This is also known as the right to be forgotten and gives you the right to request your information be removed if there is no compelling reason for its continued processing.
Please note that we keep a list of people who have asked not to be contacted which we use to ensure that you receive no further marketing from ourselves or clients as a result of our activity. Without this list your data could enter our system again from another source and we would have no record of the fact that you asked us not to contact you.
E. Right to restrict processing - This is the alternative to erasure and gives you the right to tell us to stop processing your data but allowing us to keep enough information about you to ensure that your wishes are respected in the future.
F. Right to data portability - This gives you the right to ask a holder of your information to transfer that information to another business. This right would most commonly used if you were switching banks, insurance companies, utilities companies and mobile phone providers.
G. Right to object - You have the right to object to the processing of your data for marketing purposes and profiling for marketing purposes. You also have the right to ask us to cease processing based on our legitimate interests, where there is no overriding justification for the processing of your data. Your rights and freedoms override our interests.
H. Rights related to automated decision making including profiling - We do not use automated decision making processes which would have a potentially damaging effect on you. But if we did you have the right to obtain human intervention, express your point of view, obtain an explanation of the decision and challenge it.
I. Right to withdraw consent at any time where relevant - You have the right to withdraw your consent to the processing of your information at any time and we must provide you with the information you need to do so, at the time we collect your data and each time we contact you.
J. Right to lodge a complaint with a supervisory authority - If we cannot deal with your complaint to your satisfaction you also have the right to complain to a relevant supervisory authority which include:
The Information Commissioners Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF, or call: 0303 123 1113 or online at https://ico.org.uk/concerns/ and The Advertising Standards Authority https://www.asa.org.uk/make-a-complaint.html
You can withdraw your consent globally and also opt out from receiving marketing messages via specific method by registering this with The Preference Centre Click Here.
We have also added some links to industry used suppression files that are free to record your data and this will be used by reputable marketing companies to suppress your details from their marketing activity.
Postal Marketing: you may register your opt out from receiving marketing materials by post using the following link: www.mpsonline.org.uk
Email or SMS messaging can be stopped by hitting the unsubscribe link in the emails sent to you or by replying to SMS messages with the word STOP.
Telephone calls can be prevented by registering your telephone number, mobile or landline with the Telephone Preference Service TPS using this link: www.tpsonline.org.uk
www.youronlinechoices.com is also a site that holds information as to what you can do to enhance your digital communications.