Privacy Policy

We are Gather Content Limited. We are a company incorporated in Scotland with company number SC400199. Our registered office is at Bishop’s Court, 29 Albyn Place, Aberdeen, AB10 1YL and our main trading address is at GatherContent, Mocatta House, Trafalgar Place, Brighton, BN1 4DU, United Kingdom.

We trade under the name GatherContent. When we refer to this trading name, or “we”, “us” or “our“ in this policy, we are referring to Gather Content Limited. We are the controller and responsible for your personal data.

Our service helps you to improve your content operations process. We help you to organise, structure and manage the production of resilient content, at scale and with confidence.

This privacy policy aims to give you information on how we collect and process your personal data when you use our website or service.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy notice 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 using your data. This privacy policy supplements the other notices and is not intended to override them.

Our website 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. We do not control these third-party websites and are not responsible for their privacy statements. When you leave one of our websites, we encourage you to read the privacy notice of every website you visit.

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your personal data by filling in forms or by corresponding with us in person, by email, by conference call or otherwise. This includes personal data you provide when signing up to our service and when you request marketing communications to be sent to you, or opt-in to attend a webinar or download an e-book.

• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources, for example, if you sign-up to our service via a social media platform such as Facebook.

We may collect and process the following data about you:

• Sign-up Data. This includes your name, email address and any other information provided at the time of registering to use our site or subscribing to our service.
• Correspondence Data. If you contact us, we may keep a record of that correspondence.
• Marketing and Communications Data. This includes name, company name, email address, preferences in relation to receiving marketing materials from us.
• Survey Data. We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
• Transaction Data. Details of transactions you carry out through our site and of the fulfilment of your orders.
• Marketing Analytics. Details of your visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
• Payment Confirmation Data. Where you place an order with us or otherwise purchase our services, confirmation of your payment (but we shall not hold your credit card details as we use a third party payment service provider).
• IP Address Data. We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.

What are cookies?

Our website uses certain cookies. A cookie is a small file of letters and numbers that we put on your computer if you agree. These cookies allow us to distinguish you from other users of our website, which helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

What cookies do we use?

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.
• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

You can find more information about the individual cookies we use and the purposes for which we use them by contacting support@gathercontent.com.

Cookie Declaration

Important information about cookies

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

How do I change my cookie settings?

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

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.

To find out how to manage cookies on popular browsers:

• Google Chrome
• Microsoft Edge
• Mozilla Firefox
• Microsoft Internet Explorer
• Opera
• Apple Safari

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

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances, but for more information about the types of lawful basis that we will rely on to process your data, please click here.

We use information held about you:

• To ensure that content from our site is presented in the most effective manner for you and for your computer.
• To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes.
• To carry out our obligations arising from any contracts entered into between you and us.
• To allow you to participate in interactive features of our service, when you choose to do so.
• To notify you about changes to our service.
• To process your payment card details in order to complete any purchase that you make through our site.

If you are an existing customer, we will only contact you by electronic means (e-mail) with information about goods and services similar to those which were the subject of a previous sale to you.

If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this.

If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please get in touch with support@gathercontent.com.

We may have to share your personal information with the following third parties:

• External service providers acting as processors who provide the following services:
• Web hosting;
• Metrics and analytics;
• Customer relationship management;
• Payment processing;
• Billing management; and
• Net promotion services;
• Advertising and marketing services.

Please note this includes the international service providers listed below in International transfers.

• Professional advisers, including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based who require reporting of processing activities in certain circumstances. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
• If Gather Content Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

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

If we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• The country has been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• If we use certain service providers based outwith the EEA, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
• If we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
• In any other case, we will obtain your explicit consent before any transfer takes place.

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

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

All information you provide to us is stored on secure servers. Any payment transactions will be encrypted using SSL technology and using trusted third parties. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, 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, and the applicable legal requirements.

We normally delete personal identifiable information we hold on you within 12 months of you unsubscribing but in some circumstances you can ask us to delete your data sooner: see Deleting personal data below for further information.

Where we anonymise your personal data (i.e. so that it can no longer be associated with you) for further research or statistical purposes, then we may use this information indefinitely without further notice to you.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

• Access to your information
• Request correction of your personal data
• Request deletion of your personal data
• Object to processing of your personal data
• Request restriction of processing your personal data
• Request transfer of your personal data
• Right to withdraw consent
• Right to review by an independent authority

If you wish to exercise any of the rights set out above, please Contact us. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

You have the right to ask for a copy of the information which we hold on you (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.

You have the right to request that we correct personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold corrected, though we may need to verify the accuracy of the new data that you provide to us.

You may ask us to delete or remove personal data where there is no good reason for us continuing to process it. This is more commonly known as the ‘right to be forgotten’. 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 local law.

Please note, however, that we may not always be able to comply with your request to delete or remove personal data for specific legal reasons which will be notified to you, if applicable, at the time of your request.

You have the right to stop us processing your personal data for direct marketing purposes. We will always inform you if we intend to use your personal data for such purposes, or if we intend to disclose your information to any third party for such purposes. You can also exercise the right at any time by contacting us at support@gathercontent.com

You may also object to us processing 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. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

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; or
• you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

In certain circumstances, you may 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.

Please 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.

Where we are relying on consent to process your personal data you can withdraw your consent at any time. Please note that this will not affect the lawfulness of any processing carried out before you withdraw your consent.

You will always have the right to lodge a complaint with a supervisory body. The relevant authority in the UK is the Information Commissioner’s Office. If you do have a complaint, we would appreciate the chance to deal with your concerns before you approach the ICO, so please do Contact us in the first instance if possible.

This version was last updated on 23rd May 2018.

Historic version of this policy can be obtained by contacting us (please see Contact us).

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

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to privacy@gathercontent.com.