Marketing Policy

Privacy Notice - marketing

Last updated: 23rd May 2018

Who are we?

"We", "our" or "us" means Lhasa Limited. We are a charitable organisation. Our company no. is 1765239 and charity no. is 290866. Our registered office is at Granary Wharf House, 2 Canal Wharf, Holbeck, Leeds, West Yorkshire, LS11 5PS.

What does this privacy notice apply to?

This privacy notice sets out how we use your personal information for marketing purposes, if you have agreed to this, and also tells you what your rights are over your personal information and how to exercise those rights.

This privacy notice answers the following questions – please click on the links below to take you directly to the answers to each question:

  1. How we collect your personal information for marketing?
  2. How we use your personal information for marketing?
  3. What is our legal basis for using your personal information?
  4. How long we will keep your personal information?
  5. Who will we share your personal information with?
  6. Will we transfer your personal information outside the UK/EEA?
  7. What rights you have over your personal information?
  8. How we’ll tell you about changes to this privacy notice?
  9. How you can contact us?

1. How we collect your personal information for marketing?

Information you give us through our website: If you fill in a form or use the live chat function on our website, we will respond to your query and we may also send a follow-up email to you to ask if you are happy for us to send you marketing and which communications you would like to receive.

Information you give us if you are a contact at one of our member organisations: If your organisation becomes a member of Lhasa, we may ask you whether you are happy for us to contact you for marketing and which communications you would like to receive.

Information you give us if you register to attend one of our events or webinars: When you register to attend one of our events or webinars, we have tick boxes on the registration pages so that you can tell us if you are happy for us to contact you for marketing and which communications you would like to receive.

Information you give us when you meet one of our members of staff: If you meet one of our members of staff we may send a follow-up email to you to ask if you are happy for us to send you marketing and which communications you would like to receive.

In each case we will only market to you if you respond to let us know that you are happy for us to send you marketing. If you do not respond, or you respond to say you do not want us to send you marketing, we will not add you to our marketing list and we will not contact you for marketing purposes.

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2. How we use your personal information for marketing?

If you have agreed that we can send you marketing, we will use your personal information to send you marketing. This is typically via email and is about:

  • other Lhasa software that may be of interest to you;
  • Lhasa events, webinars, and projects that you may be interested in participating in;
  • news about Lhasa;
  • relevant publications; and
  • opportunities to complete surveys that we will use for marketing purposes.

We do not use the personal information you give us for marketing for any other purpose.

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3. What is our legal basis for using your personal information?

Under data protection law we must have a legal basis to use your personal information. Where we use your personal information for marketing, we do this on the basis that you have consented to us sending you marketing. You have the right to change your mind about this at any time. There will be unsubscribe links in all the marketing emails that we send you, and you can also contact us at any time to ask us to stop sending you marketing by filling out an unsubscribe request form on the Lhasa Limited website.

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4. How long we will keep your personal information?

Where we have your personal information for marketing, we will contact you every two years to make sure you are still happy to hear from us. If you do not wish to receive marketing from us anymore, or we do not hear back from you, we will remove you from our marketing list. If you are still happy to receive marketing from us, we will keep your personal information for as long as you tell us you are happy with this.

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5. Who will we share your personal information with?

We will only share the personal information that you give us with the following third parties and for the following reasons:

To send you marketing.

We use third party software Dotmailer to facilitate our sending of our marketing messages. We consider that our use of your personal information is in our legitimate interests and is proportionate because we only pass personal information through this software as required to send our marketing messages.

Where your organisation is a member of Lhasa or we have otherwise collected your personal information, for example through our website or at an event.

We will share your personal information with our group company Lhasa Limited Inc. Where your organisation is a Lhasa member based in the USA, this is because our USA based group company is best placed to contact you in respect of matters relating to your organisation’s contract, membership account and financial account and to contact you in relation to the software and services we provide to your organisation. Where your organisation is a Lhasa member not based in the USA, or we have otherwise collected your personal information, for example through our website or at an event, this is because Lhasa Limited Inc. provides us with support in managing all our members’ accounts and prospect data. We consider the use of your personal information is in our legitimate interests and is proportionate because we will only pass on the information you have given to us.

If you have agreed to fill in a survey about us.

We use third party software QuestionPro to administer our surveys. We will pass your personal information through this software so that we can give you access to the survey. We consider it is in our legitimate interests to be able to use reputable third party providers to facilitate us obtaining feedback about our software and our relationships with our members. We consider the use of your personal information is proportionate as we only pass personal information through this software as required for us to carry out the survey.

With organisations who provide support for our internal systems or develop our website.

We use reputable third parties to provide us with support for our internal systems and also to develop and improve our website. We will share your personal information with them to the extent that they need to access our systems and website to be able to provide their services. We consider it is in our legitimate interests to be able to use reputable third party providers to facilitate us having well-functioning IT systems and website, and to fix any issues with our IT systems and website.

With an organisation that we merge with or transfer our business assets to.

In the unlikely event that we sell all or part of our business, or merge with another organisation, we may transfer personal information that we have collected as described in this notice, along with our other business assets, to the organisation that we are selling to or merging with.

With entities, organisations or individuals outside Lhasa for legal reasons.

We will share your personal information with entities, organisations or individuals outside Lhasa where this is strictly necessary to: comply with any law, rule, regulation, legal procedure or governmental request that is applicable to us; obtain legal advice; enforce the terms of our agreements; prevent or detect fraud; otherwise as permitted or required by law.

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6. Will we transfer your personal information outside the UK/EEA?

We store your personal information that we collect for marketing in the United Kingdom or in countries within the European Economic Area. We will only transfer your personal information outside the EEA where we share your data with Lhasa Limited Inc. in the USA, or to pass your personal information through the Dotmailer third party software to facilitate our email marketing

We only transfer your personal information outside the EEA where we have a legal basis for doing so and where we ensure that your personal information is protected to the same standard as it would be protected in the UK.

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7. What rights you have over your personal information?

You have a number of rights over your personal information, which are:

  • the right to make a complaint to the Information Commissioner’s Office (ICO) if you are unhappy about the way your personal information is being used – please refer to the ICO’s website for further information about this (https://ico.org.uk/);
  • the right to ask us what personal information we have about you and to have a copy of your personal information from us;
  • the right to ask us to correct any errors in your personal information;
  • the right to ask us to review and explain our legitimate interests to you;
  • the right to ask us to delete your personal information where: (i) we don’t need your personal information anymore; (ii) you have asked us to review and explain our legitimate interests to you and we don’t actually have a valid legitimate interest to do what we are doing; (iii) our use of your personal information is illegal; (iv) we have to delete your personal information to comply with our legal obligations; and
  • the right to ask us to restrict the use that we are making of your personal information where: (i) you don’t think the personal information we have about you is correct, so that we can check if it is correct; (ii) what we are doing with your personal information is illegal but you would rather we stop using your personal information rather than delete it; (iii) we don’t need your personal information anymore, but you need us to keep it so that you can exercise any legal rights; and (iv) you have asked us to review and explain our legitimate interests to you, so that we can check whether we actually have a valid legitimate interest to do what we are doing.

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8. How we’ll tell you about changes to this privacy notice?

We keep our privacy notice under regular review. Any changes we make to our privacy notice in the future will be posted on this page and if the changes will have an effect on you or the way we use your personal information we will bring them to your attention by email where appropriate (e.g. if we have your email address as a contact at one of our member organisations). Please check back frequently to see any updates or changes to our privacy notice.

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9. How you can contact us?

If you have any questions about this privacy notice or about the ways we use your personal information, please contact us at info@etoxsys.com.

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