Privacy Notice

PRIVACY NOTICE

Version 2.0

Last updated: 1 March 2023

Torpedo Group is a UK-based marketing agency delivering marketing, creative and digital solutions to drive business success. We are committed to protecting and respecting any personal information you share with us.

This Notice describes the types of personal information we collect from you when you work with us, use our website, interact with our digital platforms, when we meet you and when you contact us. It explains how your personal information is used by us, when we share it with others and your choices about its use.

Where this statement refers to “we”, “our” or “us” below, unless it mentions otherwise, we’re referring to Torpedo Group.

Our registered address is, The Long Barn, Worton Park, Cassington, Oxon, OX29 4SX, United Kingdom, with company registration number: 4889983.

We may update this statement from time to time, so you may wish to check this Notice occasionally. If any significant changes are made to the way in which we handle and use your personal information we will endeavour to notify you directly.

HOW TO CONTACT US

Please direct any queries about this Notice or about the way we process your personal information to our Data Protection Champion using the postal address above or by emailing us at

dataprotection@torpedogroup.com. If you would prefer to speak to us by phone, please call +44 (0)1865 733710.

HOW WE COLLECT YOUR PERSONAL INFORMATION

We may collect information about you whenever you engage and interact with us, whether through our website www.torpedogroup.com (“our website”), over the telephone, face to face, email, social media or other touch points.

We may also obtain information about you when you contact us, register for events, if you complete any of our surveys conducted for research purposes or if you apply for a job.

The personal information we may collect routinely includes the following:

  • Full name
  • Job title
  • Email address
  • Postal addres
  • Business telephone number
  • Mobile number
  • Social media handles

Where we believe you are likely to be interested in our services, we may also obtain your name and business contact details from publicly available sources, (for example, information you have allowed to be shared as part of your public profile).

We will also handle personal information about you if you include personal details within correspondence you send to us.

In providing our services we do not routinely handle any Special Category Data, and our services are not aimed at children.

If you are applying for a job with Torpedo, you should reference our Applicant Privacy Notice (available via our website or on request). We also have a specific privacy notice for our employees.

Our use of cookies and similar technologies

We may use strictly necessary cookies to enable our website to work (these cannot be switched off); functional cookies to enhance your experience; targeting cookies to build a profile of your interests and show you relevant content and adverts; and performance cookies to better understand how people browse our website, improve its performance and provide you with interesting and useful content. These cookies may be set by us or third parties whose services we use. Cookie settings can be reviewed and amended via our Cookie Preference Center.

We may collect information about you such as your IP address, the internet browser and device you are using and details of pages you visit and interact with. Some details we collect, for example website analytics, do not identify you personally.

HOW WE USE YOUR PERSONAL INFORMATION

We endeavour to only handle the personal information necessary for our business operations. Outlined below are the ways in which we use your personal information and details of our lawful basis for processing under UK GDPR.

To send you marketing communications

We want to keep in touch with you to provide information about our services and promise we will never sell your information to other organisations for their own marketing purposes.

We rely on our legitimate interests to send you marketing communications in a business context. We will always give you the option not to receive marketing communications from us in future.

We include tracking pixels or web beacons in our email newsletters so we can track how many people open our emails and click to view certain pages on our website. They help us to understand the effectiveness of our email communications.

We may contact you with targeted advertising delivered online through social media and platforms operated by other companies or use your personal information to tailor marketing to improve its relevance to you, unless you object.

You can stop receiving marketing from us at any time, by using the unsubscribe mechanism on our emails or by contacting us at dataprotection@torpedogroup.com. If you’d prefer to speak to us, please call +44 (0)1865 733710.

To provide our services

We will handle your personal information where we supply to you, have supplied to you or are in discussions about supplying any of our services, or where we have arranged for the supply of another company’s products or services to you.

We will use this information in connection with providing our services. This will routinely include names and business contact information. We process this personal data under the lawful basis of performance of a contract, or necessary for taking steps before entering into a contract.

Where we have a legal obligation

It may be necessary for us to process your personal information to comply with legal obligations. For example, for taxation purposes, fulfilling employment law requirements or other statutory regulations.

Where we have a legitimate interest

We will use and process your personal information where it is necessary for us to pursue our legitimate interests as a business. Where we rely on legitimate interests, we balance our interests with yours and make sure your privacy rights and freedoms are protected.

We rely on our legitimate interests for the following purposes:

  • to conduct market analysis and research (including contacting you with surveys) so we can better understand your needs and provide tailored and bespoke offers and services that we think you will be interested in
  • for service and product development purposes (for example to improve our services, offering and performance)
  • to administer competitions and promotions that you enter with us from time to time and to distribute prizes
  • to analyse, evaluate and improve our services so that your engagement with us is more useful and enjoyable
  • to correspond or communicate with you, where not strictly necessary as part of a contract
  • to verify the accuracy of data we hold about you
  • for network and information security
  • for prevention of fraud and other criminal activities
  • for the management of queries, complaints, or claims
  • for the establishment and defence of our legal rights
  • to inform you of updates to our terms and conditions and policies

In exceptional circumstances we may handle your personal information for reasons of public interests or to protect your vital interests.

YOUR RIGHTS

In addition to your right to not receive marketing (please see above ‘To send you marketing communications’), you have other privacy rights under data protection law. To fulfil these rights, we may need to ask you to provide proof of your identity. We will acknowledge any request received and provide further information, as necessary. Your rights are:

  • Accessing your personal information You have the right to ask for a copy of your ‘personal data’ (as defined under UK GDPR) and details of the purpose(s) we are using it for.
  • Correcting and updating your personal informationYou have the right to request that we amend any personal data which is incorrect or requires updating.
  • Objecting to our use of your personal informationIn certain circumstances you have the right to object to our use of your personal information. For example, when we rely on legitimate interests for processing your personal data, you may object to these purposes. Any objection received will be assessed and handled on a case-by-case basis.
  • Erasing your personal information or restricting its useYou can ask for your personal information to be removed from our systems. This is not an automatic right and there may be circumstances in which we can justifiably deny your request.

    You may also ask us to restrict our use of your personal information. For example, where you believe it is unlawful for us to do so, you have objected to its use and our investigation is pending, or you require us to keep it in connection with legal proceedings.

  • Transferring your personal information in a structured data file (“data portability”)In specific circumstances you may ask us to provide you, or another organisation, with a copy of your personal information in a structured file.

If you wish to exercise any of the above rights, please contact our Data Protection Champion

Email: dataprotection@torpedogroup.com.

Telephone: +44 (0)1865 733710

Address: Torpedo Group, The Long Barn, Worton Park, Cassington, Oxon, OX29 4SX

We make every effort to fully respond to any queries or specific requests, and please let us know if you feel we have not responded sufficiently.

If you are not satisfied with the way in which we have handled your request, you have the right to complain to the Information Commissioner’s Office (ICO) if you are concerned about the way we have processed your personal information. Please visit the ICO’s website for further details.

OTHERS WHO MAY RECEIVE OR HAVE ACCESS TO YOUR PERSONAL INFORMATION

Our suppliers and service providers

We will share your information (or give access to it), where necessary with our service providers, agents, subcontractors and other organisations, who act on our behalf to provide our services.

Such organisations may include cloud service providers (such as hosting and email providers), advertising media companies, photographers, printers, solicitors, accountants, advisors and administrative services.

When we use service providers, we limit the personal information shared to what is necessary for them to provide their service. We have agreements in place with our service providers requiring them to keep your information secure and not to use it other than in accordance with our specific instructions.

Other ways we may share your personal information

We may transfer your personal information to another organisation as part of a sale of some or all of our business and assets or as part of any business restructuring or reorganisation.

We may also disclose your personal information if we are under a duty to do so in order to comply with any legal obligation, to detect or report a crime, to enforce or apply the terms of our contracts or to protect the rights, property or safety of our visitors and customers.

We will always take steps with the aim of ensuring that your privacy rights continue to be protected.

WHERE WE STORE YOUR PERSONAL INFORMATION

All information you provide to us is stored on our secure servers which are located in the UK. If at any time we transfer your personal information to, or store it in, countries located outside of the UK (for example, if our hosting services provider changes) we will endeavour, to make sure appropriate safeguards are in place for that transfer and storage as necessary, and if required, under applicable law.

Where we use service providers based outside the UK we endeavour to make sure this is appropriately covered by appropriate safeguards under UK data protection law.

HOW LONG WE KEEP YOUR PERSONAL INFORMATION FOR

The length of time we keep your personal information for is determined by a number of factors including the purpose for which we use that information, our business needs and in some cases our obligations under other laws.

We take necessary steps and endeavour to only keep your personal information for as long as is necessary for the purpose(s) we are handling it.

If you would like more information concerning our retention periods, please email dataprotection@torpedogroup.com. If you’d prefer to speak to us, please call +44 (0)1865 733710.

OUR WEBSITE & LINKS TO OTHER SITES

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information when and if transmitted to our website and, accordingly, any transmission is at your own risk. Once we have received your personal information, we put in place reasonable and appropriate controls to ensure that it remains secure against accidental or unlawful destruction, loss, alteration, or unauthorised access.

Our website may contain links to other websites run by other organisations. This Notice does not apply to those other websites‚ so we encourage you to read their Privacy Notices. We cannot be responsible for the privacy policies and practices of other websites even if you access them using links that we provide. In addition, if you linked to our website from a third party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party website and recommend that you check the Privacy Notice of that third party website.