Privacy Policy

Welcome to the privacy notice of Silverbullet Data Services PLC. At Silverbullet, privacy is a top priority and we provide the below Privacy Policies to outline our practices and procedures to enable you to make informed decisions about sharing information with us.

Introduction​

Welcome to Silver Bullet Data Services Group’s (SBDSG) privacy policy. This privacy policy applies to the affiliated companies of Silver Bullet Data Services Group incorporated in England and Wales (“Affiliates”), including:

Silver Bullet Data Services Limited

Silver Bullet Media Services Limited

Save where specifically set out in this privacy policy, references to SBDSG apply equally to Affiliates.

SBDSG respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from), when you transact with us, and when we have contact with you, and tell you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

  1. [IMPORTANT INFORMATION AND WHO WE ARE]
  2. [THE DATA WE COLLECT ABOUT YOU]
  3. [HOW IS YOUR PERSONAL DATA COLLECTED?]
  4. [HOW WE USE YOUR PERSONAL DATA]
  5. [DISCLOSURES OF YOUR PERSONAL DATA]
  6. [INTERNATIONAL TRANSFERS]
  7. [DATA SECURITY]
  8. [DATA RETENTION]
  9. [YOUR LEGAL RIGHTS]
  10. [GLOSSARY]

IMPORTANT INFORMATION AND WHO WE ARE:

Purpose of this privacy policy:

This privacy policy aims to give you information on how SBDSG collects and processes your personal data through your use of this website or with other interactions with us, including any data you may provide whether through this website or otherwise when you purchase a product or service OR contact us with comments or enquiries OR if you are a shareholder of SBDSG.

This privacy policy does NOT apply in relation to personal data we process as part of any services provided by any Affiliates, where we will be a data processor rather than a data controller.

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 policy or fair processing policy 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 other notices and privacy policies and is not intended to override them.

Controller:

The Silver Bullet Data Services Group is made up of different legal entities. This privacy policy is issued on behalf of the Silver Bullet Data Services Group so when we mention “SBDSG”, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the Silver Bullet Data Services Group responsible for processing your data. We will let you know which entity will be the controller for your data when you purchase a product or service with us. Silver Bullet is the controller and responsible for this website.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details:

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

Full name of legal entity: Silver Bullet Data Services Group Limited

Email address: data.protection.officer@wearesilverbullet.com

Postal address: Studio 11, Tiger House, Burton St, London, WC1H 9BY

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes:

We keep our privacy policy under regular review. This version was last updated on June 17th 2021.

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.

Third-party links:

This 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 our website, we encourage you to read the privacy policy of every website you visit.

DATA WE COLLECT ABOUT YOU.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

Where you work for a company, business or other organisation, and interact with us whilst representing that organisation, some of the data we collect about you may constitute personal data even if it relates to that organisation. For example, your work email address, and mobile phone number may be your personal data. Where we refer to “you” we also mean your company, business or organisation, as the context permits, although in many of those cases, the information we collect will not be personal data.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • Location Data includes information we can infer from your IP address

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data:

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

HOW IS YOUR PERSONAL DATA COLLECTED?

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

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • apply for our products or services;
  • create an account on our website;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey;
  • attend an event hosted by us or our partners; or
  • give us feedback or contact us.
  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
  • Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

Technical Data from the following parties:

  • analytics providers [such as Google based outside the UK];
  • social media networks [such as LinkedIn based outside the UK]

HOW WE USE YOUR PERSONAL DATA.

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:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message and for certain technical information and cookies, which can be disabled. We also rely upon consent where you have contacted us seeking information or providing comments and feedback, and we respond to such communications. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
BUSINESS ACTIVITIES    
To register you or the organisation you represent as a new client (a) Identity

(b) Contact

Performance of a contract with you.
To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how clients use our products/services)

To enable you to take part in a prize draw, competition or complete a survey (a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how clients use our products/services, to develop them and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how clients use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, client relationships and experiences (a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of clients for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business)
To respond to direct communications from you, for example, giving feedback, seeking information on goods and services, or otherwise enquiring about any aspects of our business (a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

Consent
SBDS SERVICE ACTIVITIES    
To service an advert to you in the course of provision of services to a client. (a) Technical

(b) Location

(a) Consent

(b) Necessary for our legitimate business interests in reporting our service performance to our client

SHAREHOLDER ACTIVITIES    
To provide you with business information, updates and news about the Silver Bullet Data Services Group and to invite you to shareholder events (a) Identity

(b) Contact

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

 

To seek your approval to shareholder resolutions or otherwise provide you with information we are required by law to send to you (a) Identity

(b) Contact

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

Marketing.

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. If you do not wish to receive any marketing materials from us, please contact us.

Promotional offers from us.

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

Third-party marketing.

It is our policy not to share your personal data with any third parties for marketing purposes.

Opting-in and opting-out of marketing communications

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you OR by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

As an additional safeguard against processing data you are unhappy with, we are an approved member of the European Interactive Digital Advertising Alliance (EDAA). You are able to opt-out of all behavioural advertising on Beeswax, our advertising buying platform

Cookie.

In line with common industry practices, Silverbullet utilise cookies and mobile advertising identifiers to identify your internet connected device.

Note: A cookie is a small text file that is stored by your browser when interacting with our services. We assign your browser a pseudonymous identifier using a cookie which helps us to monitor the performance of our services and to ensure the most relevant adverts are delivered to you. It enables us for example, to prevent repeated delivery of the same advert to you beyond the intended number of impressions.

You have a number of controls available to you surrounding our use of cookies by using your browser settings. Please be aware that some settings may degrade your experience accessing online services and websites. We recommend you review and consider your options by visiting https://www.allaboutcookies.org/.

Mobile advertising identifiers fulfil a similar role in the context of mobile apps. On Android this identifier is known as an AAID and on iOS it is known as an IDFA. Your mobile advertiser identifier is generated by your mobile device and made available to the apps you have installed. Where available, this identifier is shared with us by our partners as a pseudonymous unique identifier for your device.

SBDS Group has joined a number of industry schemes including the IAB Transparency & Consent Framework (https://advertisingconsent.eu/) that have been developed to ensure that users are in a position to decide whether and how they want their web browser data used for digital advertising purposes. IAB Gold Standard and JicWebs Certification. Silverbullet’s Vendor Identification number within the transparency and consent framework is ID 927

As a result, Silverbullet will not process personal data unless it can be evidenced that their publisher & advertiser partners have first obtained the users’ permission to do so. This is usually done by means of a pop-up window that enables users to manage their preferences in regard to cookie application and related data processing.

Change of purpose.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

DISCLOSURE OF YOUR PERSONAL DATA.

We may share your personal data with the parties set out below for the purposes set out in the table [Purposes for which we will use your personal data] above.

  • Internal Third Parties as set out in the [Glossary].
  • External Third Parties as set out in the [Glossary].
  • Specific third parties who support the delivery of our services and/or who provide functionality and support in our day-to-day business activities. For further details on which third party providers we use, please contact us directly.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

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.

INTERNATIONAL TRANSFERS.

We share your personal data within the Silver Bullet Data Services Group. This will involve transferring your data outside the UK.

We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. We do this through a contractual agreement, which gives us legal remedies if they do not.

Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

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

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data or where we have been able to secure appropriate contractual controls over the way the personal data is processed; or

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

DATA SECURITY.

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.

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.

DATA RETENTION.

How long will you use my personal data for?

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 or reporting requirements. 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 to our relationship with you.

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, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for six years after they cease being clients for [tax] purposes.]

In some circumstances you can ask us to delete your data: see [your legal rights] below for further information.

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.

YOUR LEGAL RIGHTS.

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:

  • [Request access to your personal data].
  • [Request correction of your personal data].
  • [Request erasure 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].

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

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 could refuse to comply with your request in these circumstances.

What we may need from you

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.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could 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.

GLOSSARY.

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

Other companies in the Silver Bullet Data Services Group acting as joint controllers or processors and provide IT and system administration services and undertake leadership reporting.

External Third Parties

  • Service providers acting as processors who provide IT and system administration services.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.

 

YOUR LEGAL RIGHTS

You have the right to:

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.

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.

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 local 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.

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.

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.

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.

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. 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.