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ProfileTree Web Design and Digital Marketing Limited

PRIVACY POLICY

ProfileTree’s Privacy Policy

Here we list all the steps we take to protect our users’ private data as detailed in this Privacy Policy. As a leading digital marketing agency, we fully respect everyone’s data and want to ensure you are fully aware of how we handle your data. If you want to read our Terms and Conditions, they are available on this link.

1. ABOUT PROFILETREE WEB DESIGN AND DIGITAL MARKETING LIMITED

1.1. We are ProfileTree Web Design and Digital Marketing Limited, a limited liability company registered in Northern Ireland with registered number NI665548 and address, McSweeney Centre, 31 Henry Pl, Belfast BT15 2AY (we, us, our). Our business profile can be found on Google Maps. We have a second office based in Clones, Co. Monaghan, Republic of Ireland.

1.2. We provide various websites as well as a number of social media channels relating to digital marketing, education, food, cars and travel. We offer these agency services to companies in Northern Ireland, Ireland, across the UK, Europe, the USA and the rest of the world. As a global digital marketing agency based in Northern Ireland, we follow Northern Ireland law.

• any reference herein to ProfileTree shall be a reference to all or any such websites and/or social media channels provided by us (but excluding any third-party platforms or content). Our contact details will always be included on any such website or channel.

• Most ProfileTree Web Design and Digital Marketing Limited online assets can be accessed free of charge, though we also provide a number of premium services, including digital marketing services, hosting services and subscriptions to premium content. Any reference to our Premium Services shall be a reference to these paid-for services; and

• any reference to Services shall be a reference to our Premium Services as well as the provision of ProfileTree Web Design and Digital Marketing Limited. Our core agency services can be found via the following links – WordPress HostingVideo Production and Video MarketingContent Marketing ServicesSearch Engine Optimisation or SEOWeb Design and Website DevelopmentDigital StrategyDigital Training and Social Media Marketing.

• ProfileTree LLP was incorporated on 26th August 2011 as a limited liability partnership registered in Northern Ireland with registered number NC000806. In 2019 we started to move the business to an LTD and created the company ProfileTree Web Design and Digital Marketing Limited as the vehicle to take over ProfileTree LLP. This process was completed in 2023 when we transitioned fully to ProfileTree Web Design and Digital Marketing Limited.

We regularly review the Data Protection Commission of Ireland’s updates on safe date transfer requirements. On 28 June 2021, the Commission adopted two adequacy decisions for transfers of personal data to the United Kingdom under the General Data Protection Regulation (GDPR) and the Law Enforcement Directive (LED), respectively The European Commission has carefully analysed the relevant law and practice of the United Kingdom (UK). Based on its findings, the Commission concludes that the United Kingdom ensures an adequate level of protection for personal data transferred from competent authorities in the Union, falling within the scope of Directive (EU) 2016/680, to competent authorities in the United Kingdom falling within the scope of Part 3 of the Data Protection Act 2018 (DPA 2018)8. This Decision has the effect that such transfers may take place without the need to obtain any further authorisation for a period of four years, subject to possible renewal, and without prejudice to the conditions laid down in Article 35 of the Directive (EU) 2016/680. Article 45 – Transfers on the basis of an adequacy decision condition is met for Northern Ireland. Article 46 – Transfers subject to appropriate safeguards; we regularly enter into a legally binding and enforceable instrument between clients and our company to ensure Data Transfers are subject to appropriate safeguards.

2. WHO DOES THIS WEBSITE AND DIGITAL AGENCY HOLD DATA ABOUT?

2.1. The nature of our Services means that we may obtain and use Personal Data (that is, information relating to an individual who can be identified) that we collect about the following groups of individuals (Data Subjects):

(i) Users: that is anyone who visits or accesses ProfileTree;

(ii) Clients: that is any individual or business which enters into a contract with us to receive any Premium Service, including any individuals who we contact on behalf of our Client in connection with such services.

(iii) Prospective Clients: that is, employees, directors or representatives of any businesses which are not yet Clients but which we believe may be interested in becoming Clients.

We will hold Personal Data about the above-listed Data Subjects as a Controller. This means that we make decisions about what data we collect and how it should be used to best serve our purposes. The reason for this notice is so that each Data Subject is clear as to what data we collect about them, what we do with that data, how long we store it and their rights in relation to that data.

2.2. To the extent that we provide hosting services, it is likely that we may also collect and store information belonging to our Clients and that this may include Personal Data relating to third parties (Managed Data). We process any such Managed Data as a Processor, which means that we only use it in accordance with our Client’s instructions. Our terms of processing which set out how we deal with Managed Data will be set out in the agreement we enter into with our Client in respect of such services and are not dealt with here.

3. ABOUT THIS NOTICE

3.1. Under the General Data Protection Regulation (EU) 2016/679 (GDPR) and the Data Protection Act 2018, we are required to provide individuals about whom we hold data as a Controller with certain information about what we are doing with their data. This notice is intended to do just that. We’ve listed the individuals to whom this notice is addressed at paragraph 2.1 above.

3.2. This notice only deals with our use of Personal Data. If you click on any links to third-party sites or products, you should check their privacy notices before disclosing any Personal Data to them.

3.3. We might need to change this privacy notice from time to time. We will publish our privacy notice on each ProfileTree site or channel and do our best to update you directly if we think the changes might affect you. Please keep an eye on our notice before sending us any Personal Data.

3.4. If you have any questions about this notice, feel free to send us an email to support@profiletree.com.

4. WHAT PERSONAL DATA DOES THE WEBSITE AND DIGITAL AGENCY COLLECT, AND WHERE DO WE GET IT FROM?

Users

4.1. We collect Personal Data relating to Users (User Data) in the following ways:

(i) Primarily, we will obtain User Data from users directly if they set up an account to use ProfileTree (User Account) and if they create a public profile for ProfileTree (User Profile). This is likely to be limited to their name, their email address, the town or city in which they live and any user name and strap line they will include in their profile as well as the password they create. It may also include a photograph if the User so wishes.

(ii) We will also collect details of any posts uploaded by a User to ProfileTree and any responses they receive from other Users.

(iii) We may also collect usage data in respect of a User’s use of ProfileTree. This could include location data (such as the region, town or city in which the User lives), information about what a User looked at and links clicked on, as well as IP addresses. We would do this to collect and collate aggregate data for our own business purposes.

(iv) We may also collect usage data (such as IP addresses) to ensure that ProfileTree is being used in accordance with our terms of use.

(v) If a User contacts us directly with a support request or other issue, we may retain details of the request for our records and to make sure that the issue was properly resolved.

(vi) If a User clicks on a link on ProfileTree and consequently purchases any goods or services from a Client, we may receive information from our Client confirming that a sale was made. This is unlikely to include any Personal Data, and where possible, we would request that it doesn’t. Any such information would only be used to assess any payment due between us and our Client and for aggregate statistical purposes.

Client

4.2 We may collect Personal Data relating to contacts within our Client (Client Data) in the following ways:

(i) Primarily, we will obtain Client Data from our Clients when they instruct us who we should contact in connection with our Services. This is likely to include their name and business contact details as well as their role in our client’s business. We will also need to hold information about our Client, which we need to set them up as a Client and avail of our rights and fulfil our obligations under any services agreement we enter into with them. This is likely to include our Clients’ financial data as well as details of any past transactions and payment history with us.

(ii) If our Client contacts us directly with a support request or other issue (whether by email, telephone or letter), we may retain details of the request for our records and to make sure that the issue was properly resolved.

(iii) If our Client signs up to receive our newsletter or receive marketing information from us, we may retain information about marketing preferences and any contact details our Client provides us with.

Prospective Clients of the Web Marketing Agency

4.3 There are a number of ways we might collect Personal Data about contacts for prospective Clients (Prospective Client Data):

(i) If a business contacts us directly (whether by calling us up, sending us an email or if we meet a representative for a business somewhere in person) and the representative asks for information about our Services, we may retain information about that request, including their name, where they work and their business contact details.

(ii) Our marketing team may also carry out its own research using online sources to try to locate businesses and key contacts within those businesses who we think may be interested in hearing about our Services.

(iii) If a representative of a business signs up to receive our newsletter or receive marketing information from us, we may retain information about their marketing preferences and any contact details they provide us with.

Cookies

4.4 In addition to what’s set out above, we may also collect Personal Data from visitors to ProfileTree. We use cookies on all ProfileTree Websites, so if you visit it, we may also collect certain information, including IP addresses, usage data, technical data and other related traffic data. For more information about how we use cookies, have a look at our Cookies Policy which can be accessed here.

5. SPECIAL CATEGORIES OF DATA AND CRIMINAL OFFENCE DATA

5.1 In the UK, some types of Personal Data are afforded special status because they are considered to be more sensitive in nature and could potentially cause more harm to an individual if the data was misused.

• Special Categories of data include details about an individual’s race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about health and genetic and biometric data; and

• Criminal Offence Data means data relating to an individual’s criminal record.

5.2 We do not anticipate that we will collect or store any data relating to our users, Clients or Prospective Clients of this nature,

6. HOW WE USE PERSONAL DATA AND OUR LAWFUL BASES FOR DOING SO

Users

6.1 We may use User Data for the purposes set out below.

  • To enable you to use ProfileTree: This includes enabling you to set up a publically available User Profile; enabling you to post public reviews, read and respond to other reviews and comments and download resources (if agreed). It is necessary for the performance of our contract with you for the provision of our Services to you.
  • To ensure that you are using ProfileTree in accordance with our terms of use and enforce our contractual and legal rights: This means that we may monitor your use of ProfileTree by collecting usage, traffic and location data, and we may transfer this data to our professional advisors if we believe that the usage data suggests you have acted in breach of our terms of use. It is necessary to protect our legitimate interest of protecting our intellectual property rights.
  • For administration and dispute resolution purposes: We may also need to process Personal Data about you to meet our internal administration requirements and, as well as for matters such as dispute resolution. It is necessary to achieve our legitimate interest of protecting our rights as a business.
  • To send marketing communications: From time to time, we might send you an email about events we are running or other products or services which we think might be of interest to you. We will always include an opt-out in any such emails. We will only send you marketing communications if you have expressly consented to it.
  • To facilitate our online marketing strategy: We may collect data about how you use ProfileTree and use that information to make decisions about the type of online advertising to show you when you use ProfileTree. It is necessary to achieve our legitimate interest of promoting our business.
  • To calculate the commission payable by our Clients to us: We may use the information that we receive from our Clients about any services you have purchased from them after clicking on a link on ProfileTree. This is unlikely to include any Personal Data, but if it does, such use would be limited solely and strictly to the extent necessary to achieve our legitimate interest of creating a robust revenue structure.
  • To create aggregate data for analysis purposes: We may collect aggregate data relating to your use of ProfileTree to analyse trends per region and split by other demographic. This data may be sold to third parties or used by us to help us improve our Services. Any such data shall not include data from which an individual can be identified.

Client Data

6.3 We may use Client Data for the purposes set out below.

  • To provide our Clients with services: This includes recording and retaining communications with our Clients about their requirements.
    Necessary for the performance of the contract for the provision of our services or taking steps necessary to enter into a contract/ necessary to achieve our legitimate interest of creating a robust revenue structure.
  • Administration and Dispute Resolution: We may also need to process Personal Data to meet our internal administration requirements to facilitate payments and, as well as for matters such as dispute resolution. It is necessary to achieve our legitimate interest of protecting our rights as a business.
  • Marketing: From time to time we might send you an email about products or services which we think might be of interest to you. We will always include an opt-out in any such emails. It is necessary to achieve our legitimate interest of promoting our business.

Prospective Client Data

6.4 We may use Prospective Client Data for the purposes set out below.

  • To provide you with information about our services: If you have asked us to do so, we may use the details you give us to provide you with a quote for our services. We would usually do this by email.
  • Marketing: We might use the contact details you have provided us with to send you emails about events we are running or information about our Services which we think might be of interest to you. We will always include an opt-out in any such emails. It is necessary to achieve our legitimate interest of promoting our business.

7. DISCLOSURE OF PERSONAL DATA

Data Processors

7.1 We may disclose any Personal Data that we hold to our employees as well as other third parties who we engage to help us provide our Services. For example, we use third parties to provide the following services for the following services:

• Email Provider
• Host Server provider
• Marketing Database Provider
• Project Management Software

A list of our core services collecting data from your use of this website:

Provider – Cloudflare Inc.
Purpose – Traffic optimization and distribution

Personal Data collected – Various types of data as specified in the privacy policy of the service
Description – Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc. The way Cloudflare is integrated means that it filters all the traffic through this Website, i.e., communication between this Website and the User’s browser, while also allowing analytical data from this Website to be collected.

Provider – Google Ireland Limited
Purpose – Analytics

Personal Data collected – Trackers, Usage data and Device information
Description – Google Analytics 4 is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network. In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data centre or server. Users can learn more by consulting Google’s official documentation.

Provider – Google Ireland Limited
Purpose – Tag Management

Personal Data collected – Usage data and Trackers
Description – Google Tag Manager is a tag management service provided by Google Ireland Limited.

Provider – HubSpot, Inc.
Purpose – User database management

Personal Data collected – Various types of data as specified in the privacy policy of the service and Trackers
Description – HubSpot CRM is a User database management service provided by HubSpot, Inc.

Provider – This Website
Purpose – Analytics

Personal Data collected – Trackers and Usage data
Description – Matomo is an analytics software used by this Website to analyze data directly without the help of third parties.

Any such parties contracted by us will be acting as our Processors and will be subject to strict contractual requirements only to use Personal Data in accordance with our privacy notice. If you would like more information about third-party processors used by us, please contact us at: support@profiletree.com.

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