- Through your use of our various websites (regardless of whether you visit them using a
computer, mobile phone, tablet, or other Internet-connected device), including when you
access our website(s) through direct links from other webpages;
- Through your use of our mobile application (“App”);
- Through our process of publishing and/or promoting material on our own or on third-party content syndication platforms that you access (for example, articles or blogs written by Sokin’s representatives or employees);
- Through digital advertising platforms (for example, Google Ads and LinkedIn Sponsored Updates);
- Through social media platforms where you access our posts and/or pages on those platforms (for example, on Twitter or LinkedIn); and
- Through our own offline sales and marketing activities (including where we market our products and services to current and prospective business-to-business (‘B2B’) clients and partners, either using third party data sources, or in person and during events hosted or attended by us).
2. The Data Sokin Processes About You
2.1 In the production and performance of our websites and our own marketing activities, we may process personal information about you that has been made available to us by you or by our partners to whom you have made your information available, such as:
- CRM: Customer Relationship Management and data platform
- Marketing Automation and Communication: Using client and prospect data to run personalised email programmes
- Web Analytics: Analysing website performance through traffic statistics
- Social Media Monitoring: Analysing engagement and brand interaction across social media platforms
2.2 The information collected by us or through the third party categories mentioned may be offline and/or online information:
- Offline information about you originates from you yourself (such as when you interact and provide us with your personal information), as well as from our clients, partners, and/or providers who may have a direct relationship with you.
- Online information about you originates from the use of automated technologies (such as cookies and/or similar technologies like pixel tags and device identifiers) that collect information about you automatically. Automated technologies are activated when, for example, you visit or interact with any of our websites, websites that are operated by us or include our cookies, or by opening emails from us. Online information may also originate from information you choose to manually provide, such as when you fill out our online registration forms. Automated technologies may also allow the collection of Technical Data (described below) about the equipment you are using and your browsing activities and patterns.
2.3 Both the offline information and online information that we process can be categorised into various sub-types of data, and could include:
- Identity Data, such as first name, maiden name, last name, username (or similar identifier), marital status, title, date of birth, and gender;
- Contact Data, such as postal address, email address, and telephone number;
- Technical Data, such as your internet protocol (‘IP’) address, log-in data, time zone setting and location, web browser type and version used, web browser plug-in types and versions used, operating system and platform used, and other technology on the devices you use to access websites;
- Usage Data, such as information about how you use websites and their products and services; and
- Marketing and Communications Data, where you have stated that you would like to receive marketing from us and our third parties.
- 2.4 Please be aware that we may collect your personal information by asking you to provide us with information about yourself so that we can register you for certain products and services that you request or about which you request materials. The information you provide us will solely be used to:
- Support and develop your relationship with us;
- Help make our website(s) become easier for you to use; and
- Inform you of services and product updates, new products, and other related information.
Also, please be aware that as a controller for the data that we process per the above, we may process your personal data without your knowledge or consent where this is required or permitted by law. This is, however, always subject to our legal grounds as described below under the Sokin’s Legal Grounds for Processing Your Personal Data subheading under Section 3 (Sokin’s Uses Of Your Personal Data) below.
Please refer to Section 4 (Your Choices Regarding Your Data) below for further details on how to exercise your rights under the GDPR.
3. Sokin’s Uses Of Your Personal Data
3.1 We will only use your personal data as the law allows us to do. Most commonly, we will use your personal data for the purposes specified in this policy and to provide you with information, products, and services. This is usually something that you have requested or for which you’ve signed up. Your personal information may also be collected as necessary and in regard to any legal obligations we may have.
Purposes for Which We May Use Your Personal Data
Sokin processes your data for various purposes, which may include any of the following:
3.2.1 To communicate with you. Where you have made any inquiries and/or requests to us (such as by submitting contact forms on any of our websites or sending us an email on firstname.lastname@example.org ), we may process information about you to communicate with you to best respond to your inquiries and/or requests.
3.2.2 To market our products and services to you. We process personal information about you to help enable us to market (both online and offline) our products and services to you based on your interests. More specifically, we may process information about you:
To register for and/or allow you to subscribe to our special offers, demonstrations of our products and services, or seminars and events;
To sign you up to participate in surveys or even contests that we might provide;
To allow you to download different papers and/or articles that we write, produce, or otherwise make available; and/or
To actually provide you with access to our products, such as our payments platform.
3.2.3 To manage the security of our websites, networks, and systems, as well as to operate our business. We may process usage and systems operations data from our websites in order to better manage our operations, as well as to investigate and help prevent cyber-attacks or potential fraud. We may also process personal information in the operation of our day-to-day and overall business (such as when we conduct audits and investigations); for finance, accounting, archiving, and/or insurance purposes; as well as to help analyse, develop, optimise, or simply improve the use of our websites and products and services.
3.2.4 To comply with applicable laws and regulations.In some cases, we may process personal information as part of our compliance with applicable laws and regulations, such as in responding to a request from a regulator or to defend a legal claim.
3.2.5 In order to best support the above mentioned activities, we will ask you for personal information about you and/or the company for which you work. This allows us to better support and develop your relationship and interactions with Sokin.
3.3 Sokin’s Legal Grounds for Use of Your Personal Data
3.3.1 We may process your personal data based on more than one legal ground, depending on the specific purpose(s) for which we are using your data. You can contact us by emailing us on email@example.com if you would like details about the specific legal ground(s) we are relying on to process your personal data and to find out if more than one legal ground applies.
3.3.2 Our processing of your personal information collected through our website and/or marketing activities are mainly based on the following legal grounds:
Where we specifically and directly collect your information ourselves, such as via our own websites or our direct interaction with you, your consent is obtained by us. We also rely on your consent for the purpose of enabling automated technologies on your browser, in addition to those other uses described above under the Purposes for Which We May Use Your Personal Data subheading above.
Where you communicate with us by making a request or inquiry, we will be relying on legitimate interest in processing your information in order to best respond to your request or inquiry.
We may also process your information for our legitimate interest in analysing, developing, improving, and optimising our websites, products, and services, as well as to maintain the security of our websites, networks, and systems.
Legal and Contractual obligation.
We may need to process your information in order to enter into and perform a contract with you or the company you represent in your interactions with us (such as where you or your employer have engaged in a transactional agreement with us).
3.3.3 You can always withdraw or modify (where applicable) your consent. Please refer to Section 4 (Your Choices Regarding Your Data) below for further details on how to opt out of interest-based data processing that we perform based on your consent.
3.4 Change(s) of Purpose
3.4.1 We will only use your personal data for the purposes for which it was collected. We may reasonably consider that another purpose is compatible with the one for which it was originally collected. If you wish for us to provide you with an explanation as to how our processing for the new purpose is compatible with the original purpose, please contact us at firstname.lastname@example.org. If we would like to use your information for a new purpose, we will obtain your consent accordingly.
4. Your Choices Regarding Your Data
Sokin respects that you have the right to have control over your data, so we provide you with multiple choices for managing that control with us.
4.1 Opt Outs
4.1.1 Marketing opt outs
You can ask us to stop sending you marketing and/or other messages related to our own products and/or services at any time by emailing us on email@example.com and stating clearly that you would like to be opted out from future contact by us in this context.
You can unsubscribe from email marketing by clicking the unsubscribed option on any emails sent by you
4.1.2. Sokin cookies opt outs
Cookies are one of the online world’s primary automated technologies, and are small text files that are downloaded onto your computer and/or other devices you use to browse the internet and visit websites. Cookies allow us to recognise your device and gather some information about your preferences and past actions, which is then stored in connection with your cookie. The cookies and associated information are used to provide you with a more tailored experience on webpages, including remembering your previous activities on the website, providing you with tailored content based on your previous interactions on that website, and remembering your log-in information (where you choose to allow that).
If you want to restrict or block the cookies we use, you can do this through your browser settings.
Microsoft Internet Explorer
4.1.3. Advertising technology industry opt outs
You may also opt out of our processing of your information collected on our websites by using the opt-out tools provided by the following industry groups:
Digital Advertising Alliance (DAA): http://www.aboutads.info/choices/
European Interactive Digital Advertising Alliance (EDAA): http://www.edaa.eu/ and http://www.youronlinechoices.eu/
4.1.4. Mobile opt outs
4.1.5. Please be aware that if you opt out using any of the first three opt-out methods above, you may still temporarily see interest-based advertising on our sites where our advertising campaigns are already underway. You will, however, be opted out of future advertising campaigns when using our sites.
Also, please be aware that the cookie-based opt out tools above (which excludes MAIDs opt outs for mobile devices) only prevent us from using your personal information for interest-based advertising on the browser on which they are installed. As a result, these opt-out methods only function if your browser is set to accept third-party cookies and may not function where cookies are sometimes automatically disabled or removed (such as in certain mobile devices and operating systems). If you delete cookies, change your browser settings, use a different browser or computer, or use another operating system, you will need to opt out again, since we do not use persistent, unique identifiers to revive your previously opted-out profile or deleted cookie.
5. Accessing Information about You
5.1.1. You have the right to request details about the information that we may have collected about you over time. To do so, please contact us via email to firstname.lastname@example.org and stating “Subject Access Request” in the subject line and/or in the email body. Please ensure that you provide us with the correct information about you in the email body so we can identify you in our systems.
5.1.2. When you make a Subject Access Request to Sokin, you are entitled to all the information that we may hold on you. The information that we provide back to you includes:
Opt Out Report: which is a report indicating whether you are listed in out existing opt out list (both for offline and online suppression lists).
Offline Data: which includes offline identifiers (this means personal data such as name, address, email, phone) or attributes (such as demographic data).
Online Data: this will be data such as your mobile ID, Cookies that we have associated with you and so forth.
5.1.3. Please be aware that we may need you to confirm your identity to ensure that we do not provide your information to someone that may not be you. The deadline for making the full response then starts from when you provide the necessary information. We intend to respond to your request within one month. If you have made a number of requests or your request is complex, then we may need extra time to consider your request and they may take up to an extra two months to respond.
5.2. Requesting Information about You to be Rectified
5.2.1. If you feel that we may have processed information about you that is incorrect, or if you wish for us to amend any information about you that may have changed or is out of date in anyway (i.e. you now have a different email address than what you believe we have in our system for you), then please contact us via email to email@example.com and stating “Other Privacy Inquiries or Application of Rights” in the subject line and/or in the email body. Please indicate in the body of the email what information you would like us to correct. When doing this, please state what information we may have in the system for you, and what you would like us to change it to.
5.3. Deleting Information about You
5.3.1. You can request that we delete all personal information that we may have collected about you by contacting us via email to firstname.lastname@example.org and stating “Erasure Request” in the subject line and/or body of the email. Please ensure that you provide us with the accurate email address which the erasure request is linked to in the email body.
5.3.2. Please be aware that Sokin will be required to continue to retain your information in the event that you continue to receive any Sokin products or services.
5.3.3. Please also be aware that Sokin reserves the right to store some information about you in compliance with applicable law (for example, we may retain the information you provide with your request for erasure in order to maintain our suppression lists).
5.4 Sokin’s Disclosures Of Your Personal Data
Sharing within Sokin
5.4.1. Sokin may share your information out of the EEA when sharing data within Sokin as we are a global organisation.
5.4.2. Please note that our employees are authorised to access your personal data only in relation to their role and duties and only where they need to in order to perform their job functions.
5.4.3. We may share your personal information with service providers who provide us with the following functionality:
CRM data platform
Marketing Automation and Engagement platform
Sales Communication platform
Web Analytics platform
5.4.4. Sokin also uses contracts and other service providers to help us deliver services accessed through this site, to deliver content and fulfil requests made on this site. However in these instances, the information that you provide remains the property of Sokin.
5.4.6. We may also be required to disclose personal data to comply with legal obligations (such as subject to a subpoena or other legal processes), in order to protect both your and our rights, and ensure your safety, as also discussed in Clause 3 (Sokin’s Uses Of Your Personal Data), under the heading Purposes for Which We May Use Your Personal Data. Such instances can include situations where we must respond to government requests, investigate fraud, and even respond to public and government authorities outside your country of residence for national security and/or law enforcement purposes.
5.4.7. Sokin requires all third parties to which we distribute your personal data to respect the security of your personal data and to treat it in accordance with the law. We make efforts to ensure that the recipients of your data are reputable entities, including by conducting appropriate checks on them.
6. Sokin’s International Transfers Of Personal Data
6.1. Sokin is a global organisation, which means that in the performance of the above mentioned purposes for which we process your personal information, we may transfer your data outside the European Economic Area (‘EEA’).
6.2. The UK left the EU on 31 January 2020 and entered a transition period, which will end on 31 June 2021, till end of transition period transfers between UK to EEA remain unrestricted. After Transition period, restricted transfers from the UK to other countries, including to the sea, will be subject to transfer rules under the UK regime. These UK transfer rules broadly mirror the EU GDPR rules, but the UK has the independence to keep the framework under review.
6.3. Whenever we transfer your personal data out of the EEA, we require that a degree of protection similar to the protection that we provide ourselves is afforded to your data. We do this by requiring that at least one of the following safeguards is implemented:
6.3.1. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
6.3.2 Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. Should you have any further questions or require further information on the specific mechanism(s) used by us when transferring your personal data out of the EEA, then please contact us via email to email@example.com.
7. Data Security
7.1. Sokin takes protection of your data seriously and have implemented appropriate technical, organisational, and physical measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered, or disclosed. In addition, we limit internal access to your personal data to our employees, agents, contractors, and other third parties who have a legitimate business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
7.2. We have also 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.
8. Data Retention
How Long Sokin Will Use Your Personal Data
8.1. We take various factors into consideration to determine the appropriate retention period for your personal data, including:
- 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;
- whether we can achieve those purposes through other means; and
- the implications of retaining your personal data on our applicable legal, regulatory, tax, accounting, and/or other necessities and obligations.
8.2. Personal information necessary to preserve your opt-out preferences is retained indefinitely, unless you delete it or otherwise prevent its collection as further described in Clause 4 (Your Choices Regarding Your Data) above.
8.3. We will not store your personal data for longer than 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, however, retain your personal data for a longer period as reasonably necessary for us to deal with a complaint or if we reasonably believe that litigation may be likely with respect to our relationship with you or our use or retention of your personal data.
8.4. In some circumstances you can ask us to delete your data despite these retention periods. To find out more, please email us on firstname.lastname@example.org or read more below under Clause 9 (Your Legal Rights).
9. Honouring Your Rights
9.1. The GDPR provides individuals in the EU with certain rights in certain circumstances, such as your right to make a subject access request to receive information about your personal data that we have collected (or may collect) over time. In respect of your rights and privacy, we have created the email address: email@example.com to allow you to easily exercise your rights with us.
No Fee Is Usually Required
9.2. You will not have to pay a fee to access your personal data (or to exercise any of your other rights). However, we are permitted by law and may charge you a reasonable fee if your request is determined to be clearly unfounded, or if you submit repetitive or excessive requests. Alternatively, we are permitted by law to refuse to comply with your request in these circumstances.
What Sokin May Need from You to Act on Your Request
9.3. In order to carry out your requests, we may need to request specific information from you to help us confirm your identity and ensure that your access request is applicable to your own personal data (for both access and to exercise any of your other rights). This is a security measure that we implement to help ensure that your personal data is not disclosed to any other person who has no right to receive it. We may also contact you to ask you for further information related to your request to help speed up our response.
Sokin’s Time Limit to Respond to Your Request
9.4. We try to respond to all legitimate requests within 1 month. It could, however, occasionally take us longer than a month if your request is particularly complex or if you have made a number of requests. In these situations, we will notify you and keep you updated on the status if your request.
10. Sokin Contact Details
10.1. If you have any questions about any of our privacy practices, please contact us or our data protection officer in any of the following ways:
By email to Sokin:
By post to Sokin:
Plata Capital Limited t/a Sokin, 1st Floor 90 Chancery Lane, London, United Kingdom, WC2A 1EU
10.2. You have the right to make a complaint at any time by contacting the Information Commissioner’s Office (‘ICO’), who is the UK supervisory authority for data protection issues (www.ico.org.uk) . We would, however, appreciate the chance to address your concerns directly with you before you approach the ICO and ask that you please contact us first.
1 March 2021, updated and revised to more clearly address your rights and our obligations under GDPR.