Privacy policy

1.    GENERAL

1.1      Codilink respects the privacy rights of all users of our website, our services, and the promotions run via our services. This statement provides information about how your information is stored and used, and covers three types of users:

(a)  Users who are members of the general public who visit the publically accessible website at www.footfall123.com, and who interact with the website in any way, including but not limited to entering contact details in sign up forms, using the live chat functionality, expressing interest in Codilink services by selecting ‘like’, ‘follow’ or ‘+1’ or similar service. (Public Users)

(b)  Users who are customers, or prospective customers, of Codilink services who have login credentials to access the platform on free or paid accounts on any Footfall123 or Social Rocket branded account. (Service Users)

(c)  Users who are members of the general public who interact with Codilink services via promotions and communications on Codilink platforms, including but not limited to information entered into the Footfall123 Toolbox (Footfall123) sign up forms, or  Footfall123 Facebook marketing app (Social Rocket). (Offer Users)

1.2      Please read this statement and the Terms carefully before you start to use the Service.  If you do not agree to the Terms, do not use the Service.

1.3      Codilink may revise this statement and the Terms at any time by amending the page at www.footfall123.com/terms-of-use/en and www.footfall123.com/privacy. You are expected to check this page from time to time to take notice of such changes, as they are binding on you.

1.4      The Services are owned and provided by Codilink UK Ltd t/a Footfall123, River House, 143-145 Farringdon Rd, London EC1R 3AB (“Codilink”, the Client and Codilink together being the “Parties”).

1.    COLLECTION AND USE OF PERSONAL DATA – ALL USERS

Codilink may collect and process personal data as follows:

1.1   Cookies and Web beacons. Codilink may store "cookies" on the computer of all users. Cookies are small data files that many internet sites automatically download to a user's hard disk. They are primarily used in helping web sites recognise a user that has visited the web site previously. They can store account and password information. Most web browsers automatically accept cookies. The Services may use cookies so that Codilink can better service your return to the Services. You do not have to accept cookies, and you should read the information that came with your browser software to see how you can turn off the automatic download feature, should you so wish. Alternatively, you can refer to www.allaboutcookies.org for more information. With those cookies, Codilink may be aware of and collect information concerning when you use the Services, your browser type and version, your operating system and platform and other similar information. Codilink may also use electronic images known as Web beacons. With Web beacons, Codilink can determine when you open email it sends you, and collect other data relating to your use of the Services.

1.2   Tracking Emails. When Codilink sends emails to users it may sometimes track who has opened (or not opened) the emails or clicked on hyperlinks. Codilink does this to measure the performance of campaigns, and to improve its offerings to specific customer groups.

2.    COLLECTION AND USE OF PERSONAL DATA – Service users

In addition to the collection and use of personal data as detailed in 2.1 to 2.3, Codilink may collect and process personal data as follows:

Access to the Services.  Access to the Services is restricted to service users only, and Codilink will need to collect certain personal data about you in order to register you as an authorised user, grant access to the Services, collect payment and to provide the Services.  This may include IP address, name, physical address, email address, phone number, mobile phone number, credit card information, company details and registration number, and other information such as gender, occupation and other demographic information. Codilink may also use personal data to enable it to deal with any queries that you have about the Services and to notify you of any changes to the Services.

2.1   Distribution lists. When a service user uploads a distribution list using the Services, Codilink may have access to the data on your list for the purpose of sending out communications to your customers on your behalf as part of the Services.

2.2   Monitoring compliance with the Terms of Use.  Codilink may sometimes review the content of campaigns using the Services to verify compliance with the Terms of Use. In this regard, Codilink uses software with algorithms to detect any failure to comply with the Terms of Use.  For example, Codilink may check that the email address of an individual who opts out of receiving emails has been removed from distribution lists.

2.3   Supporting and improving the Services.  In order to provide benchmarking and other comparison information regarding, for example, the relative success of different campaigns using the Services by companies in the same or different industries, Codilink may aggregate and analyse data relating to your use of the Services and will only provide this data to third parties in anonymised form.

2.4   Other Features and services. From time to time Codilink may contact you with information about new features for the Services or other services offered by Codilink which Codilink considers may be of interest to you.

3.    COLLECTION AND USE OF PERSONAL DATA – offer users

In addition to the collection and use of personal data as detailed in 2.1 to 3.5, Codilink may collect and process personal data as follows:

3.1   Information gathered from Sign Up forms and Social Media. In the course of using Services provided by Codilink, Codilink may receive information that may include, but is not limited to: Any information entered in a sign up form, your Social Media profile, and any associated email address, information posted on Social Media profiles, such as likes, friends, follows, but only ever to the extent that you make them publically available or that you supply the information as part of a response to a Social Media promotion from a Service User’s campaign.

3.2   Offer distribution.  Codilink will use information provided by you via our services to provide you with offers generated by Service Users. By using these services you hereby acknowledge and agree that Codilink will receive, use, store and process your information.

4.    DISCLOSURE OF PERSONAL DATA – ALl users

Codilink may disclose your personal data as follows:

4.1   Disclosure to affiliates.  Codilink may disclose your personal data to any of any company or other business entity Controlled by, Controlling, or under the common Control of Codilink (where “Control” means the direct or indirect power to direct or cause the direction of the management and policies of a company or other business entity, whether through ownership of fifty percent (50%) or more of the voting interest, by contract, or otherwise (and “Controlled” and “Controlling” shall be construed accordingly).

4.2   Disclosure to third parties.  Codilink may disclose your personal data to third parties:

(a)  That are specifically engaged by Codilink to provide services to it, in which case Codilink will require those parties to keep that information confidential and secure and to use it solely for the purpose of providing the specified servicess to Codilink.

(b)  If Codilink or substantially all of its assets are acquired by a third party, in which case personal data held on the Services will be one of the transferred assets.

(c)  If Codilink is under a duty to disclose or share your personal data in order to comply with a court order or other legal or regulatory requirement.

4.3      Transfers outside the EEA.  The personal data that Codilink collects from or about you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA").  It may also be processed by personnel operating outside the EEA who work for Codilink or for one of its suppliers.  You should be aware that in territories outside the EEA, laws and practices relating to the protection of personal data are likely to be different and in some cases may be weaker than those within the EEA.

5.    DISCLOSURE OF PERSONAL DATA – Offer users

In addition to the disclosure of personal data as detailed in 4.1 to 4.3, Codilink may disclose your personal data as follows:

5.1   Sharing your data with Service Users providing offers. If you are an Offer User you hereby accept and acknowledge that any personal data gathered by Codilink in connection with a marketing campaign of any Service User will be received, used, stored and processed by the relevant Service User as well as Codilink. You are hereby informed that it is your responsibility to review and consent to each Services Users' privacy policies and those of the applicable Social Media platform prior to participating in any marketing campaign offered by a Service User or offered on any Social Media Platform.

5.2   New Offers and Services. From time to time Codilink may contact you with information about new offers from Codilink, Codilink’s partners, Service Users or third parties which Codilink feels may be of interest to you.

6.    Queries

If you have any queries about this Privacy Policy, please email us at dataprotection@footfall123.com or write to us at:

 

Data Protection Co-ordinator

Codilink UK Limited

River House, 143-145 Farringdon Road

London EC1R 3AB