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Webeo privacy statement – marketing and sales

The Webeo product

The Webeo product is a B2B sales and marketing enablement tool. It is SaaS (Software as a Service). We specialize in tailor made website personalization for businesses of all industries and sizes. Webeo allows businesses to personalize their website against a number of variables, enabling them to deliver a targeted, rich, specifically tailored experience for their website visitors. We personalize against: company, industry, employee band and turnover.

Webeo works on the basis of reverse business IP tracking. A small tracking code is placed on a business’ website(s) which then enables them to identify the business IP addresses of their website visitors. Webeo matches the identified business IP address to a wholly owned global database of businesses and business information. It then delivers a pre-designed personalization specific to that vertical if one has been created.

The Webeo software is almost entirely focused on leveraging business-related information to effectively match a business IP address with wider business data to provide valuable business-related visitor information to our customers. Webeo does not identify any personal IP addresses, mobile devices or any other data than that associated with the business.

Business-related data is not applicable under GDPR – which has the intention of protecting personal data. Therefore, the majority of the Webeo solution and its features are not relevant to GDPR.

The purpose of this statement is to provide information regarding how and why Webeo collect, process and store data personal data, as well as providing the appropriate contact information should you wish to request the information we hold about you, withdraw from processing or request deletion of any data we hold about you.

Under the EU General Data Protection Regulation (GDPR) there are six lawful bases for processing personal data. These are detailed as follows:

Consent

The individual has given clear consent for you to process their personal data for a specific purpose

Contract

The processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract

Legal obligation

The processing is necessary for you to comply with the law (not including contractual obligations)

Vital interests

The processing is necessary to protect someone’s life

Public task

The processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law

Legitimate interests

The processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests. (This cannot apply if you are a public authority processing data to perform your official tasks.)

Further information regarding the lawful basis for processing personal data can be found at ico.org.uk

Webeo marketing and sales data

As an organization that processes business related data, Webeo has assessed all six grounds for lawful processing of personal data and has selected ‘Legitimate interests’ as the most suitable lawful ground for the processing of data for the purposes of Webeo marketing and sales.

Webeo collects, processes and stores data relating to businesses and decision makers. We believe that the individuals that we process the data of, are likely to have an interest in the Webeo product. Deemed as ‘Legitimate interest’ this is based upon specific criteria including the business industry sector, size of organization as well as the individual’s job function within the organization. Our typical segmentation includes those within marketing, sales, business development, MD and owner related job functions, although this list is not exhaustive and other variables may apply.

We will only ever collect, process and store the essential information required for making contact with the data subjects within a business environment. The personal data we collect is limited to first name, last name, email address, social profiles (limited to LinkedIn) as well as business IP address. Other business-related data may also be processed including business name, job function, turnover and business address, however we will never collect further personal data such as those classed under ‘Sensitive personal data’.

The data collected will be used to communicate marketing and sales messages relating to the Webeo product, based upon the job function held by the data subject. Webeo specifically only sends messages to those we believe are likely to be interested in the Webeo product based upon the organization they are employed by and based upon their job function within that organization. Messages from Webeo could be delivered via email, social media, via telephone or any other business to business (B2B) marketing methods that may be relevant.

When you send Webeo an inquiry or booking form via our website or one of our micro sites you will be asked to provide your contact details. We will use the data you provide to process your request and may use it to inform you by email, telephone or mail about other Webeo products and services that we feel may be of interest to you, it is deemed that as you have visited the Webeo website and provided us with your contact information that you are legitimately interested in our products and services. You have the right to object from any method of correspondence at any time, following the unsubscribe instructions on an email, by informing the telephone operator or by contacting us via any of the methods below.

How we procure data

At Webeo we procure data in a variety of ways, collected in line with the lawful basis of ‘Legitimate interests’. If you have received correspondence from us, we will have procured your data in one of the following ways:

You have requested information from Webeo on a previous occasion
Someone has sent us your e-mail address requesting information about our articles and/or services be sent to you
You or someone else has expressly shared your contact details with us for the purpose of receiving information now and/or in the future
We have previously met at an event and your business card or contact details were handed to us willingly

You or a business colleague has visited our website and we believe that there is a genuine legitimate interest in our services

You have previously connected with a member of our team via the LinkedIn and discussed our services
A member of our team has found your business and your contact details online, believing that your business would genuinely be interested in the Webeo product, based upon your job function aligning with our typical customer profiles they have made contact to introduce you to our product.

You or someone else has expressly shared your contact details with our sister company and your data has been shared with us as we believe you may hold a legitimate interest in our product

Your data has been purchased by a registered third-party data supplier, which will have been segmented by industry, organization size and job function based upon our typical customer profiles. (Due diligence checks around GDPR compliance will have been conducted accordingly).

Legitimate interest assessment (LIA)

Webeo has carried out a legitimate interest assessment (LIA) as advised by the ICO. Based upon that assessment it is deemed that the rights and freedoms of the data subjects would not be overridden in our correspondence regarding Webeo and that in no way would a data subject be caused harm by our correspondence. Based upon our segmentation by organization and by specific job function, coupled with our processing of personal data within the context of a business environment, we believe that any individual that receives correspondence from Webeo in a direct marketing or sales capacity, could be legitimately interested in the Webeo solution. It is also deemed that direct marketing and sales is necessary in the context of promoting Webeo to professionals in business in order to increase awareness of our SaaS solution in the marketplace.

Per the ICO guidance, Webeo can confirm:

We have checked that legitimate interests is the most appropriate basis

We understand our responsibility to protect the individual’s interests

We have conducted a legitimate interests assessment and data protection impact assessment and kept a record of these, to ensure that we can justify our decision and show that we have identified the relevant legitimate interests and considered the potential impact on all data subjects.

We have checked that the processing is necessary and there is no less intrusive way to achieve the same result

We have done a balancing test, and are confident that the individual’s interests do not override those legitimate interests

We only use individuals’ data in ways they would reasonably expect

We are not using people’s data in ways they would find intrusive or which could cause them harm

We do not process the data of children

We have considered safeguards to reduce the impact where possible

We will always ensure there is an opt-out / ability to object

Our LIA did not identify a significant privacy impact

We keep our LIA under review every six months, and will repeat it if circumstances change

We include information about our legitimate interests in our privacy notice

Webeo has an in-house data verification team, who are responsible for ensuring the validity and quality of the data contained within the Webeo CRM system ‘Cyclone’. The team continually cleanse the data held within the CRM system, completing a full cleanse cycle at least once every 12 months. Any records found to be out of date are placed into a cleanse/ deletion queue which is securely purged four times in a 12-month period.

Data storage and retention

The data held within the Webeo CRM system is processed and stored in the UK within a secure environment.

Webeo has a continual cycle of cleansing and refreshing data contained with our CRM system, all data is verified at least once in a 12-month cycle. Any invalid records are placed into a deletion queue, which is then securely purged four times in a 12-month period.

Request to object

In all correspondence with you we will give you the right to object from receiving further correspondence from Webeo. On any emails you receive from Webeo there will be the option to ‘unsubscribe’ from receiving any further email correspondence. If you receive a telephone call from us, you have the right to request not to receive any further calls. Webeo has a companywide CRM system, your request to object will be logged within our CRM system to ensure that you do not receive any further communication.

Should you wish to object to receiving communication from Webeo, you can do so in a variety of ways:

Please follow the ‘unsubscribe’ instructions at the bottom of every email

If you have received a call, please tell the representative that you do not wish to receive any further communication

Please call 0207 206 7293 and ask to speak with the data compliance team

You can also make your request in writing;

By emailing:
datacompliance@webeo.com

Or by writing to:
Data compliance, Webeo, Building 3000, Lakeside, North Harbour, Portsmouth, PO6 3EN.

All requests will be processed within 30 days. Your details will be added to a suppression file to ensure that your details cannot be processed by the Webeo CRM system in the future. Please note this applies only to the processing of your personally identifiable data, not that of the business data which does not fall under the remit of GDPR.

Request for deletion

It is important to understand the difference between a right to object and a request for deletion. If you make a request for deletion, we will remove any data we hold about you from the Webeo CRM system. This will also mean that we will remove you from our suppression files. If you are removed from our suppression files, there is a risk that your data may be processed again in the future if your details are re-added to our CRM system by a member of our sales team who genuinely believes that your business would benefit from Webeo. If you do not wish for us to contact you again about Webeo, we would recommend you request to object rather than a request for deletion, as this will ensure that your details are always suppressed from processing.

The option however is yours, and in either case we will process your request within 30 days.

Please make your request in writing by emailing:
datacompliance@webeo.com

Or by writing to:
Data compliance, Webeo, Building 3000, Lakeside, North Harbour, Portsmouth, PO6 3EN.

Request for data held

You may make a request for the data we hold that relates to you. Please make your request in writing;

By emailing:
datacompliance@webeo.com

Or by writing to:
Data compliance, Webeo, Building 3000, Lakeside, North Harbour, Portsmouth, PO6 3EN.

We will process and respond to your request within 30 days, this service will be free of charge.
DPO Details:
Lindsay Waterman datacompliance@webeo.com

This policy was last reviewed and updated on the 17th October 2018. Policies are periodically reviewed to ensure compliance with the current compliance environment.

For questions relating to this policy, please contact datacompliance@webeo.com

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