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Privacy Policy

The Webeo Product

The Webeo product is a B2B sales and marketing enablement tool. It is SaaS (Software as a Service). We specialise in tailor made web personalisation for businesses of all industries and sizes. Webeo allows businesses to personalise their website against a number of variables, enabling them to deliver a targeted, rich, specifically tailored experience for their web visitors. We personalise 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 personalisation specific to that vertical if one has been created. Webeo customers also have the option to implement a cookie alongside the code to enhance the tracking capabilities of the software.

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 basis 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 organisation 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 processes 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 organisation as well as the individual’s job function within the organisation. 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 organisation they are employed by and based upon their job function within that organisation.

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 enquiry 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.

Screening phone numbers against TPS/CTPS lists

All phone numbers that are collected are checked against the TPS (Telephone Preference Service) and CTPS (Corporate Telephone Preference Service) lists daily. This will ensure that our team does not contact via telephone any individual or business that has registered their phone number on either of these lists.

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
  • Your data has been purchased by a registered third party data supplier, which will have been segmented by industry, organisation 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 organisation 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.

Call Recordings

In the interest of our employees, customers, and prospective customers, all calls are recorded for training and monitoring purposes. Please see our Call Recording Policy for more information.

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 0208 099 9077and 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.the interest of our employees, customers, and prospective customers, all calls are recorded for training and monitoring purposes. Please see our Call Recording Policy for more information.

Request for Deletion

In the event that you make a request for deletion, a minimal amount of your personal data will be kept in our suppression files. This enables Webeo to fulfil our legal obligation under Article 6(1)(c) of the GDPR to ensure that you are not contacted again.

If you are not added to our suppression file, there is a risk that your data may be processed again in the future if your details are re-added to our software by out data procurement team. Therefore, we will keep a minimal amount of data (name, business phone number, and business email or LinkedIn URL where applicable) in a suppression file with a note to say that you no longer wish to receive communication so that you are not contacted again in the future.

All requests will be processed 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

Yo may 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 is free of charge.

Data Protection Officer (DPO) details

Lindsay Evans, datacompliance@webeo.com

This policy was last reviewed and updated on 05th June 2020. Policie are periodically reviewed to ensure compliance with the current complicante environment.

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

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