Privacy Policy

Welcome to the My Data Choices privacy policy. My Data Choices is the name of Sagacity Solutions Limited preference centre. This is where we store your record and where you can go to change the way we process your data. You are here because you have given or may choose to give us permission to process your personal information. We want to make sure that you are now completely clear on how, when and why we can use your data. We also want to make it clear that you can change your mind and ask us to stop using your data whenever you like.

Your data will be shared and processed with-in our group of companies, under the original purpose it was collected and in line with the UK GDPR, Data Protection Act 2018 and the Privacy and Electronic Communications Regulation 2003 (PECR)

You will be relieved to know that we cannot process or use your data unless we have legal grounds to do so.

1. Who we are

1.1. We are Sagacity Solutions Limited (05526751) and owned by Sagacity Group Ltd (13350011). The foregoing, "Sagacity", "Sagacity Solutions", "we", "us" and "our" means Sagacity Solutions Ltd and our subsidiary and affiliated companies and "you" means the individual using our Site.

Registered Offices:

Sagacity Solutions Limited 120 Holborn, London, EC1N 2TD

Sagacity Group Limited: 33 Glasshouse Street, London, W1B 5DG (“Sagacity”)

We are a data insight and marketing service company and help our clients:

•  look after their existing customers
•  find new customers
• keep the information they hold on their customers up to date and accurate
• trace individuals  or verify identity
• add to  information about customers
• link and match information that may have come from a number of different sources
• use information about you for  credit and risk assessment and management, identification and fraud prevention, enforcement, debt collection and returning assets to you

We hold your personal data in our database and process it on behalf of our clients.

Your data will be shared and processed with-in our group of companies under the original purpose it was collected and in line with the UK GDPR principle of purpose limitation - Article 5(b). the Data Protection Act 2018 and the Privacy and Electronic Communications Regulation 2003

Please see table below which explains these purposes.

Each company within our group shall comply with their respective obligations under the data protection Legalisation in respect of any shared personal data or any personal data held or processed by each company.

You will be relieved to know that we cannot process or use your data unless we have legal grounds to do so.

Either we will have:

a. your consent to process your data; or

b. a legitimate interest which makes processing your data necessary.

c. a public task carried out in the public interest to process your data 

The table below sets out the purposes for which we and our clients will use your data and the basis upon which they will process it:

If you contact us we will be able to give you any further information you require to understand this.

2. Legitimate Interest

You may be wondering what legitimate interest means and what our legitimate interest is. Our business as a data services provider rests upon us being able to process personal data for our clients’ direct marketing or for other legitimate business purposes. If we could not do this then we would not have a business, so we have a legitimate interest to do so. Our clients will also have a legitimate interest in processing your data whether it is to find new customers, make sure that they deliver the best products and services to existing customers, keep personal data up to date and accurate, trace individuals, or improve their insight into their customers by matching and linking data. That on its own is not enough, we also have to balance these interests with yours. We consider whether you will expect your data to be processed by our clients for their legitimate business purposes and whether you will expect your personal data to be our database. If on balance we think that your interests will not be overridden then we can process your data. If you do not want us to do so, then tell us and your data will be removed from our database. Unsubscribing

We have already told you about our legitimate interest for holding your data but there are others. We are permitted to share information with other businesses who use such information for non-marketing purposes (including credit and risk assessment and management, identification and fraud prevention, enforcement, debt collection and returning assets to you). This would include the information you provide to us today, at any time in the past and in the future.

3. Public Task

For the performance of a public task or in the exercise of official authority vested in our clients

Not all of our clients have a legitimate interest , some of our clients operate within the public sector which means that as public authorities they might need to process your personal data when is necessary to exercise their official authority or carry out a task in the public interest. Some of these public authorities might use it for public enforcement purposes. 

4. Who we share your information with

We will share your information with our clients who include:

UKPhonebook.com licenses data from Sagacity Solutions Limited under the lawful basis of Legitimate Interest and has entered into appropriate undertakings in relation to data protection compliance. UK Phone book have carried out legitimate interest assessments on each type of data they receive and taken the steps necessary to protect the interests of data subjects. UKPhonebook.com has a legitimate interest in making data available on its website as subscribers to the website wish to search for individuals.

More information regarding the data UK Phonebook publish can be found here: https://www.ukphonebook.com/privacy

Epsilon operates the Abacus Alliance , which is a data cooperative used by UK Charities and Retailers (Members) to find consumers who may be interested in what they offer. More Information on how Epsilon process personal data can be found here : https://legal.epsilon.com/abacus/services-privacy-policy

Our clients can only use your data as we have set out in this Privacy Policy. If they use it for anything else it will be unlawful.

Kinesso - Kinesso provides digital marketing, advertising solutions, and technology services that help our clients connect and engage with people in more respectful and beneficial ways.

Our services help us reconcile disparate sets of data and connect our clients to their customers and prospective customers in connected channels, such as websites, mobile apps,and connected TV. To learn more or opt out of Kinesso's products and services, please visit: Kinesso Ltd - https://kinesso.com/products-services-privacy-notice/

These clients, like us, use your data to create marketing products and services to help their clients tailor products and services which suit their requirements. Your data is transferred to these clients on the basis of legitimate interest. They  have an obligation to ensure that you are made fully aware of the grounds upon which they will process your data and the basis on which they will do so.  You can request  information on all the processing of your data at any time by way of a Subject Access Request. 

All of the contact details are set out in section 9 below or click HERE

The brands that are likely to contact you will operate in one of the following sectors:

5. What information do we collect from you?

Your information will have been collected by any following means:

Sagacity Solutions gathers personal information from a variety of sources including the Edited Electoral Register and from customer satisfaction and lifestyle surveys, mail order, and offers and competition websites as listed below; For information about each source please click here

When you signed up you will have been told that your data would be used by us or by companies like us. You will also have ticked a box or said ‘yes’ to contact or you will have been told that we, companies like us or our clients would be contacting you as we have a legitimate interest to do so. As well as name and address information you may have provided information about your household, your hobbies, holidays, cars etc. 

6. Special categories of data

We do not collect or process any Special Categories of Personal Data about you , as set out in the UK, UK GDPR. This includes details about your race or ethnic origin, political opinions, religious or philosophical beliefs ,health and medical information , trade union membership and genetic and biometric data.

7.    Why do we collect this information?

We collect this information because it is the basis of our business. We provide the following services to our clients:

a. Insight: To make sure that you receive offers relevant to you our clients use your information and information on other individuals to decide how best to target you. They do this by creating models which help our clients target their marketing campaigns effectively. This means you should only receive offers which are relevant to you.

b. Marketing: As we explained above our business is providing personal data to our clients for their marketing campaigns. For example, if a new golf club is opening near you the owner may come to us and ask for a list of individuals within certain postcodes, aged between 18 and 60 who like golf. We will provide that list on the basis that the golf club owner will contact you to see if you would be interested in becoming a member.

c. Data Hygiene. We must ensure that the information we hold about you is kept up-to-date, relevant and accurate. To do this we match data against lists of people who we know have moved, relocated or died such as the Telephone Preference Service, Mail Preference Service, The Bereavement Register (TBR) and Goneaway Away Suppression file (GAS).

d. Matching and Linking. If we have information about you from more than once source we will match and link the information to create a clearer understanding of you.

e. Appending and Enrichment.  If you are a customer of a client of ours we will supply additional information to the client so that they can learn more about you but only if you have given our client permission to do this.

f. Tracing and Verification. If you are a customer of a client of ours then we will supply information about you to the client so that they can ascertain your identity or trace you. This will only happen if the client has a legitimate interest to do so or if they have another legal reason to process this information. For instance because you have a contractual arrangement with them.

8.    What do we do with your information?

You can be assured that your information will only be used in accordance with this Privacy Policy.

a. We will use your information, and information from others, to develop products and services, for marketing, research, modelling and/or profiling. We will also use your information, combined with the information of others to derive assumptions about you and others for the purpose of updating and correcting databases, tracing and linking purposes. This profiling is used by our clients to tailor the offers they make to you and ensure that their marketing is targeted to your interests. Profiling is used to help our clients understand more about you as a customer it is not designed to have any legal effect or adverse impact on any decisions made about you as a result. If you do not want your data to be used in this manner then please click here:  https://www.mydatachoices.co.uk/Suppress

b. We will use your information to determine what goods and services you may be interested in. Your information will be shared with and used to appropriately target offers and marketing communications from different brands. Marketing communication may be through email, mailing, telemarketing, SMS/MMS, digital display as you browse the internet and door-to-door canvassing. This will be dependent upon what you have agreed to.

c. We will combine all the information we hold about you into one complete record. This helps us to know you much better and improve the accuracy of information we hold. Our clients can use this record to enhance an existing database with more information. We could receive your date of birth from one source and your hobbies and interests from another to create one complete record.

d. We will regularly match your record against our registers of people who have moved house, been relocated or died to make sure that your record is up to date. We will regularly check whether you have registered with the Telephone Preference Service or the Mail Preference Service.

e. The majority of our clients like to use display advertising or banner ads which will appear whilst you are browsing on the internet. To enable this, each time we send you an email we can automatically collect technical information, including the type of device you use and a unique device identifier. We will deliver a tiny graphic image of just one pixel to your computer either as part of a web page request or in an HTML email message. Either directly or through service providers, we use these pixels to learn more about the devices you are using in order that you see content or advertisements to match your preferred interests. We will share this information with our clients to enable them to make appropriately targeted offers and marketing communications.

You have the right to opt out of all marketing and profiling at any time by unsubscribing here at My Data Choices.

9.    How long do we keep hold of your information?

Our databases are refreshed bi-monthly and we will also make regular double checks by matching your data against the registers we mentioned above. If  you have asked us to remove you from our databases we do retain a version of your record on our suppression file. This is for two reasons:

a. We need to keep a record that says you do not want to be contacted. We find that information frequently comes to us from more than one source so the only way to be sure that you are not re-entered into the database is to have a register we can check against.

b. If you ask us to provide you with all the information we hold about you then we need a record of you to search our old databases to understand when your information was originally passed to us, and by whom.

10. Securing your information

Sagacity are ISO27001 certified and a fully functional Information Security Management System (ISMS) is in place managed by an Internal Steering Committee. In addition, the group have a fully functional UK GDPR compliance programme which uses the ISO27001 framework. Sagacity hold the following certifications and memberships : DMA Data Seal, Cyber Essentials and DMA membership and the group is registered with the Information Commissioners Office.

Your data will not be transferred outside the EEA unless there is a mechanism in place to ensure  that it will be processed to the same standards as are expected within the United Kingdom. This mechanism may be the acceptance of the EU model clauses which govern data transfer to countries outside the EEA or if the transfer is to the United States of America then will be governed by Standard Contractual Clauses (SCCs). We understand that this might not mean much to you so if you require any more information about the safeguards we have put in place then please contact  dpo@sagacitysolutions.co.uk.

11.    Requests, Enquiries, and Unsubscribing

If you change your mind about us processing your personal information at any time we must act upon your requests. You can:

a. Ask for a copy of the information that we hold about you.

This is called a Subject Access Request (“SAR”) and we must:

• Tell you whether your personal information is being processed;
• Give you a description of the personal information, the reasons it is being processed, and whether it will be given to any other organisations or people;
• Give you a copy of the information comprising the data; and given details of the source of the data (where this is available).
• We will ask for proof of identification before complying with your SAR. We have to respond to you within 1 month of your request. It can take us time to make sure we have checked all of our archives. Certain types of personal information are exempt from the right of subject access, details of these exemptions can be found at https://ico.org.uk/for-organisations/guide-to-data-protection/exemptions/.

b. Request the removal of your details from Sagacity’s database.

c. Ask us to update or rectify the information Sagacity hold about you.

d. Ask us to stop sending you emails and other forms of marketing communication.

e. Ask us to permanently erase any information we hold about you.

f. Ask us to transfer all of your personal information to another company.

You can manage all of this via My Data Choices www.mydatachoices.co.uk, or by email to dpo@sagacitysolutions.co.uk or by writing to:

Data Protection Officer, Sagacity Solutions  Limited 120 Holborn, London, EC1N 2TD

Complaints Procedure

If you have a complaint regarding the use of your information, please contact the Data Protection Office using the details provided above. We will carry out a full investigation into the use of your information. We aim to respond to all complaints without undue delay, or in any event within 28 days from receipt.

Should you feel your complaint has not been effectively handled by Sagacity, you have the right to escalate your complaint to the Information Commissioners Office.

12.  Changes to this Privacy Policy 

We reserve the right to change this privacy policy from time to time. Any such changes will be posted on this page so we can keep you informed of our information collection and sharing practices. We encourage individuals to be responsible for their privacy and recommend that you frequently consult this page, so you are aware of our latest policy.

Last updated 19/01/2024