Privacy Policy

This Privacy Policy describes the information that we gather on or through our Services and how we use and process such information. For each processing purpose we will articulate the reason for requiring the data, what data we will process, the legal basis for processing the data and how long we will keep the data.Where the legal basis of consent is to be used, this will be gathered freely, and we will use clear, plain language that is easy to understand, and you will be able to remove your consent at any point.

What information do we collect about you?

We collect/process information so that we can provide the best possible experience when you utilise our services.  This section of the policy will describe the purpose for processing your personal data, the legal basis to do so and how long we will keep your data.

Our Product / Service

Fospha Pro collects data from various sources, including:

Client Data: This includes data provided by our clients (the businesses using Fospha Pro) about their marketing activities, such as advertising spend, campaign details, and website analytics. This data may include information about their customers, but only if and to the extent that our clients have the necessary legal basis and consent to share this data with us for this purpose. We act as a data processor on behalf of our clients in these circumstances. The types of customer data typically processed include:

  • Pseudonymous Identifiers: These are identifiers like transaction IDs, or hashed email addresses, which do not directly identify an individual but can be used to track marketing interactions.
  • Marketing Interaction Data: This includes data about how users interact with marketing campaigns, such as clicks, views, conversions, and purchases.
  • Aggregated and Anonymized Data: We may also process aggregated and anonymized data derived from the client data, which does not identify any individual.

Third-Party Data: Fospha Pro may integrate with third-party data providers to enrich the data collected from clients. This data may include demographic information or other marketing-related data. We only work with reputable third-party providers who have appropriate data privacy practices in place.

How Fospha Pro Uses Data:

Fospha Pro uses the collected data for the following purposes:

  • Marketing Measurement and Attribution: To analyze the performance of marketing campaigns and attribute conversions to different marketing touchpoints.
  • Reporting and Analytics: To provide clients with reports and insights on their marketing performance.
  • Product Improvement: To improve the functionality and performance of Fospha Pro.

Requests to correct, amend, or delete data where Fospha is the data processor for our customers (the data controller) should be addressed to our customers using the details required on their privacy policy. Upon receipt of requests we will act within 30 days.

Corporate

If you choose to become a customer of our service, personal data items such as Name, Email Address and Telephone number may be stored in our Corporate Cloud Storage, Corporate Email Platform or our Help Desk platform.

We will process data using the under the legal basis of legitimate interest. A contract will be in place with your employer, however we will need to use legitimate interest to process your data given we do not have a direct contractual relationship with the data subject.

Personal data will be retained for a period of up to 2 years for an active customer account.

Marketing

We would like to send you information about products and services of ours which may be of interest to you. You have a right at any time to stop us from contacting you for marketing purposes. The personal data will include names, addresses, email addresses, employer, job title and telephone numbers.

We will process data using the following legal rationales to send marketing information, if you are an individual and not associated with a contracted client we will ask for your consent. If you are associated with a contracted client, we will use contractual obligation as the legal basis to process the data. If you are associated with a previous contracted client, we will use legitimate interest as the legal basis to process the data. All of the above rationales for marketing information can be removed by informing us of your wish to remove consent.

We will retain personal data for active customer leads for a period of up to 1 year, a lead will be active under the following circumstances

  • An email sent by our organisation has not received an unknown account bounce back
  • An email has been sent to our organisation from the data subject

Cookies

Like many websites, we use cookies and similar technologies to collect additional website usage data and to improve our Services. Website usage information is collected using cookies to monitor aggregate site usage metrics such as total number of visitors, pages viewed and web traffic routing on our Services. We will store the cookie values on our platform to allow us to perform our analysis, however this will not be used to target marketing material to an individual user.

We will process data under the legitimate interest legal basis as we only use the data to perform aggregated tracking analysis and will not target individuals based upon this analysis and you also need to accept our cookie policy to allow us to process the data.

We will retain active cookie data for a period of up to 1 year, a cookie will remain active if a user re-visits our platform.

Learn more about how we use cookies by reading our  Cookie Policy.

CCPA

In relation to the California Consumer Privacy Act (CCPA), we confirm the following

  • We do not sell any personal information
  • We do not offer any financial incentive for your personal information
  • You will not receive any discriminatory treatment by our business for exercising your privacy rights
  • We will not charge you for exercising your privacy rights
  • Upon receiving a request to know or a request to delete, we will confirm receipt of the request within 10 business days and provide information about how the business will process the request.
  • We will respond to requests to know and requests to delete within 45 calendar days.
  • We shall not disclose in response to a request to know a consumer’s Social Security number, driver’s license number or other government-issued identification number, financial account number, any health insurance or medical identification number, an account password, security questions and answers, or unique biometric data generated from measurements or technical analysis of human characteristics.
  • We are able to provide the information and classification of information when responding to a Request to Know request
  • We are able to delete the personal information in relation to a Request to Delete request

Updating These Terms

We may change our Service and policies, and we may need to make changes to these Terms so that they accurately reflect our Service and policies. Unless otherwise required by law, we will notify you at least 30 days before we make changes to these Terms and give you an opportunity to review them before they go into effect. Then, if you continue to use the Service, you will be bound by the updated Terms. If you do not want to agree to these or any updated Terms, you can request an account deletion.

Your Rights

Accessing or Rectifying your personal data

We want to make sure that your personal information is accurate and up to date and you have the right to request a copy and update the personal data that we hold about you. You may ask us to correct or remove information you think is inaccurate. In most circumstances before we are able to invoke your rights we may need to verify you as the data subject, therefore we will request data from you and this will be checked against our records before we can proceed. If you would like to invoke this right, please email or write to us at the below address.

Deletion

Based upon the retention periods described above we will remove your personal data from our platforms.

Object, Restrict or Withdraw Consent

You may wish to object to or restrict our ability to process your personal data, this can be done either via email or in writing, using the contact details below. Further context may need to be requested to ensure we can carry out the relevant tasks on our platforms to perform the request.

Portability

You may wish to port your personal data to another platform. This can be done either via email or in writing, using the contact details below.