Privacy & cookies policy

This privacy policy aims to give you information on how Tangent Marketing Services Limited collects and processes your personal data through your purchase of services from us, correspondence with us, use of our website and/or application for a job with us, including any data you may provide through any of those activities.
Our services and this website are not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller
Tangent Marketing Services Limited is the controller and responsible for your personal data (referred to as, "we", "us" or "our" in this privacy policy) where:

• you provide your personal data directly to Tangent Marketing Services Limited;
• your personal data is provided to Tangent Marketing Services Limited by a customer in connection with a contract for the provision of services by Tangent Marketing Services Limited to that customer;
• your personal data is provided to us by a supplier, outsourcing company or other third party in connection with a contract for the provision of goods or services by that organisation to us; or
• your personal data is provided to us by a recruiter in respect of a job application.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third-parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We will only collect Special Category Data or Criminal Convictions Data about you if you apply for a job with us and have disclosed this to us or a DBS check has been carried out.

Special Category Data is considered as being sensitive personal data, which requires a higher level of protection. We need to have further justification for collecting, storing and using this type of personal data.

We will only collect Criminal Conviction Data if it is appropriate given the nature of the role and where we are legally able to do so. Where appropriate, we will collect Criminal Conviction Data as part of the recruitment process, or we may be notified of such information directly by you in the course of you working for us, or we may conduct additional background checks in the course of your employment but will notify you beforehand.

If you fail to provide personal data
Where we need to collect personal data by law, under the terms of a contract we have with you or when you apply for a job with us, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services or properly assess your suitability for a role with us), nor comply with our legal obligations (such as to ensure the health and safety of candidates). In this case, we may have to cancel a service or contract you have with us, not enter into a contract we are trying to enter into with you, or not be able to properly assess your suitability for a role with us, but we will notify you if this is the case at the time.

We use different methods to collect data from and about you including through:

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where it is necessary for our legitimate interests. This means the interest of our company in conducting and managing our company to enable us to give you as our customer or as an applicant for a job with us the best service or experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
  
  
• Where we need to perform a contract that we have entered into with you. This means processing your data where it is necessary for the performance of a contract to which our customer (for which you are a contact) is a party or relating to your application for a job with us, or to take steps at your request before entering into such a contract.
  
  
• Where we need to comply with a legal obligation. This means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Processing Special Category Data and Criminal Conviction Data
We may process Special Category Data in the following circumstances:

• in limited circumstances, with your explicit written consent;
• where we need to carry out our legal obligations or exercise rights in connection with employment (please see the ‘Purposes for which we will use your personal data’ table below for further information);
• where it is needed in the public interest; and/or
• where it is necessary to protect you or another person from harm.

We may process Criminal Conviction Data in the following circumstances:

• to assess your suitability for a role;
• where it is necessary in relation to legal claims,
• where it is necessary to protect your interests (or someone else's interests) and you are not capable of giving your consent, and/or
• where you have already made the information public.

Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

You can ask us to stop sending you marketing messages at any time by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, service experience review or other transactions.

Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Our website may use cookies to distinguish you from other users of our website. Cookies help us to provide you with a good experience when you browse our website and also allows us to improve our site.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website.
• Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users find what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website and remember your preferences.
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our advertising more relevant to your interests. We may also share this information with third parties for this purpose. Third parties may place cookies, web beacons and other storage technologies on your web browser to enable Tangent Marketing Services to serve you with advertising relevant to you and your interests.
• Retargeting cookies. We may use services provided by Google, Facebook and LinkedIn for cookie-based retargeting advertising. During retargeting, the following data may be collected: your browsing activity, IP address, mobile device type and what advertisements you interacted with and how. This information will help us regulate the advertisements you are served and measure their effectiveness.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

We may share your personal data with the third-parties set out below for the purposes set out in the ‘Purposes for which we will use your personal data’ table above.

• Service providers acting as processors who provide IT and system administration services, including for dealing with certain processes necessary for the operation of the website.
  
  
• Third-parties to whom we may choose to sell, transfer or merge parts of our company or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our company, then the new owners may use your personal data in the same way as set out in this privacy policy.
  
  
• Analytics and search engine providers that assist us in the improvement and optimisation of our website.
  
  
• Third-parties to whom we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements or to protect the rights, property, or safety of our donors, or others.
  
  
• Professional advisers such as lawyers, bankers, auditors and insurers based in the UK who provide consultancy, legal, banking, accounting and insurance services.
  
  
• HM Revenue & Customs, regulators and other authorities based in the UK who require reporting of processing activities in certain circumstances.

We require all third-parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
  
  
• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third-parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Generally speaking, if you have not applied for a job with us, we will only retain your personal data for 3 (three) months. If you have applied for a job with us and unless you are employed by us, we will only retain your personal data for 12 (twelve) months of your application for a role with us.

In either case we will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
By law, for tax purposes, we have to keep some of your personal data for seven years from the end of the tax year or accounting period to which it relates.

In some circumstances you can ask us to delete your personal data. Please see the ‘Your legal rights’ section below for further information.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  
  
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  
  
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third-party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  
  
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  • If you want us to establish the data's accuracy.
  • Where our use of the data is unlawful, but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third-party. We will provide to you, or a third-party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  
  
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:

• Full name of legal entity: Tangent Marketing Services Limited (a company registered in England and Wales with company number 04323657)
  
  
• Email address: ideas@tangent.co
  
  
• Postal address: The Varnish Works, 3 Bravingtons Walk, London, N1 9AJ
  
  
• Telephone number: +44 020 7462 6100

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

We keep our privacy policy under regular review. The history of and any future changes we may make to our privacy policy in the future are and will be stated below and, where appropriate, notified to you by email:

11 May 2018

• Created

8 January 2020

• Updated with more detailed information about retargeting cookies
  
  

26 May 2021

• Updated in compliance with data protect legislation