Privacy Policy

Welcome to We are Snook Limited’s privacy notice for its website and marketing communications. 

We Are Snook Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. 

Purpose of this privacy notice 

This privacy notice aims to give you information on how We Are Snook Limited collects and processes your personal data (a) through your use of our website, including any data you may provide through the website when you contact us or a member of our team using it, and (b) when you are included on our marketing database, including if you sign up to our newsletter  through our website. 

Our website is not intended for children and we do not knowingly collect data relating to children that use our website. 

It is important that you read this privacy notice together with any other privacy notice or fair processing notice 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 notice supplements the other notices and is not intended to override them. 

Controller 

We Are Snook Limited is the controller and responsible for your personal data (collectively referred to as “Snook”, “we”, “us” or “our” in this privacy notice). 

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

Contact details 

Our full details are: 

Full name of legal entity: We Are Snook Limited 

Email address of the Data Protection Officer: dpo@necsws.com 

Postal address:  Suite 7.02, Clockwise, Savoy Tower, 77 Renfrew St, Glasgow, G23BZ  

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority 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. 

Changes to the privacy notice and your duty to inform us of changes. 

This version was last updated on 13th September 2023 

It is important that the personal data we hold about you is accurate and current. We’d be grateful if you could keep us informed if your personal data changes during your relationship with us by contacting us at curious@wearesnook.com.

Third-party links 

Our website or communications that we send to you 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. We encourage you to read the privacy notice of every website you visit. 

The data we collect about you 

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: 

  • Identity Data includes first name, last name, age, gender, job title, company details. 
  • Contact Data includes company address, email address and telephone numbers. 
  • Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website. 
  • Usage Data includes information about how you use our website, products and services. 
  • Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences. 

We also collect, use and share Aggregated Data such as statistical or demographic data. 

Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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 notice. 

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. 

How is your personal data collected? 

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

Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: 

  • give us some feedback; 
  • subscribe to receive any of our news or marketing communications (including emails); 
  • request marketing communications to be sent to you; 
  • download something from our website; 
  • ask us a question; or 
  • request further information from us. 

Automated technologies or interactions. As you interact with our website, we may automatically collect Usage Data and Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details. If you are on one of our marketing lists we will be able to identify you when you use our website. 

Third parties or publicly available sources. We may receive Technical Data from analytics providers such as Google, MailChimp and others. 

How we use your personal data 

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 (or those of a third party) and your interests and fundamental rights do not override those interests. 
  • Where we need to comply with a legal or regulatory obligation. 
  • In certain circumstances, where you consent to the processing. 
  • Where we are processing on the basis of your consent you have the right to withdraw that consent at any time by contacting us at curious@wearesnook.com 

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. 

Purpose/Activity  Type of data  Lawful basis for processing including basis of legitimate interest 
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you  (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical 		 Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) 
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences  (a) Technical
(b) Usage 		 Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) 
To make suggestions and recommendations to you about goods or services that may be of interest to you  (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile 		 (a) Necessary for our legitimate interests (to develop our products/services and grow our business)
(b) Your consent 
To respond to any questions or queries you submit 
1 Identity
2 Contact 		 Your consent 
To administer and protect our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)  (a) Identity
(b) Contact
(c) Technical 		 (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation 


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. 

You will receive marketing communications from us if you have requested to be added to our marketing database, you have subscribed for news alerts or similar from us and have not opted out of receiving that marketing. 

You can unsubscribe from receiving marketing communication from us by updating your subscription settings. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a direct request for further information. 

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. 

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. 

Disclosures of your personal data 

We may have to share your personal data with the parties set out below for the purposes set out in the table above. 

We may need to transfer your personal data to other companies within the SNOOK group of companies, for example if you express an interest in a product on this website that is provided by another member of our group. If that happens, the relevant other member of the SNOOK group of companies will process data in the same manner as set out in this privacy notice, 

We may transfer your personal data to other companies within the wider NEC Group (SNOOK is owned by the NEC Corporation). 

We may need to transfer your personal data to external third party companies (for example, to the company that manages our website from time to time, or a company that we engage to print hard copy marketing material). 

Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice. 

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. 

International transfers 

In some circumstances we may need to share your personal data within the SNOOK Group. This may involve transferring your data outside the UK or the European Economic Area (EEA). 

Whenever we transfer your personal data out of the UK or EEA, we ensure a similar degree of protection is afforded to it and that the transfer is in accordance with legislation. For example, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. 

Data security 

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. 

Data retention 

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, 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 requirements. 

Your legal rights 

Under certain circumstances, by law you have the right to: 

Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. 

Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected. 

Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below). 

Object to the processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes. 

Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it. 

Request the transfer of your personal information to another party. 

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact our Data Protection Officer (DPO) in writing at dpo@necsws.com, or   

Suite 7.02, Clockwise, Savoy Tower 77 Renfrew Street, Glasgow, G2 3BZ 

If you wish to exercise any of the rights set out above, please contact us at curious@wearesnook.com.

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 may 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 28 days. Occasionally it may 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.