Privacy

This Privacy Policy sets out the data processing practices of Positive Images UK.   Please note that all data thus
captured will be used and held in accordance with the requirements of the Data Protection Act 1998 and General Data
Protection Regulation 2018. Positive Images UK provides print, direct mail and multichannel marketing services. 
Positive Images UK is the controller of the data outlined below and is responsible for how and why this data is
processed.  Positive Images UK also processes data on behalf of some of our clients. Our Data Protection Officer (DPO)
is Mike Sullivan.  If you have any requests concerning your personal data or any queries with regard to how we handle
your data you can contact the DPO by phone on 020 8544 5500, email hello@positiveimagesuk.com or write to us at Mike Sullivan, Positive
Images UK, 44 Wates Way, Mitcham, Surrey CR4 4HR.  

Purpose of processing your personal data

Activity Purpose of processing Lawful basis
Completing contact form on the website. Dealing with your enquiry or request. Where you have chosen to do so, providing
you with information about our products and services.
Contract     Consent
Completing a brochure request form on the website. Sending you the brochure.   Where you have chosen to do so, providing you with information about
our products and services.
Contract       Consent
Subscribing to our newsletter via the website. Providing you with information about our products and services. Consent
Completing a business order on your business’s online ordering portal Providing you with your goods or service. Contract
Completing a business order received by phone or email. Providing you with your goods or service. Contract
Direct marketing to our existing business customers. Providing you with information about our products and services. Legitimate Interest
Direct marketing to lapsed/ cancelled business customers. Providing you with information about our products and services. Legitimate Interest
Direct marketing to businesses that visit our website. Providing you with information about our products and services. Legitimate Interest
Direct marketing to other business prospects Providing you with information about our products and services. Legitimate Interest

The legal basis on which we rely are:

  • Consent –You have given us consent to process your personal data for direct marketing.
  • Contract – processing is necessary for us to administer the pre-contract and contractual
    relationship between ourselves and our suppliers/customers/potential employees in connection with the performance of
    a contract.
  • Legitimate interests –processing your data for direct marketing is necessary to meet our business
    objectives. We have carried out a Legitimate Impact Assessment (LIA) and we believe the policies and procedures we
    have put in place will ensure that our legitimate interests are not overreached by the rights of individuals whose
    personal data will be processed for direct marketing.

Marketing

We would like to use your personal data to send you details of products or services that we offer that we have
identified as likely to be of interest to you. If at any point you would like to opt-out of receiving communications
from us, or would like to change the channels (such as email or post) that we use to contact you, please email Mike
Sullivan, Data Protection Officer hello@positiveimagesuk.com or write
to Mike Sullivan, Positive Images UK, 44 Wates Way, Mitcham, Surrey CR4 4HR.  

Recipients/categories of recipients

In carrying out our business including our obligations to you, we may use sub-contractors. These will be, email
broadcasters.  We will ensure that they respect your privacy and abide by all data protection laws.  

Data subject’s rights

You have rights in respect of your personal data. We will need to confirm your identity before we can consider your
request so, if you wish to exercise any of these rights, we will need to see your passport, driving licence or a
utility bill. The right to be informed – you have the right to be told about the collection and use
of the personal data you provide. This privacy policy sets out the purpose for which we process your personal data,
how long we will keep your data, who we will share your data with. If you have any questions on how and why we process
your data please contact the DPO. If you want to know more about this right, the ICO has more guidance on their
website: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-be-informed/
Right of access – you have the right to know whether we are processing your personal data, and to a
copy of that data. We would need as much information as possible to enable us to locate your data. We will respond to
your request within 28 days of receipt of your request. If you want to exercise this right, please contact the DPO at
the contact details above. If you want to know more about this right, the ICO has more guidance on their website: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-of-access/
Right to rectification – you have the right to have any incorrect personal data corrected or
completed if it is incomplete. You can make this request verbally or in writing. We will need as much information as
possible to enable us to locate your data. We will look at any request and inform you of our decision within 28 days
of receiving the request.  If you want to exercise this right, please contact the DPO at the contact details above. If
you want to know more about this right, the ICO has more guidance on their website: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-rectification/
Right to erasure – this right, often referred to as the right to be forgotten allows you to ask us to
erase personal data where there is no valid reason for us to keep it. We will look at any request and inform you of
our decision within 28 days of receiving the request.  If you want to exercise this right, please contact the DPO at
the contact details above. If you want to know more about this right, the ICO has more guidance on their website: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-erasure/
Right to restrict processing – you have the right to ask us to restrict processing of your data. We
will look at any request and inform you of our decision within 28 days of receiving the request.  If you want to
exercise this right, please contact the DP at the contact details above. If you want to know more about this right,
the ICO has more guidance on their website: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-restrict-processing/
Right to data portability – you have the right to move, copy or transfer your personal data from one
IT environment to another. This right applies to data that you have provided to us and that we are processing on the
legal basis of consent or in the performance of a contract and that processing is by automated means. We will respond
to your request within 28 days of receipt of your request. If you want to exercise this right, please contact the DPO
at the contact details above. If you want to know more about this right, the ICO has more guidance on their website:
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-data-portability/
Right to object – you have the right to object to our processing of your personal data based on (i)
legitimate interests, or for the performance of a task in the public interests/exercise of official authority
(including profiling); (ii) direct marketing (including profiling); and (iii) for purposes of scientific/historical
research and statistics.

  • Legitimate interests/legal task – your objection should be based on your particular situation. We can continue to
    process the data if we can demonstrate compelling legitimate grounds which override your interests.
  • Direct marketing – you have an absolute right to ask us to stop processing for the purposes of direct marketing.
    We will action your request as soon as possible.
  • Scientific/historical research and statistics – your objection should be based on your particular situation. If we
    are conducting research where the processing is necessary for the performance of a public task, we can refuse to
    comply with your objection.

If you want to exercise this right, please contact the DPO at the contact details above. If you want to know more
about this right, the ICO has more guidance on their website: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-object/
 

Processing based on consent

Where we process your personal data based on your consent you have the right to withdraw that consent at any time
without reason. You can opt-out by using the unsubscribe/opt-out in any marketing we send you and you can contact the
DPO at the contact details above.

The right to lodge a complaint to the supervisory authority

If you are unhappy with any aspect of our handling of your data you can make a complaint to the Information
Commissioner’s Office – https://ico.org.uk/concerns/  

Statutory/contractual requirement to provide personal data

The personal data that you provide to us is necessary for us to carry out the contract you have entered into with us
or for us to perform our obligations under Statute.  

Job Applicants

We will not share any of the information you provide during the recruitment process.  The information you provide
will be held securely by us and we will not retain it for longer than is necessary. Therefore, if you unsuccessfully
apply for a role with us, we will delete or anonymise your personal information once we have communicated this to you.
There may be circumstances in which we will retain your data for a future opportunity and if this is the case, we will
seek your express consent beforehand.

Cookies

A cookie is a small piece of information sent by a web server to a web browser, which enables the server to collect
information from the browser.  Find out more about cookies on http://www.allaboutcookies.org/   Most browsers will allow you to turn
off cookies.  If you want to know how to do this please look at the menu on your browser, or look at the instruction
on http://www.allaboutcookies.org/  Please note however that turning off
cookies will restrict your use of our website. Please note that the services you have asked for cannot be provided if
necessary cookies are disabled.

Cookie Type Cookie details How to disable and consequences
Google Analytics Google Analytics mainly uses first-party cookies to report on user interactions on Google
Analytics customers’ websites.   Google Analytics does not collect any data that personally identifies an
individual (such as name or email.)   For further information visit https://developers.google.com/analytics
/devguides/collection/analyticsjs/cookie-usage
 
Website users that don’t want their data reported by the Google Analytics JavaScript can install
the Google Analytics opt-out browser add-on.   Disabling google analytic cookies shouldn’t have any impact on
your user experience.   For further information visit https://support.google.com/analytics/answer/181881
 
Cookie Consent We use google analytics  to remember if a user consents to cookie use.   gtag.js uses the _ga and
_gid cookies to distinguish unique users, and uses the _gat cookie to throttle the request rate.   For further
information visit https://developers.google.com/analytics/
devguides/collection/gtagjs/cookie-usage
Most browsers will allow you to turn off cookies (see paragraph 8 above).   Please note that
disabling these cookies may affect your user experience.
Market Direct Cookies (Marketing Campaigns only)       Positive runs direct marketing campaigns to business prospects.   We use market direct technology
and cookies to personalise and track these campaigns:   dsmt –  Tracking cookie used to track
site visits   dsm_cookie – Campaign cookies key that matches to the users cookievalues  
dsmcookiekey – the actual user session  
Most browsers will allow you to turn off cookies (see paragraph 8 above).   Disabling the traffic
cookie (dsmt) shouldn’t have any impact on your user experience.   Please note that disabling the other market
direct cookies will affect your user experience.
Storefront Cookies   (Online Ordering Sites only) Some of our clients have access to their own online ordering sites/ portals.   These sites/
portals utilise a variety of cookies.   Necessary Cookies Necessary cookies are essential in
order to enable you to move around the website and use its features.   ASP.NET_SessionId– Used
by ASP.NET to create a session ID for the user, so that the system itself can identify the user as a unique and
individual user, distinct from anyone else looking at the website.   Functionality Cookies
Functionality cookies are used to remember your choices and preferences.  They do not track your browsing
activity on other websites.   AutoLogin– This cookie allow users to automatically sign in.  
AutoAdminLogin– This cookie allow administrators to automatically sign in.  
MenuHeader_Orders– Remembers basic preferences, such as format of search results and how to
display information.   MenuHeader_AccountManagement- Remembers basic preferences, such as
format of search results and how to display information.   MenuHeader_Content– Remembers basic
preferences, such as format of search results and how to display information.  
MenuHeader_PurchasingConfig- Remembers basic preferences, such as format of search results and
how to display information.   MenuHeader_AdminPages- Remembers basic preferences, such as
format of search results and how to display information.   ROIStorefrontCookieConsent-
Remembers if a user consents to cookie use.
Most browsers will allow you to turn off cookies (see paragraph 8 above).   Please note that the
services you have asked for cannot be provided if necessary cookies are disabled.   Please note that disabling
functionality cookies may affect your user experience.

Lead Forensics

We use Lead Forensics to provide us with information on businesses visiting our website, based on IP addresses.  In
addition to information about the business, Lead Forensics provides information about the date and the duration of the
user’s visit and the web pages which the user visits.  Lead Forensics does not provide information on specific,
identifiable individuals visiting a website; nor does it use cookies to identify and track visitors.  As an additional
service, Lead Forensics provides names and email addresses of individuals in a business, although these do not relate
specifically to visitors to the website. This information is collected from a range of sources where those providing
the information have given consent for its use.  For further information, please visit https://www.leadforensics.com/privacy-policy/  

Third party websites

Our website may contain links to other websites that are outside our control and are not covered by this Privacy
Policy.  If you access other sites using the links provided, the operators of these sites may collect information from
you that will be used by them in accordance with their privacy policy, which may differ from ours.  

Changes to the privacy policy

This privacy policy is regularly reviewed and will be updated when necessary. If we make any significant changes to
the policy we will communicate these to you.  

Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure,
we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information
we collect online.  

Data Retention

In compliance with the Data Protection Act 1998 and GDPR 2018 your data will not be kept longer than necessary.  We
will retain Personal Data for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a
longer retention period is required or permitted by law.