Skip to content

Privacy Notice

Last updated 24th December 2024

Who Are We?

Serpico Marketing Solutions Limited, a company incorporated and registered in England and Wales with company number 12063220 whose registered office is at Cannon Place, 78, Cannon Street, London, EC4N 6AF (“Serpico”, “we”, “our”) is committed to protecting the privacy and security of your personal information. Serpico is a reseller of Google Marketing Technologies to include Search Ads 360, Campaign Manager 360, Display & Video 360 and Google Analytics.

Controller

Serpico acts as a “data controller” and is responsible for certain personal data about you that we collect and use to provide our services to the organisation that you represent (our Customers) or where you use or browse our website as a user. 

Processor

We may also act as processor of some personal data that we receive from or collect on behalf of one of our Customers, acting as a controller. This is so that we can provide our services to our customers and our legal obligations as a processor are instead set out in the contract between us and the relevant controller and the relevant privacy obligations applied.

Contact us

If you have any questions about this policy or about how we handle your data, please contact our data privacy team as follows:

Email: dpo@croud.com

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. This version was last updated on 24th December 2024.   

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.

Third-party apps, websites and services

If you use any third party apps, websites or services to access our services, your usage is subject to the relevant third party’s terms and conditions, cookies policy, and privacy policy. For example, if you interact with us on social media, your use is subject to the terms and conditions and privacy policies of the relevant social media platform

What data is collected?

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:

Representatives of Customers

  • Identity Data: includes name and job title.  
  • Contact Data: includes business address, email address and telephone numbers, organisation details, where applicable online presence.
  • Profile Data: includes orders made by you on behalf of your organisation, your feedback.
  • Usage Data includes information about how you use our website and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Website users

  • Technical Data: includes your computer’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, the device type, operating system, unique device identifiers, device settings, and geo-location data. 
  • Usage Data: information about how you use our website, IT, communication and other systems.

It is unlikely that we will need to deal with any special categories of personal data relating to you but, should you choose to provide any special categories of personal data to us, we will ensure that we take additional measures to ensure its security.

How your personal data is collected

We collect some of this personal data directly from you in person for example by telephone, email and/or via our website. However, we may also collect information:

  • from publicly accessible sources, such as publicly accessible websites for example LinkedIn or Companies House;
  • from cookies on our website—for more information on our use of cookies, please see our cookie policy

How will we use your information?

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

  • where we need to perform the contract we have entered into with you, or to take steps to enter into that contract;
  • where we need to comply with a legal obligation;
  • where it is necessary for our legitimate interests (or those of a third party), so long as your interests and fundamental rights do not override those interests.
  • Serpico does not generally rely on consent as a legal basis for processing your personal information other than in relation to sending third party direct marketing communications to you electronically. You have the right to withdraw consent to such marketing at any time.

We will use the personal information we collect about you to:

  • register your organisation as a client/customer;
  • perform our contract with your organisation and to provide our services;
  • manage our relationship with your organisations, including notifying your about changes to our contract or services or asking you to provide us with feedback;
  • administer and protect the business and the Website;
  • preventing and detecting fraud against you or us;
  • to enforce legal rights or defend or undertake legal proceedings, or to provide information required relating to audits, enquiries or investigations by regulatory bodies;
  • make suggestions or recommendations to you about similar products or services that may be of interest to you.

If you fail to provide personal information

If you fail to provide certain information when requested either by law, or under the terms of a contract we have with you, 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 goods or services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

Data retention

We will only retain your personal information 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. Details of retention periods for different aspects of your personal information are available in our retention policy. To ask questions or comment about this privacy policy and our privacy practices, contact us at dpo@croud.com. After this period, we will anonymise or securely destroy your personal information.

Data security

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

We have put in place procedures to deal with any suspected data security breach and will notify you and the Information Commissioner’s Office of a suspected breach where we are legally required to do so.

Sharing your personal information with others

We may share your personal data with the following entities:

  • other companies with whom we may partner in order to perform our contract with you e.g. website hosts and systems administrators;
  • our group companies including our parent company Croud Inc Ltd (see further under International Data Transfers);
  • financial organisations;
  • our auditors;
  • survey and research organisations;
  • professional advisers and consultants;
  • courts and tribunals;
  • professional bodies.

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or the police or to otherwise comply with the law.

We only allow these third party organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.  We do not allow our third-party service providers to use your personal data for their own purposes unless this is permitted by law. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

International Data Transfers

We operate globally therefore by using our Website and our services, you acknowledge that we may share your personal information with our group companies (Croud Inc. in the US and Croud Australia Pty Ltd in Australia and other third parties outside of the UK . Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring that 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; or
  • 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 by emailing dpo@croud.com if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

Automated decision-making

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.

What are your rights?

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below (Your Legal Rights) to find out more about these rights. If you wish to exercise any of these rights, please contact us by emailing us: dpo@croud.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 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.

Your legal rights

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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Changes to this Privacy Notice

We reserve the right to update this privacy notice at any time, and we will publish and, where appropriate, make attempts to provide you with a new privacy notice when we make any substantial updates. We recommend that you review this notice periodically.

Last updated: 24th December 2024.