Privacy Policy

Privacy Policy
Last Updated On 01-Jun-2024
Effective Date 01-Jun-2024

This Privacy Policy describes the policies of NitroClicks Ltd (also referred to as "NitroClicks," "TurboTalk," "TurboClicks," "TurboCloud,"  “TurboCharged,” and "TurboSite,") Oxford Science Park John Eccles House, Robert Robinson Avenue, Oxford, Oxfordshire OX4 4GP, United Kingdom of Great Britain and Northern Ireland (the), email: dbo@turboclicks.co.uk, phone: 01865968679 on the collection, use and disclosure of your information that we collect when you use our website ( www.turboclicks.co.uk ). (the “Service”). By accessing or using the Service, you are consenting to the collection, use and disclosure of your information in accordance with this Privacy Policy. If you do not consent to the same, please do not access or use the Service.
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We may modify this Privacy Policy at any time without any prior notice to you and will post the revised Privacy Policy on the Service. The revised Policy will be effective 180 days from when the revised Policy is posted in the Service and your continued access or use of the Service after such time will constitute your acceptance of the revised Privacy Policy. We therefore recommend that you periodically review this page.

Who we are

Company Information

Company legal name:

NitroClicks Limited

Company address:

Oxford Science Park John Eccles House,

Robert Robinson Avenue,

Oxford, Oxfordshire,

United Kingdom,

OX4 4GP

Privacy queries email:dpo@nitroclicks.co.uk

Name of DPO: Jay Savdas

Further information

For further information about cookies and how to disable them, refer to the Information Commissioner’s webpage on cookies: https://ico.org.uk/for-the-public/online/cookies

We may update this Privacy & Cookies Policy from time to time, and if we do so we will highlight any changes to these pages. If you continue to access or use our services after notified changes have come into effect, you will have agreed to the revised policy.

Our Role

When we provide our services to our Customers, we are acting on their behalf as their service provider and processor. If you are a user that is using our service on behalf of one of our customers, your personal data is processed in accordance to:

•    data protection legislation

•    instructions given to us from the Customer

•    the section in our privacy policy that talks about our Customers and

the privacy policy of the Customer, which is made available by them (normally on their website)

Information we collect about you

These are the categories of data we may process:

•    Contact Details: examples include name, email address, telephone number, address.

•    Financial Data: examples include billing address, credit card number, bank account details.

•    Household and Relationships: examples include emergency contact, marital status, next of kin.

•    Identifiers and Legal Documents: examples include passport, national insurance number, proof of residence, national identification number.

•    Activity and Behavioural: examples include friend list, interests, tagged media.

•    Personal Characteristics: examples include sex, nationality, gender, date of birth, cv information, academic qualifications.

•    Location Data: examples include gps location, tracking data.

•    Communications Data: examples include instant messaging data, social media posts, postal content.

•    Images and Recordings: examples include cctv footage, photos, videos.

•    Views and Opinions: examples include survey responses, testimonials, non-political, religious or philosophic opinions.

•    Work-related Data: examples include details of grievance, completed tasks, disciplinary proceedings.

•    Technical Identifiers: examples include ip address, mac address, username, passwords.

•    Aggregated Data: examples include 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.

This is just an overview, please see the next section to see in more detail, exactly what we use.

Legal justifications we rely on to use your data

Company legal name:

NitroClicks Limited

Company address:

Oxford Science Park John Eccles House,

Robert Robinson Avenue,

Oxford, Oxfordshire,

United Kingdom,

OX4 4GP

Privacy queries email:dpo@nitroclicks.co.uk

Name of DPO: Jay Savdas

How your personal data is collected

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

Direct interactions - you may give us information on your Contact Details, Identifiers, and Financial Data... (all the categories that come through direct interactions) by filling in forms or by corresponding with us by post, phone, email, via our website or otherwise. This includes personal data you provide when you:

•    apply for our products or services;

•    create an account with us;

•    subscribe to publications;

•    request marketing to be sent to you; or

•    give us feedback or contact us.

Automated technologies or interactions. - As you interact with our website and services, we will automatically collect Technical, Profile and Usage Data about your equipment, browsing actions, and patterns.

Third parties or publicly available sources. - We might receive personal data about you from various third parties or publicly available sources like the ones set below.

•    Work-related data from services like AngelList or recruiting websites.

•    Identity and Contact Data from publicly available sources such as Crunchbase or other registries.

International Transfers

Some of our external third parties are based outside the UK and EEA so their processing of your personal data will involve a transfer of data outside the UK and EEA. Whenever we transfer your personal data out of the UK and EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

•    the country to which personal data is being transferred has been deemed to provide an adequate level of protection for personal data by the European Commission; or

•    we use specific contracts approved by the European Commission which give personal data the same protection it has in the UK and 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.

Where you have chosen a password that enables you to access certain parts of our applications, you are responsible for keeping this password confidential. We ask you not to share the password with anyone.

Data Retention

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. 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 with respect to our relationship with you.

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.

Automated decision-making and profiling

Your personal data is not used in any automated decision making (a decision made solely by automated means without any human involvement) or profiling (automated processing of personal data to evaluate certain conditions about an individual).

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 to continue 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.

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.