Last updated 8 August 2024

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PR Manager Privacy Policy

PRgloo Limited (‘PR Manager Product“) respects the personal information (such as title, name, telephone number, email address, etc) of people from whom it collects information and complies with the General Data Protection Regulation (EU 679/2016) (GDPR)/UK (GDPR).

We ask that you read this privacy notice carefully as it contains important information on:

  • Who we are
  • How and why we collect, store, use and share personal information
  • Your rights
  • How to contact us and supervisory authorities in the event you have a complaint
  • The transfer of your personal information out of the EEA
  • Marketing
  • Keeping your personal information secure
  • Changes to our website’s privacy policy

 

1. Who We Are

Onclusive PR Manager is a cloud-based software platform based in the UK with its registered address at Fora Montacute Yards, 186 Shoreditch High Street, London, E1 6HU. Onclusive PR Manager collects, uses and is responsible for certain personal information it collects about you. When we do so, we are regulated under the retained EU law of the General Data protection Regulation ((EU) 2016/679)(UK GDPR) and the Data Protection Act 2018. This means, we are responsible as ‘controller’ and the “processor” of that personal information with respect to these laws.

 

2. What is Onclusive PR Manager?

The Onclusive PR Manager platform is used by communication professionals across the globe to provide customers with tools to manage media enquiries, statements, send press releases, research journalists, manage stakeholders and all of their day-to-day and strategic tasks. Onclusive PR Manager is used by hundreds of organisations including central and local governments, public and private sector companies, and thousands of communication professionals.

 

3. The Personal Information We Collect

a) Information collected by us:

In the course of providing our business, we currently collect and process the following information about you but only after we have carried out a careful assessment as to whether we think that you would be interested in having news and information communicated to you about topics we believe may be of interest to you.  If, after our assessment, we believe you would be interested, we collect (where possible) the following information from public and professional sources.

Please note: 

  • We only add contacts to our database if they are currently working within the media
  • When researching contact details, we use the information provided by the journalist themselves (on their websites, social media profiles etc), by the publication the journalist works for (normally the „contact us“ section) or by a reputable news gathering source. We do not use leaked documents,  documents which were intended to be private or documents relating to a journalists private life.
  • When researching a journalist and the information made available about them is too scarce for us to put together a decent profile, we will contact the journalist via email, phone or social media to ask if they would like to be part of the database and if so, what information should we display on their profile.

Information we store:

  • Name
  • The publications /outlets you work for
  • Professional email address
  • Professional phone number
  • Professional mobile number
  • LinkedIn profile (link only)
  • Instagram page (link only)
  • Professional website or author profile page from your publication (link only)
  • Facebook page (link only)
  • Twitter profile (link only)
  • Country in which you operate
  • Our best approximation of the geographical reach of the articles you write
  • The subjects you write about (taken from your past article history or from your stated interests or both)
  • The types of publications you write for (magazines, B2B, newspapers etc)
  • Your preferred contact method (including „does not accept press releases“) and
  • A collection of summarised articles, which you have written (if available) over the past 60 days.
  • If a customer or Onclusive PR Manager sends you an email via the Onclusive PR Manager system, then we may record whether this email has been opened, clicked on, or has had a failed delivery.

 

b) How and why we collect your personal information

We use our own in-house researchers to research and collect data about professionals currently working within the media. We collect this data to provide an updated database of media contacts to be used by our customers. Our customers are PR and communication professionals, who communicate news and updates to the journalist community via email, social media, face to face or over the phone using data from the professional profiles of the journalists which Onclusive PR Manager collects, or which is offered to us by the journalist.

The personal information we process is either:

  • Directly provided by you for the purpose of being added to our journalist contact database
  • Collected from publicly available sources
  • Obtained through the work of our own in-house research team
  • Suggested to us by our customers
  • Automated from our mail service providers (SendGrid) – limited to whether an email which was sent to you was delivered, opened, clicked on or failed.

Please note: the information we collect is business-to-business information

c) We use personal information to:

  • Provide your contact details to our customers who may need your services and who may contact you for those
  • Verify your identity
  • Understand what type of news you would like to be contacted about (where possible)
  • Ensure your details are kept up to date (EG if an email to you fails, our researchers will ensure that your record is updated)

 

d) Who we share your personal information with?

We share your data with our customers who need to communicate with the media.

We also share personal information with law enforcement or other public authorities and regulators if and where this is required by law.

As we operate globally, we may share your information with third-party recipients who may be based outside the European Economic Area in order for us to be able to provide our services to our clients and to you.

e) Whether information has to be provided by you, and if so why.

Onclusive PR Manager uses „Legitimate Interest“ as the legal basis for adding contact information into our journalist contact database as we believe that the information our customers provide to the journalist community (news and information) is needed by journalists in their professional capacity. Because we use Legitimate Interest and not Consent, we also take appropriate steps to ensure that data subjects are made aware of the fact that we have processed their data, give them access to our privacy policy and give them the option to object, ask questions or tailor their profile. For more information, please see below section „Right to be Informed“ 

f) How we store your personal information

Your information is securely stored in UK datacentres managed by Microsoft Azure.

g) How do we keep your data up to date?

Data is only as good as the systems in place to keep it up to date. We rely heavily on 5 methods:

  • Twitter: if a Twitter bio changes, then we will automatically review your profile. This often lets us know that you have moved publications or out of journalism altogether.
  • Email Issues: If a release sent by any of our customers fails to reach you, then we review this profile immediately.
  • Customer alerts: if a customer alerts us to the fact that you have moved then we will review this profile immediately.
  • Our own research: if we are not able to keep track of a contact via above means, we will also create reminders to review each contact on the platform no longer than once every 3 months.
  • Email distribution issues: If any customer sends a release to a journalist, and that email fails, our research team will immediately research the journalist profile to see if they have moved jobs or moved out of journalism. Either way their record will be updated.

 

h) How long your personal information will be kept

We will hold your personal data in accordance with applicable laws and for as long as we are able to determine that you are still engaged in journalism. If we determine that you are no longer in journalism, (for example if you have no new articles appearing for 6 months or more) then we will mark your record as „ex-journalist“, delete all email and phone records and set a reminder to review your profile in 6 months‘ time.

At the end of 6 months, if you are still no longer active in journalism, we will delete your details completely from our systems. We will also delete your information upon receiving a request from you to do so.

i) Reasons we can collect and use your personal data

We rely on a combination of legal bases to collect, use, process and store your personal data. These include consent (which we may collect from you when we email you to confirm if your details are correct and if you consent to us holding your data) and legitimate interests. Should you require more information on these please contact our Data Protection Officer (see below “How to contact us”).

j) Transfer of your personal information out of the EEA

GDPR (UK GDPR) permits the transfer of personal data out of the EEA and UK so long as safeguards are in place.

To provide our services, we may transfer the information we collect to countries outside of the EEA which may not provide an adequate level of data protection similar to that which applies in the country in which you may be living, and which may not be recognized by the European Commission as providing the same level of data protection.

In such cases we transfer subject to safeguards being in place such as the European Commission’s Standard Contractual Clauses (“SCC”) and the UK’s equivalent of those.

If you would like further information, please contact us, or our Data Protection Officer (see below “How to contact us”).

 

4. Your rights

Under the UK (GDPR), you have several important rights. In summary, those include rights to:

a) Unsubscribe / object to processing

You have the right to unsubscribe/right to object to processing. Specifically you have the right

  • To object to our contacting, you to add you to our database or update your details
  • To object to our processing of your information
  • To withdraw your consent to our use of your information
  • The right of erasure
  • The right to restriction of processing

 

b) Our contact details for exercising your right to unsubscribe/rights to object to processing

You can exercise your opt-out rights/rights to object to processing by filling in this simple form: https://onclusive.typeform.com/dataprotection

This will allow you to opt out of the Onclusive PR Manager database. If you would simply like to unsubscribe from any news which one of our customers send to you, then you can click the unsubscribe link on the email send to you.

Please note that complete deletion from our database means that you may be contacted again in the future. This could happen where for example if a researcher adds you back into our live database because they have found your online presence to be active. Instead we can mark you as „consent withheld“ which means your contact details (email, phone etc) will be excluded from your profile so that our customers do not contact you.

c) Your right to object to our adding your details to our database for our customers.

You have the right to object at any time to our processing of personal data concerning you, for the purposes of adding your details on our contact database and making these available for our clients who may be interested in your services.  You can object to this kind of processing by clicking the link provided below or using the contact details provided at paragraph 8 of this privacy policy.

https://onclusive.typeform.com/dataprotection

d) Your right to object to processing on the basis of a legitimate interest

If we are processing your data, on the basis of our legitimate interests, you have the right to object at any time on grounds relating to your particular situation.

If you object, we will cease to process the data unless we have compelling legitimate grounds to continue to do so or need to continue to process the data for the establishment, exercise, or defence of legal claims.

You can object to this kind of processing by clicking the link provided below: https://onclusive.typeform.com/dataprotection

e) Your right to Withdraw Consent

If you have given us consent to use your personal data, you have the right to withdraw that consent at any time. You can withdraw consent by clicking here https://onclusive.typeform.com/dataprotection

f) Your right of Erasure

You have the right to require us to erase your personal data without undue delay where:

  • The data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
  • You have withdrawn your consent on which the processing is based and there is no longer any legal ground for the processing;
  • You exercise your right to object to the processing when that processing is based on legitimate grounds, or you exercise your right not to be subject to a decision based solely on automated processing (these rights are explained elsewhere in this policy);
  • The personal data have been unlawfully processed (of course we have no intention of carrying out any unlawful processing and do our utmost to avoid any unintended unlawful processing); or
  • The personal data have to be erased for compliance with a legal obligation to which we are subject.

You can exercise this right by clicking the link below: https://onclusive.typeform.com/dataprotection

g) Your right to Restriction of Processing

You have the right to in certain circumstances to require us to restrict processing of your data. The right applies:

  • During a period enabling us to verify data which you have said is inaccurate;
  • Where the processing is unlawful, and you oppose the erasure of the personal data and request restriction of its use instead (of course we have no intention of carrying out any unlawful processing and do our utmost best to avoid any unintended unlawful processing);
  • When we no longer need the personal data for the processing, but you need the personal data for the establishment, exercise, or defence of legal claims; and
  • You have objected to processing based on a legitimate interest for a period to enable us to verify whether our legitimate interests override yours.

If you exercise that right, processing of your personal data will be limited to:

  • storage;
  • processing to which you have consented; and
  • processing for the establishment, exercise or defence of legal claims, the protection of the rights of others or for reasons of important public interest.

You can exercise this right by filling out this form: https://onclusive.typeform.com/dataprotection

h) Your right to fair processing of information and transparency over how we use your personal information.

i) Your right to access to your personal information. Please provide enough information to identify yourself; you may make such a request by emailing via the e-mail address provided below:

dpo@prgloo.com

j) Your right to require us to correct any mistakes in your information which we hold. You can request us to rectify and correct any personal data that we are processing about you which is incorrect by contacting us at  dpo@prgloo.com We will update your personal details and keep your data accurate.

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office on individual rights under the UK (GDPR).

 

5. keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach within 72 hours where we are legally required to do so.

You should also note that whilst we use all our efforts to protect your privacy and data, we cannot ensure or warrant the security of any information you transmit to us over the internet because no method of transmission over the internet or method of electronic storage can be guaranteed to be absolutely secure.

 

6. Right to be Informed

PR Manager uses „Legitimate Interest“ as the legal basis for adding contact information into our journalist contact database as we believe that the information our customers provide to the journalist community (news and information) is needed, wanted and expected by journalists in their professional capacity.

Art 14 requires specified information to be provided to the data subject when the data is not obtained from the data subject.

Because of this, we also take appropriate steps to ensure that data subjects are made aware of the fact that we have processed their data giving them access to our privacy policy, the option to object, ask questions or tailor their profile via our Right to Be Informed communication process.  This process takes the following form:

  1. PR Manager researcher researches a contact
  2. PR Manager determines whether this contact should be added to the database or not (using the legitimate interest test)
  3. If the contact is added to the database, and the contact has an email address, the researcher will send a „Right to be Informed“ email to the data subject telling them that we have added them to our database, telling them how to object, how to tailor their profile, providing a link to our privacy policy and how to ask questions
  4. If the contact is added to the database and they do not have an email address but they do have a Twitter account with Twitter DMs open, then we will send this information that way instead.
  5. If the contact is added to the database and they do not have an email address, Twitter account where we can directly contact them, then we will try other methods (LinkedIn or a mention on a social media channel) however this is very dependent upon the data subject being active on these other channels. If we are unable to provide the Right to be Informed data proactively, then we ensure that if any of our customers sends them an email, that the email footers always contain a link to this privacy policy which includes all of this information.
  6. On a regular basis we will review all contacts whom we were unable to contact with this information so that if the situation changes (and we are able to locate an email address or other direct form of communication via a social media channel), then we will immediately send this information.

 

7. How to complain

We hope that we can resolve any query or concern you raise about our use of your information. Should you wish to file a complaint with us, you may email us at dpo@prgloo.com  and we will investigate your complaint in accordance with our complaint process. If you are still not satisfied, you have the right to make a complaint at any time to the Information Commissioner’s Office (office details provided below).

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the United Kingdom is the Information Commissioner’s Office (ICO)  which may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.

The ICO’s address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, Helpline number: 0303 123 1113, ICO website:

https://www.ico.org.uk

 

8. Changes to this website privacy policy

If we make changes to this privacy policy that we consider to be important we will let you know by placing a notice on our website. You may also wish to check this policy from time to time for any updates.

 

9. How to contact us

If you have any questions about this Privacy Notice you can contact us in the following ways:

Write to us: Data Protection Officer, 7 Bell Yard, London, WC2A 2JR
Email our Data Protection Officer: dpo@prgloo.com

PRgloo’s registered office is Fora Montacute Yards, 186 Shoreditch High Street, London, E1 6HU
Registered in England and Wales under the company number: 08984741
ICO registration number is: ZA076809

 

10. Do you need any extra help?

If you would like this website policy in another format (for example audio, large print, braille) please contact us (see “How to contact us above”).

 

PRgloo Limited