Please read this policy carefully to understand how we collect, use and store your personal data.
Ultimate Pole is the trading name of Sultip Investments Limited, a company registered in England and Wales with registered company number 06065394
At Ultimate Pole we take your privacy very seriously and are committed to protecting your personal information.
Or call our team: +44 (0)20 7267 8141
This policy includes:
- How we collect information
- Where we collect information from
- What personal information we collect
- How we will use your personal information
- Children’s data
- How we keep your data safe and who has access to it
- How we keep your information up to date
- Ultimate Pole international
- Your right to your information
- Changes to this policy
- How we collect information
We may collect information about you whenever you interact with us, for example when you:
- Enquire about our activities or services, visit our website or purchase one of our products or services
- Sign up to receive updates on a campaign or our activities
- Create or update a profile
- Post content to our website/social media sites (including Facebook)
- Volunteer for us
- Attend a meeting with us and provide us with information about you
- Take part in one of our events
- Contact us through the following channels: online, email, phone, SMS, social media or post
We may also receive information about you from third parties – but only if you’ve given them permission to share your information.
Where we collect information from
Ultimate Pole may collect information in the following ways:
When you give us information directly: You may provide your details to us when you request specific information, register with our online platform to buy services, purchase products from our retail store or participate in one of our events.
When you have given other businesses/organisations permission to share it: You may have provided your details to another business or organisation that partners with Ultimate Pole. For example, in order to sign up to a third party event, or if you purchased a product via Stripe or Mind Body. However, when working with other organisations, we work to ensure it’s completely clear to you that your information will be shared with Ultimate Pole. The information we get from these services depends on your settings or the response choices you give, so you should regularly check what you have agreed to with third party organisations.
Social media: Depending on your settings or the privacy policies for social media and messaging services like Facebook and Instagram, you might give us permission to access information from those accounts or services.
When your information is available from other public sources: We may collect personal details about you from the public domain, such as from social networks, company websites, political and property registers, and news archives. We may use data services agencies to collect this information. Please see the section below for more details.
What categories of personal information we collect
The type and quantity of information we collect and how we use it depends on why you are providing it.
If you buy or enquire about services or express interest in attending one of our events, we may collect where relevant:
Your contact details (full address, email address and phone number)
Your date of birth
Your bank or credit card details (only if you are purchasing something)
Where it is appropriate, we may ask for your reason for buying services and your specific interests relating to Ultimate Pole’s work.
We carry out targeted marketing activity to ensure that our communication with you is as relevant and timely as possible, and provides the best experience of accessing Ultimate Pole’s services. In doing so, we may supplement what we know about you with information from third party sources to help us better understand your background and ensure any notifications are tailored to you and your interests. This also helps us not to send irrelevant or inappropriate communications to our clients, so that we can operate as cost effectively as possible. These third party sources may provide us with the following information:
Your parliamentary constituency
- An estimate of your age based on publicly available sources
- An estimate of the size and composition of your household
- Information about your interests, including shopping preferences, TV subscriptions and hobbies
- How we will use your personal information
We will use your personal information in a number of ways, including for the following purposes:
- To provide you with the services or information you have requested
- To update you about any changes to our services
- To display your profile or content on the MindBody (if you have agreed to do so)
- To maintain our company records and ensure we have your most up-to-date marketing preferences
- To help us improve our services, campaigns or information-offering
- To invite you to participate in interactive features on our website
- To invite you to participate in voluntary surveys or research
- To analyse and improve the operation of our website
- To analyse your website behaviour
- To tailor advertising that is presented to you on the internet according to your interests, preferences and other characteristics
- To help us work with third parties to ensure that we send you targeted communications (see ‘What categories of personal information we collect’ above)
- To contact you where you have been identified as a contact person for an organisation, such as a school (if we obtain your contact details in this way, we will only use them to contact you in the ways in which you have agreed to be contacted)
If you would like to contact us about your marketing preferences, please write to Ultimate Pole, firstname.lastname@example.org or call us on +44(0)20 7267 8141 – our Admin team will be happy to answer any queries you may have.
We always want you to get the most out of our website, so if you do experience any issues with our online forms we may follow up with you to find out how our team can best support you with any problems experienced.
We may analyse your personal information to create a profile about you, your interests and preferences. In doing this, we may combine information that you have given us with other information about you when it is available (for example, from public records or social media). This may include any of the information listed above (for example, an estimate of your age). This provides background information about our clients and potential clients and helps us to tailor appropriate communications to them, as well as helping us to improve the quality of our clients’ experience with us. We may use third party suppliers to undertake these activities on our behalf and share your data with them only to the extent required (usually full name and postcode). Please rest assured that our suppliers will not share this information with any other organisation and it will only be used for the purposes set out above. Additionally, we may use and disclose information in aggregate (so that no individuals are identified) for marketing and strategic development purposes.
You can opt out of your data being used in this way by calling our Admin team on 020 7267 8141 or by emailing email@example.com.
We may participate in Facebook’s ‘Custom Audience’ programme, which enables us to display ads to our existing clients when they visit Facebook. We provide your email address, mobile number and address to Facebook so they can determine whether you are a registered account holder with them. Our adverts may then appear when you access Facebook. Your data is sent in an encrypted format that is deleted by Facebook if it does not match with a Facebook account.
For more information please see https://www.facebook.com/business/help/744354708981227 and Facebook’s Data Policy at https://en-gb.facebook.com/policy.php.
While we do not actively collect information from children (under 18s), we appreciate that our clients can be of all ages. Where appropriate, we will always ask for consent from a parent or guardian to collect information about children. All Ultimate Pole events will have clear rules on whether or not children can take part, and the collection of data will be managed in accordance with each individual event, with appropriate safeguards in place.
How we keep your data safe and who has access to it
We place great importance on the security of your personal information and will always try to take appropriate precautions to protect it.
We ensure that there are appropriate technical controls in place to protect your personal details. For example, we use encryption technology on our websites and carry out regular security reviews on our network.
We always ensure only authorised personnel (for example Ultimate Pole staff, volunteers or contractors) have access to your information, and that they are appropriately trained to manage your data.
Despite all of our precautions, no data transmission over the Internet can be guaranteed to be 100% secure. So, while we strive to protect your personal information, we cannot guarantee the security of any information you disclose to us online, and you must understand that you do so at your own risk. However, any payment card details (such as credit or debit cards) we receive through our website are passed securely to our payment processing providers who meet the required Payment Card Industry (PCI) Security Standards.
Who we share your personal data with
We may at some point use external organisations that collect and/or process personal data on our behalf. Before working with these companies, we perform rigorous checks to ensure they meet all relevant regulations and legislation. We always implement a contract with our suppliers, which imposes robust GDPR and PECR requirements, including the provisions of this policy, and seeks to provide maximum protection of your personal details.
Financial or technical considerations may occasionally lead us to use the services of a supplier based outside the European Economic Area (EEA), which in turn might lead to your personal information being transferred, processed and stored outside the EEA. If these suppliers are based in countries that European Union authorities do not consider provide adequate levels of protection for personal data, we take steps to provide suitable safeguards to protect your personal information, such as entering into the European Commission approved standard contractual clauses. If you would like to receive further information about our safeguards, please contact our Admin Team.
We may legally be required to disclose your details if required to by the police or for regulatory reasons. We will only ever share your data in other circumstances if we have your consent to do so.
How we keep your information up to date
Where possible, we try to keep your records up to date. However, we really appreciate it if you let us know if your contact details change.
How long we keep your information for
We will hold your personal information on our systems for as long as is necessary for the relevant activity, for example we will keep a record of any purchases you have made for at least six years.
If you ask us to stop sending you marketing materials, we will keep a record of your contact details and appropriate information to enable us to comply with your request not to be contacted by us.
Where you contribute material to us, for example through user generated content or in response to a particular campaign, we will generally only keep your content for as long as is reasonably required for the purpose(s) for which it was submitted, unless otherwise stated at the point of generation.
Our legal basis for processing your information
Although in many cases we will seek consent to process your personal data, in some instances we may process your information without consent when we are legally allowed to do so. This will only be where it is in our legitimate interests to do so and where we are confident that such processing is not likely to prejudice your legitimate interests or rights and freedoms.
Where we are processing your personal data on the basis of consent that you have given us, you are entitled to withdraw that consent at any time such that we can no longer rely on it as a basis for continuing to process your personal information.
Ultimate Pole international
Ultimate Pole UK
Ultimate Pole may legally be obliged to share data in accordance with relevant legislation and potential law enforcement requirements.
You retain control of how we use your data and you have the right to ask us to stop processing your personal information, which we will do. In some circumstances, we may legally be required to retain your personal information for audit purposes. However, this will be discussed with you depending on your requirements. Please contact firstname.lastname@example.org or call us on 020 7267 8141 if you have any concerns.
You also have the right to request a copy of the information we hold about you. If you want to access your information, please contact: The Administrator: email@example.com
Under the General Data Protection Regulation, which is expected to become law in the UK in May 2018, you are also granted a number of additional rights. These include:
The right to rectification
The right to erasure
The right to data portability
The right to object
Rights in relation to automated decision making and profiling
For more information on these rights please read the relevant guidance issued by the ICO at https://ico.org.uk/for-organisations/data-protection-reform/overview-of-the-gdpr/individuals-rights/
If you would like to make a complaint about how we process your personal data, please contact our Admin Team
If you are not happy with how your complaint is dealt with, you should contact the Information Commissioner’s Office. Alternatively, you are entitled to make a complaint to the Information Commissioner’s Office without first referring your complaint to us.
For further information please see the Information Commissioner’s guidance.
This policy may change from time to time. If we make any significant changes to this policy, we will publicise these changes clearly on our website or contact you directly with more information.
Please do revisit this policy each time you consider giving your personal information to Ultimate Pole.