Effective Date: 21 October 2024

This Privacy Notice (“Notice”) describes how CM Russell Limited (“we,” “our,” or “us”) collects, processes, uses, and discloses personal information obtained through your use of our website (the “Site”), which is available at http://craig-russell.co.uk, as well as our subscription service, ImpactGo (the “Subscription Service”) made available to you through the Site (collectively, the “Services”).

Information We Collect About You

If you create an account with the Subscription Service (a “User”), we may collect personal information from you directly related to creating your account and offering you our Subscription Service. The categories of information we may collect from you include:

  • Full name
  • Job title
  • Email address
  • Password that you create
  • Company name
  • Company address
  • Company website address

Personal Information Provided by Users

We may also collect information about potential Users (names and email addresses) provided by other Users as part of our referral and invitation sign-up processes.

Other personal information collected through the Site.

If you visit our Site, you may navigate the Site without submitting any personal information. However, if you use certain features on the Site we will collect any personal information that you provide through those features.

Server Logs

Server logs automatically record information and details about your online interactions with us. For example, server logs may record information about your visit to our Site or use our Subscription Service on a particular time and date and collect information such as your device ID or IP address.

Cookies

We use cookies on the Site. Cookies are small files that are temporarily stored on your mobile device through the Site. A cookie allows the Site to recognize whether you have visited before and may store user preferences and other information. For example, cookies can be used to collect or store information about your use of the Site during your current session and over time (including the pages you view and the files you download), your device’s operating system, your device ID, IP address, and your general geographic location. To learn more about how we use cookies, and advice on managing your preferences, please review our Cookie Policy.

Pixel Tags

A pixel tag (also known as a web beacon, clear GIF, pixel, or tag) is an image or a small string of code that may be placed in an advertisement or email. It allows companies to set or read cookies or transfer information to their servers when you load a webpage or interact with online content. For example, we or our service providers may use pixel tags to determine whether you have interacted with a specific part of our Services, viewed a particular advertisement, or opened a specific email.

SDKs and Mobile Advertising IDs.

Our Site may include third-party software development kits (“SDKs”) that allow us and our service providers to collect information about your activity. In addition, some mobile devices come with a resettable advertising ID (such as Apple’s IDFA and Google’s Advertising ID) that, like cookies and pixel tags, allow us and our service providers to identify your mobile device over time for advertising purposes.

Third-party Plugins

Our Site may include plugins from other companies, including social media companies (e.g. LinkedIn). These plugins may collect information, such as information about the pages you visit, and share it with the company that created the plugin even if you do not click on the plugin. These third-party plugins are governed by the privacy policies and terms of the companies that created them.

Third-party Online Tracking

We may partner with certain third parties to collect, analyse, and use some of the personal and other information described in this Notice. For example, we may allow third parties to set pixels through the Site. This information may be used for a variety of purposes, including analytics and interest-based advertising, as discussed below.

Aggregated or De-identified Information

We may share aggregated or de-identified information about customers of the Subscription Service, such as by publishing a report on trends in the usage of the Subscription Service. Such aggregated or de-identified information will not identify you personally.

How We Use and Process Your Information

We use the information that we collect for a variety of purposes. Our legal bases for processing your personal information are:

  • our legitimate interest in running and maintaining our business;
  • performance and fulfilment of our contracts;
  • your consent; and
  • compliance with our legal obligations. In many instances, more than one of these legal bases apply to the processing of your personal information.

The purposes for which we may use your information include to:

  • Provide you with our Subscription Service
  • Respond to your questions or requests concerning the Subscription Service
  • Fulfil the terms of any agreement you have with us
  • Fulfil your requests for our Subscription Service or otherwise complete a transaction that you initiate
  • Send you information about our Subscription Service and other topics that are likely to be of interest to you, including newsletters, updates, or other communications, including promotional emails
  • Deliver confirmations, account information, notifications, and similar transactional or operational communications
  • Improve your user experience and the quality of our products and Subscription Service
  • Comply with legal and/or regulatory requirements
  • Aggregate and de-identified information
  • Serve advertisements
  • Analyse how visitors use the Services and various features, including to count and recognize visitors to the Site
  • Create new products and Services
  • Manage our business

Information We Process on Behalf of Customers When They Use the Subscription Service

The Subscription Service allows our customers to collect, analyse, and report relevant social impact data. When customers use our product, they may collect personal information such as first and last name, email address, or other information about a user.

We do not control the types of personal information our customers may choose to collect or manage using the Subscription Service. We store our customers’ information on our service providers’ servers but process it as a processor under our customers’ instructions and in accordance with our Terms and Conditions, which prohibit us from using the information except as necessary to provide and improve the Subscription Service and as required by law.

Our customers control and are responsible for correcting, deleting, or updating the information they process using the Subscription Service and for complying with any regulations or laws that require providing notice, disclosure, and/or obtaining consent prior to transferring the personal information to us for processing purposes.

Information We Process When You Use the Subscription Service

Usage Data

We collect usage data when you interact with the Subscription Service. Usage data includes metrics and information regarding your use and interaction with the Subscription Service such as what product features you use the most and server log information.

Mobile

When you use, access, or interact with the Subscription Service via a mobile device, we automatically collect information such as your device model and version, operating system, or device identifiers.

With Whom and Why We Share Your Information

We may share your information with third parties for a variety of purposes, as described below.

Referring to Third Parties

If you were referred to us by another user who has requested access to data held by your organisation (a “Referring Third Party”), the information you input through the platform may be shared with the Referring Third Party.

Third-party Service Providers

We use third-party service providers that perform services on our behalf, including web-hosting companies, and mailing vendors. These service providers may collect and/or use your information, including information that identifies you personally, to assist us in achieving the purposes discussed above.

We may also share your information with third parties when necessary to fulfil your requests for Services; to complete a transaction that you initiate; to meet the terms of any agreement that you have with us or our partners; or to manage our business.

Analytics

We partner with certain third parties to obtain the automatically collected information discussed above and to engage in analysis, auditing, research, and reporting. These third parties may use pixels or server logs, and they may set and/or access device IDs and IP addresses from your device.

We may use or share your information with third parties when we believe, in our sole discretion, that doing so is necessary:

  • To comply with applicable law or a court order, subpoena, or other legal process
  • To investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our terms and conditions, or situations involving threats to our property or the property or physical safety of any person or third party
  • To establish, protect, or exercise our legal rights or defend against legal claims
  • To facilitate the financing, securitization, insuring, sale, assignment, bankruptcy, or other disposal of all or part of our business or assets

Your Choices

If you wish to opt-out of marketing emails you receive from us, you may do so by following the instructions in those emails or by contacting me at craig@craig-russell.co.uk.

If you are a resident of the EU, UK, or another jurisdiction with an applicable privacy law, you may have certain rights available to you. These rights may include:

  • The right to be informed about our data collection practices
  • The right to access and rectify your data
  • The right to erase or delete your data
  • The right to data portability
  • The right to restrict and object to the processing of your data (including for direct marketing purposes)
  • The right to opt out of the sale of your information
  • The right to opt-out of marketing emails and text messages
  • The right to limit our use of any automated decision-making processes
  • The right to lodge a complaint to your local data protection authority
  • The right to withdraw consent (to the extent applicable)

To exercise any of the rights listed above, please contact me via email at craig@craig-russell.co.uk.

We will respond to your request as soon as reasonably possible but no later than 30 days after receipt.

The Site may contain links to third-party websites. If you use these links, you will leave the Site. We have not reviewed these third-party sites and do not control and are not responsible for any of these sites, their content, or their privacy policy. Thus, we do not endorse or make any representations about them, or any information, software, or other products or materials found there, or any results that may be obtained from using them. If you decide to access any of the third-party sites listed on our website, you do so at your own risk.

Data Security

We employ physical, technical, and administrative procedures to safeguard the personal information we collect both online and offline. However, no website or platform is 100% secure, and we cannot ensure or warrant the security of any information you transmit to the Services or to us, and you transmit such information at your own risk to the fullest extent permitted by applicable law.

Data Retention

We retain personal information about you necessary to fulfil the purpose for which that information was collected or as required or permitted by law. We do not retain personal information longer than is necessary for us to achieve the purposes for which we collected it. When we destroy your personal information, we do so in a way that prevents that information from being restored or reconstructed.

International Users

The information that we collect through or in connection with the Services is transferred to and processed in the United Kingdom for the purposes described above. We may also subcontract the processing of your data to, or otherwise share your data with, affiliates or third parties in countries other than your country of residence. The data-protection laws in these countries may be different from, and less stringent than, those in your country of residence. However, we comply with all applicable laws regarding international data transfers. ‍ By using our Services or by providing any information to us, you expressly consent to such transfer and processing.

Children

Content on the Services is not directed at children under the age of 18. We do not knowingly collect personally identifiable information from children under the age of 18. In the event that we discover personal information from a child under the age of 18 has been collected, we will promptly take all reasonable measures to delete that information from our systems.

If you are a parent or guardian and believe that your child has provided us with personal information without your consent, please contact me at craig@craig-russell.co.uk, and we will work diligently to remove such information.

Changes to this Notice

We may make changes to the Services in the future and as a consequence may need to revise this Notice to reflect those changes. We will post all such changes here, so you should review this page periodically.

How to Contact Me

Should you have any questions or concerns about this Notice, you can contact me by email at craig@craig-russell.co.uk.