Effective Date: [01/10/2024]
At Silver But Savvy (“we”, “us”, “our”), we are committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, and protect your personal data when you use our website and services. Please read it carefully.
1. Who We Are
Silver But Savvy is a membership website for UGC Creators aged 50+ and Marketing Agencies/Brands. We are based in the United Kingdom and are committed to complying with UK data protection laws, including the General Data Protection Regulation (GDPR).
Silver But Savvy is a Trading Style of A Fearn t/a FRUU.co.uk
2. What Data We Collect
We collect various types of personal data from you when you register or interact with our platform:
2.1. UGC Creators
- Personal Information: Name, email address, postal address, payment details.
- Profile Data: Information you provide for your profile, such as a biography, portfolio, skills, and content you upload.
2.2. Marketing Agencies/Brands
- Business Information: Company name, contact person, email address, phone number, business address.
- Job Posting Data: Details of job opportunities posted on the Savvy Job Board.
2.3. General Website Visitors
- Technical Data: IP address, browser type, operating system, and device information.
- Usage Data: Information on how you use our website, including pages viewed, time spent, and navigation paths.
3. How We Use Your Data
We process your data to provide you with the best possible experience on our platform. Specifically, we use your data for the following purposes:
- To Manage Your Account: We use personal data to create and manage your account, process membership payments, and provide customer support.
- To Connect UGC Creators and Agencies/Brands: We use profile and portfolio data to showcase UGC Creators to potential clients and job posting data to help creators find opportunities.
- To Improve Our Services: We use technical and usage data to monitor and improve the performance and functionality of our website.
- To Communicate with You: We may send you service-related emails, such as updates on your membership, platform changes, or new opportunities.
- Marketing (with Consent): We may occasionally send marketing communications about new features, offers, or industry insights, but only with your consent.
4. Legal Bases for Processing
Under GDPR, we rely on the following legal bases to process your personal data:
- Performance of a Contract: To provide our services to you, such as managing your membership and facilitating connections between UGC Creators and Marketing Agencies/Brands.
- Legitimate Interests: To improve and develop our services and platform, or to protect the security and integrity of our website.
- Consent: Where required, such as for sending marketing emails, we will ask for your explicit consent.
5. How We Share Your Data
We respect your privacy and will not sell your personal data to third parties. However, we may share your data in the following circumstances:
- With Other Members: Profile and portfolio data may be visible to Marketing Agencies/Brands as part of your membership as a UGC Creator.
- With Service Providers: We may share your data with third-party service providers, such as payment processors or website hosting providers, to enable the delivery of our services.
- Legal Obligations: We may disclose your data if required to do so by law, or in response to a valid legal request from a governmental authority.
- Business Transfers: In the event of a merger, acquisition, or sale of assets, your personal data may be transferred as part of the business transaction.
6. How We Protect Your Data
We take the security of your personal data seriously. We implement appropriate technical and organisational measures to protect your information from unauthorised access, disclosure, alteration, or destruction, including:
- Encryption: We use encryption to protect sensitive data such as payment details.
- Access Controls: We limit access to personal data to only those employees or third parties who need it to perform their duties.
7. Data Retention
We will only retain your personal data for as long as necessary to fulfil the purposes outlined in this Privacy Policy, or as required by law. Specifically:
- For UGC Creators: We will retain your data for as long as you maintain an active membership.
- For Marketing Agencies/Brands: We will retain your data for as long as you are actively using our platform.
- After Termination: Upon termination of membership, we will delete or anonymize your personal data unless we are required by law to retain it (e.g., for tax or legal purposes).
8. Your Data Rights
As a data subject under GDPR, you have several rights concerning your personal data:
- Access: You have the right to request a copy of the personal data we hold about you.
- Rectification: You have the right to correct any inaccuracies in your personal data.
- Erasure: You have the right to request that we delete your personal data when it is no longer necessary for the purposes for which it was collected.
- Restriction: You have the right to request that we restrict the processing of your data in certain circumstances.
- Data Portability: You have the right to receive your data in a structured, commonly used, and machine-readable format.
- Objection: You have the right to object to our processing of your personal data, particularly for direct marketing purposes.
- Withdraw Consent: Where we rely on your consent for processing, you have the right to withdraw it at any time.
If you wish to exercise any of these rights, please contact us at administrator@silverbutsavvy.com. We will respond to all legitimate requests within one month.
9. Cookies
Our website uses cookies to enhance your browsing experience and gather analytics on website usage.
If you leave a comment on our site you may opt in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.
For more information on how we use cookies, please refer to our Cookie Policy.
10. International Transfers
As we are based in the UK, your data will be processed within the United Kingdom. However, some of our third-party service providers may process data outside of the UK. Where this occurs, we ensure that appropriate safeguards, such as standard contractual clauses, are in place to protect your data.
11. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of any significant changes by email or via the Website.
12.Comments
When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.
An anonymised string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service Privacy Policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.
13. Media
If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website. You must be the copyright owner of the media you upload.
14. Embedded content from other websites
Articles and pages on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.
15. Contact Us
If you have any questions about this Privacy Policy or how we handle your personal data, please contact us:
Email: administrator@silverbutsavvy.com
Address: FRUU, Shardlow Business Centre, No1 Mill, The Wharf, Shardlow, Derby DE72 2GH, United Kingdom