Welcome to Clicky.co.uk and Amplify. We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our websites and tell you about your privacy rights and how the law protects you.
1. Who We Are
This privacy policy is issued on behalf of Clicky Media Ltd (Company Number: 06328880). When we mention "Clicky Media Ltd", "Amplify", "we", "us", or "our" in this privacy policy, we are referring to the relevant company responsible for processing your data.
Amplify is a trading name of Clicky Media Ltd. This privacy policy applies to your use of both the Clicky.co.uk website and the Amplify website (www.amplifyads.co).
If you have any questions about this privacy policy or our privacy practices, please contact us at:
- Email address: [email protected]
- Postal address: 47 Lever Street, Manchester, M1 1FN, United Kingdom
- Telephone number: 0161 515 8953
2. The Data We Collect About You
Personal data means any information about an individual from which that person can be identified. Across both our Clicky Media Ltd and Amplify platforms, we may collect, use, store, and transfer different kinds of personal data about you, which we have grouped together as follows:
- Identity Data: Includes first name, last name, username, or similar identifier.
- Contact Data: Includes billing address, email address, and telephone numbers.
- Google Ads Data: Specifically includes campaign performance, ad spend, keyword data, and other advertising metrics accessed via Google APIs to provide our services.
- Technical Data: Includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our websites.
- Usage Data: Includes information about how you use our websites, products, and services.
- Marketing and Communications Data: Includes your preferences in receiving marketing from us and our third parties, and your communication preferences.
3. How We Collect Your Data
We use different methods to collect data from and about you, including through:
- Direct interactions: You may give us your Identity and Contact Data by filling in forms on either website, or by corresponding with us by post, phone, email, or otherwise (e.g., when you request our services, subscribe to our publications, or request marketing to be sent to you).
- Automated technologies or interactions: As you interact with our websites, we will automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies.
- Third parties or publicly available sources: We may receive personal data about you from various third parties, such as analytics providers like Google based outside the UK, and via direct API integrations with platforms like Google Ads.
4. How We Use Your Personal Data
Under UK GDPR, we will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Performance of a Contract: Where we need to perform the contract we are about to enter into or have entered into with you via Clicky Media Ltd or Amplify.
- Legitimate Interests: Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Legal Obligation: Where we need to comply with a legal obligation.
- Consent: Generally, we do not rely on consent as a legal basis for processing your personal data, except in relation to sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
5. Disclosures of Your Personal Data
We may share your personal data with the parties set out below for the purposes outlined in Section 4:
- We use third-party cloud infrastructure providers (such as AWS or Google Cloud Platform) to store and process the data retrieved via the Google Ads API and other platform services.
- Service providers acting as processors based in the UK who provide IT and system administration services for our platforms.
- Professional advisers including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.
- HM Revenue & Customs, regulators, and other authorities based in the UK who require reporting of processing activities in certain circumstances.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We explicitly do not sell your personal data, including any Google Ads data, to any third parties.
6. Google API Services and Limited Use Policy
To provide our digital advertising management services, Amplify accesses and uses information received from Google APIs. Our use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.
- Specific Use: We access Google Ads data (campaign performance, spend, and keyword data) strictly to provide and improve the Amplify dashboard and automation features.
- No Transfer for Ads: Amplify will not use or transfer Google Ads API data to serve advertisements, including retargeting, personalised, or interest-based advertising.
- No Selling: We do not sell, trade, or lease your Google Ads data to any third parties.
- Human Review Transparency: We do not allow humans to read Google Ads API data unless we have your affirmative agreement for specific troubleshooting, it is necessary for security purposes, or it is required to comply with applicable law.
7. International Data Transfers
We use external third-party service providers, such as Google Workspace and Google Ads, which are based outside the UK. This means their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK Government.
- Where we use certain service providers, we may use specific contracts approved for use in the UK (such as the International Data Transfer Agreement or Addendum) which give personal data the same protection it has in the UK.
- Where providers are based in the US, we may transfer data to them if they are part of the UK Extension to the EU-US Data Privacy Framework, which requires them to provide similar protection to personal data shared between the UK and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
8. 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.
9. Data Retention and Deletion
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.
By law, we have to keep basic information about our customers (including Contact, Identity, Financial, and Transaction Data) for six years after they cease being customers for tax purposes.
Requesting Data Deletion: You have the right to request that your data, including any Google Ads data we have accessed via APIs, be deleted from our servers at any time. To exercise this right, please contact us directly at [email protected].
10. Your Legal Rights
Under UK data protection laws, you have rights in relation to your personal data. You have the right to:
- Request access to your personal data (commonly known as a "data subject access request").
- Request correction of the personal data that we hold about you.
- Request erasure of your personal data.
- Object to processing of your personal data where we are relying on a legitimate interest.
- Request restriction of processing of your personal data.
- Request the transfer of your personal data to you or to a third party.
- Withdraw consent at any time where we are relying on consent to process your personal data.
If you wish to exercise any of the rights set out above, please contact us.
11. Complaints
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.