PRIVACY AND COOKIES POLICY OF MANIFEST NEW BUSINESS LIMITED
1. Introduction
This Privacy & Cookies policy explains the Privacy & Cookies policy of Manifest New Business Limited (“Manifest”), Company No. 09723557, whose registered address is Manifest New Business Limited, First Floor Gallery Court, 28 Arcadia Avenue, London N3 2FG.
Manifest’s primary line of business is to assist clients (primarily marketing agencies) build relationships with brands they’re interested in working with. Specifically, Manifest will support clients with strategic planning, and then offer direct advocacy to help clients arrange meetings with brand decision-makers.
Manifest is committed to protecting and respecting your privacy. Where we decide the purpose or means for which personal data supplied by you or us is processed, we are the “data controller.”
Manifest is committed to ensuring that all data processing is: -
a) processed lawfully, fairly and in a transparent manner;
b) collected for specified, explicit and legitimate purposes;
c) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
d) accurate and, where necessary, kept up to date;
e) kept in a form which permits identification of data subjects for no longer; than is necessary; and
f) processed in a manner that ensures appropriate security of the personal data.
The purpose of this document is to explain how Manifest will use your personal information when interacting with us. We have deliberately attempted to write this privacy policy in clear, easy-to-understand language. If anything about it isn’t clear, please email us info@manifest.agency and we will get back to you with clarification.
We may choose to make changes to this Privacy Policy at any time, to ensure compliance with applicable laws and industry regulations. Please ensure that you review this document from time-to-time to ensure you are familiar with the latest changes. These changes are effective immediately, after they are posted on this page.
2. Collection of personal information
Why do we collect personal information about you?
The reason we chose to collect and process personal information depends on your relationship with Manifest: -
Brand: If you are a marketing, HR or IT decision-maker at a brand (for example a Marketing Director at a bank, or Head of IT at a retail business), we may collect and process personal data on you as part of the work we perform on behalf of our clients. The objective of Manifest is to help our clients connect and ultimately build relationships with businesses they are interested in working with in a more effective manner.
Client: If you are a client of Manifest, we collect and process personal information in order to most effectively deliver our services.
Prospect: If you are a Prospect (a business that we believe is likely to benefit from using Manifest’s services), we may collect and process personal data on you as part of our efforts to sell, promote and market our services to you.
Supplier: If you are a supplier to Manifest, we collect and process personal information as part of our contractual relationship with you.
How do we collect personal information from you?
Information may be collected in the following ways: -
a) Face-to-face (e.g. in an interview)
b) Phone (e.g. in a telephone conversation with one of our account executives)
c) Email
d) Desk research (in this case, only publicly-available personal information is processed) –e.g. we may find and store information that you have posted on LinkedIn)
f) Post (e.g. we may record data that you send to us by post)
g) From Cognism, whose GDPR compliance guide can be found HERE.
What type of information is collected?
The types of data we will collect on may include: -
Contact Data: your name, corporate email address, workplace address.
Research Data: Written records/notes of conversations that you have had with our account executive and commercial team; publicly-available information such as that which you have posted on LinkedIn or which is available on a corporate website; contact information, reports and research supplied by third parties, detailing your supplier preferences and business challenges; job history.
Correspondence Data: records of emails that we have sent you/you have sent us.
Financial Data: your payment information and transactions, including your payments to us.
Analytics Data: your IP address or other device identifier, technical log information (as described below under the subheading “Log Data”) cookies (as described below under the subheading “Cookies”), and information about how you use our website.
All data collected and processed by Manifest is ‘corporate’ or ‘business to business’ data.
Manifest has trained its staff to ensure that no ‘special categories’ or personal data (e.g. the ethnicity, or religious beliefs of data subjects) are collected and/or processed.
Manifest does not collect or process personal data on children.
Grounds of processing
The table below explains the ways in which we use your personal data and the legal grounds for that processing. Please contact us at info@manifest.agency if you would like further information about the relevant legal grounds.
Research and business development we carry out for our clients
Our clients engage us to help them carry out research, and connect and ultimately build relationships with businesses they are interested in working with in a more effective manner.
As part of our work, we obtain and use Research Data (including Research Data, and Contact Data regarding the subjects of that Research Data, collected from third party sources, such Zoominfo) on behalf of our clients, and in accordance with their instructions. Our clients decide the means and purpose of our processing of Research Data, and our clients are the data controller in respect of that processing. If you have any questions regarding this processing, please either get in touch with us, or contact the business who engaged us.
We are careful not to process any sensitive or special categories of personal information, and restrict data processing to corporate (B2B) data.
How is your information used?
We use your information for a variety of reasons, depending on the nature of your relationship with us, including: -
a) to deliver the service that you have agreed to effectively;
b) to make a decision on whether or not to try and sell our services to you; and
c) to deliver a tailored programme of account management;
d) on behalf of our clients, we use Research Data (including Contact Data regarding the subjects of such Research Data) to connect our clients with prospects as part of their business development initiatives.
3. Your rights
You have the following rights over the way we process personal data relating to you. We aim to comply without undue delay, and within one month at the latest.
Controlling personal information that we hold on you
As a data subject, we acknowledge that you have a right to control whether or not we collect and process personal data on you, and to ask for us to stop processing/delete data that we hold.
Manifest is committed to ensuring that we process personal data in line with your wishes, so please tell us if you’re unhappy with us holding any of the data that we do. You can do this: -
Write to us: Manifest New Business Limited, First Floor Gallery Court, 28 Arcadia Avenue, London N3 2FG
By email: Please email info@manifest.agency
We will ensure that any requests for personal data to be deleted, are actioned within 2 business days of the request being received.
Keeping the data we hold on you up to date
We endeavour to keep the information that we hold on you as up-to-date as possible. If you find that any data we hold is not up-to-date or, you receive a communication from us that includes incorrect information, please alert us by emailing info@manifest.agency
Ask for a copy of data we are processing about you and have inaccuracies corrected
You have the right to request a copy of the personal information we hold about you and to have any inaccuracies corrected.
We will use reasonable efforts to the extent required by law to supply personal information held about you on our files (and with any third parties to whom it has been disclosed to).If we are processing data in order to perform our obligations to you, or because you consented, if that processing is carried out by automated means, we will help you to move, copy or transfer your personal data to other IT systems.
4. Cookies
Cookies are files that include very small amounts of data, commonly used as an anonymous unique identifier. These are transmitted to your web browser from the web page that you have visited, and may subsequently be stored on the hard drive of the computer (or other device) that you are using.
When you first access our website, you will notice a pop-up message informing you about our collection of Cookies and usage of them to improve our website. This message will allow you to either accept or refuse. If you select the latter, you may find it difficult to optimally use some portions of our website.
Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit http://www.aboutcookies.org or http://www.allaboutcookies.org.
To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.
5. Email marketing & newsletters
From time-to-time we may send you content via email that we believe is likely to be of interest to you.
For companies that we believe are likely to be interested in our services (marketing/PR agencies; digital and design agencies; technology providers) we may from time to time decide to send you information by email, post or phone that we believe will be of interest to your role.
This information may include extracts of research that we have done, or the opportunity to speak with our team to discuss Manifest’s services (if you’re not interested in receiving these communications, please let us know).
For both this activity, we use an email distribution engine called Hubspot and Lemlist. Please consult
Hubspot's Privacy Policy for more information: https://legal.hubspot.com/privacy-policy
Lemlist's Privacy Policy for more information: https://www.lemlist.com/privacy-policy
We are careful to ensure that all email correspondence sent out by Manifest includes a clear ‘unsubscribe’ link, and have a robust internal policy in place to deal with unsubscribe requests we may receive from stakeholders.
6. Data Security
The organisation uses software countermeasures and management procedures to protect itself against the treat of malicious software. All staff are trained to co-operate with this policy.
The Manifest website is hosted in a secure data centre, which meets both ISO 27001 and ISO 27002 standards, as well as being in possession of an in-depth Business Continuity (BC) plan. While the data centre is also PCI-DSS compliant, this is currently irrelevant due to the website not processing e-commerce payments.
While we take reasonable steps to maintain secure internet connections, if you provide us with personal information over the internet, the provision of that information is at your own risk.
7. Log Data
For those clients and former-clients who have previously clicked on a link in one of our email newsletter communications, we are keen to inform you that we may collect information that your browser sends (referred to above as Log Data). This may include information such as your device’s IP Address, browser type and version, pages of the Service that you access, the time and data that such activity takes place, time spent on each pages, the entry and exit points of your browsing session, and other data.
We work with a number of recognised third party providers – including Google, Zoominfo, Hubspot and Lemlist – to ensure that this data is collected and stored in a secure manner.
Privacy policies of these organisations can be found here: -
Google: https://policies.google.com/privacy?hl=en-GB&gl=uk
Hubspot: https://legal.hubspot.com/privacy-policy
Lemlist: https://www.lemlist.com/privacy-policy
The reason for such activity – which will be reviewed from time to time – is to improve your experience of the Services.
8. Retention of data
Manifest may retain data for differing periods of time for different purposes as required by law or best practices. However, under no circumstances will we retain your personal data for a period of longer than five years (from the point of collection, or updating) unless there is a critical business reason to do so (for example, we may need to maintain records of invoices issued to you for longer than this for accounting reasons).
We would be happy to provide a copy of our data retention policy if you’re interested in receiving more information on this point.
9. Public website
All elements of https://manifest.agency/ (the ‘Public Site’) are hosted on a web content management system called Wordpress.
We may from time to time collect anonymous data on usage patterns on the public website. Please view Wordpress's Privacy Policy here: https://en-gb.wordpress.org/about/privacy/
10. Links to Other Sites
Our Service may contain links to other sites. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by us. Therefore, we strongly advise you to review the Privacy Policy of these websites. We have no control over, and assume no responsibility for the content, privacy policies, or practices of any such third-party sites or services.
11. If you email us
We work closely with a third party IT support business (London Systems) to encrypt and protect email traffic in line with government advice. If your email service does not support TLS, please be aware that any emails we may send/receive may not be fully protected after we have sent them to you.
We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware you have a responsibility to ensure that any email you send is within the bounds of the law.
12. The personal information of children
Our Services do not address anyone under the age of 13. We do not knowingly collect personal identifiable information from children under 13. In the case we discover that a child under 13 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to do necessary actions.
13. International Data Transfers
Your Personal Information which you supply to us is generally stored and kept inside the European Economic Area (EEA), however due to the nature of our global business and the technologies required, your Personal Information may be transferred to third party service providers outside the EEA, in countries where there may be a lower legal level of data protection.
Where we transfer your data outside of the EEA, we transfer the minimum amount of data necessary, anonymise it where possible and we have agreements in place with those parties which include standard data protection clauses to ensure that appropriate safeguards are in place to protect your personal data in accordance with this Privacy Policy and the European levels of data protection. If you would like to find out more about these safeguards, please contact us.
14. Complaints
If you are unhappy with the way we are processing your personal data, please let us know.
If you do not agree with the way we have processed your data or responded to your concerns, or if you do not think we are handling your personal information adequately, you have the right to lodge a complaint with the Information Commissioner's Office. Further information, including contact details, are available at https://ico.org.uk.
15. Contact us
If you have any questions or suggestions about our Privacy Policy, please do not hesitate to contact us (please write to us at Manifest New Business Limited, First Floor Gallery Court, 28 Arcadia Avenue, London N3 2FG or email us at info@manifest.agency.
Manifest
