Privacy Policy
Privacy Policy
Effective Date: 30/07/2024
Last Updated: 30/07/2024
At Top Step Marketing, your privacy is important to us. This Privacy Policy outlines how we collect, use, sell, and protect personal data in line with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
1. Who We Are
Top Step Marketing
71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ
Email: hello@topstepmarketing.co.uk
ICO Registration Number:
We are a UK-based marketing company that provides lead generation and marketing data services to third parties.
2. What Data We Collect
We may collect or receive the following types of personal data:
Business Contact Information: Name, job title, company name, email address, phone number, postal address
Industry and demographic data (e.g., sector, location, company size)
Online identifiers such as IP address or cookie ID (for website users)
Publicly available business data from directories, company websites, or social media platforms like LinkedIn
We do not collect sensitive personal data (e.g., health, political opinions, etc.).
3. Where We Source Data
We collect data from:
Direct submissions through forms or interactions
Publicly available sources (e.g., LinkedIn, Companies House, websites)
Business directories
Commercial data providers under lawful agreements
Web scraping tools (compliant with data protection law)
4. How We Use and Sell Data
We use data for:
Providing marketing data lists to our clients
Creating and selling targeted B2B marketing databases
Campaign fulfilment and lead generation services
Internal analytics, platform improvement, and compliance
We sell business contact data to clients who use it for direct marketing (via email, phone, or post). All clients must agree to use the data lawfully and in compliance with applicable marketing laws, including the Privacy and Electronic Communications Regulations (PECR).
5. Legal Basis for Processing & Selling Data
We rely on the following lawful bases:
Legitimate Interests (for sourcing and selling B2B marketing data)
We have a legitimate interest in helping businesses market their products and services to other businesses.
Consent (where required, such as for email marketing to sole traders or partnerships)
Legal Obligation (for compliance, fraud prevention, etc.)
We always conduct a Legitimate Interests Assessment (LIA) before processing.
6. Who We Share Data With
We may share or sell data with:
Verified B2B clients for marketing purposes
Service providers (e.g., email platforms, CRM tools)
Regulatory bodies (if legally required)
We do not sell data to consumers or for non-marketing purposes.
7. International Transfers
Some of our partners may be located outside the UK. In such cases, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs).
8. Your Rights
You have the right to:
Access your data
Object to your data being processed or sold
Request correction or deletion
Restrict processing
File a complaint with the ICO (www.ico.org.uk)
To exercise your rights or opt out of data sale, email us at [Insert Email Address] with the subject: "Data Request – Opt Out".
9. Data Retention
We retain marketing data for no longer than necessary. Data is reviewed regularly and either updated, archived, or deleted.
10. Cookies
We use cookies on our website to analyse traffic and improve user experience. You can manage your preferences through our cookie banner or browser settings.
11. Changes to This Policy
We may update this Privacy Policy from time to time. Updates will be published on our website.
12. Contact Us
Data Protection Officer
Top Step Marketing
71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ
Email: hello@topstepmarketing.co.uk
