Proactive Presence is a trading name of Blagdon Associates S.L., a company established in Andorra (“Proactive Presence”, “we”, “us” or “our”).

We take the privacy and security of personal information seriously. This Privacy Policy explains how we collect, use, store and protect personal data when you visit our website, communicate with us, use our services, or when information is processed through systems connected to the Proactive Presence platform.

This policy is intended to reflect the principles and requirements of the EU General Data Protection Regulation (“GDPR”) and, where applicable, the UK General Data Protection Regulation (“UK GDPR”) and relevant data-protection legislation.

1. Who we are

Proactive Presence provides reputation management, customer feedback, analytics, automation and business intelligence services to businesses.

Data controller: Blagdon Associates S.L.

Trading as: Proactive Presence

Privacy enquiries and data rights requests:

Please use our Privacy Request Form. You may also contact us in writing at our registered address.

Registered address: Av de les Nacions Undies, 40, Escaldes-Engordany AD700

For some processing activities, Blagdon Associates S.L. acts as a data controller. For others, particularly where we process information on behalf of a business customer, we may act as a data processor and the business customer remains the data controller.

2. Information we collect

The personal data we process depends on how you interact with Proactive Presence and which services are enabled.

Website and enquiry information

When you visit our website, contact us or request information, we may collect:

• Your name

• Business name

• Job title or role

• Email address

• Telephone number

• Information you provide in forms or communications

• Technical information associated with your visit or enquiry

Client and account information

When a business becomes a Proactive Presence client, we may process information including:

• Business and location details

• Names and contact details of authorised users

• Account and subscription information

• Service configuration

• Support and service communications

• Billing and transaction information

• Information required to administer connected services

Reviews and customer feedback

Our services may receive or process reviews and feedback originating from third-party platforms or systems connected by our clients.

This information may include:

• Reviewer name or publicly displayed identifier

• Star rating or other rating

• Review text

• Date and time of the review

• Review source

• Business or location associated with the review

• Publicly available review identifiers or URLs

• Responses to reviews

• Other information supplied by the originating review platform

• Reviews may contain personal information that an individual has chosen to include in their review.

Customer feedback and surveys

Where clients use Proactive Presence to collect customer feedback, we may process:

• Survey responses

• Ratings

• Comments

• Contact information where requested and provided

• Business location or service information

• Dates and times associated with feedback

• Relevant consent or communication preferences

Connected systems and integrations

Proactive Presence can connect to third-party business systems.

Depending on the services enabled, we may receive information such as:

• Business and location identifiers

• Customer reviews and feedback

• Contact or customer information required for an enabled service

• Integration identifiers and configuration

• Authentication and authorisation information

• Operational events generated by connected systems

We seek to limit access to information reasonably necessary to provide the services enabled by the client.

3. Proactive Presence integrations

Clients may authorise Proactive Presence to connect with supported third-party business platforms.

These integrations allow information required for subscribed services to be exchanged securely between the connected platform and Proactive Presence.

For example, an integration may allow us to receive customer reviews so that they can be:

• Associated with the correct business and location

• Monitored and analysed

• Presented in reputation dashboards

• Used to support review-management workflows

• Included in reputation and customer-experience reporting

Authorising an integration does not mean that Proactive Presence will intentionally access every category of information available through the connected platform. We aim to request and use only the permissions and information required for the relevant services.

Clients may request that an integration is disconnected.

4. How we use personal data

We may process personal data to:

• Provide and operate Proactive Presence services

• Set up and administer client accounts

• Connect and maintain authorised integrations

• Receive and process reviews and customer feedback

• Provide reputation monitoring and analytics

• Generate dashboards, reports and business insights

• Support automated and assisted workflows

• Communicate with clients and authorised users

• Respond to enquiries and support requests

• Maintain platform security

• Detect misuse, fraud or unauthorised activity

• Diagnose technical problems

• Monitor system performance and reliability

• Maintain appropriate audit records

• Meet contractual, regulatory and legal obligations

• Establish, exercise or defend legal claims

• Improve our services where permitted by law

We do not sell personal data.

5. Our role when processing client data

A significant part of the Proactive Presence service involves processing information on behalf of business clients.

Where a client determines why and how personal data should be processed through our services, that client will normally be the data controller and Blagdon Associates S.L. will act as its data processor.

In those circumstances, we process personal data in accordance with the client's documented instructions, our agreement with that client and applicable data-protection law.

Individuals wishing to exercise rights concerning data controlled by one of our clients may therefore need to contact that business directly.

Where appropriate, we will assist our client in responding to such requests.

6. Lawful bases for processing

Where we act as a data controller and GDPR or UK GDPR applies, our lawful basis will depend on the particular processing activity.

We may rely on:

• Contract — where processing is necessary to enter into or perform a contract with you.

• Legitimate interests — where processing is necessary for our legitimate business interests or those of another organisation and those interests are not overridden by your rights and freedoms. This may include operating, securing and improving our services, administering business relationships and responding to business enquiries.

• Consent — where you have given valid consent for a particular processing activity.

• Legal obligation — where processing is necessary for us to comply with a legal requirement.

• Legal claims — where information needs to be retained or processed to establish, exercise or defend legal rights.

Where we act as a processor, the relevant client is responsible for determining the appropriate lawful basis for its processing.

7. Automated processing and artificial intelligence

Some Proactive Presence services use automation and artificial intelligence to assist with activities such as:

• Analysing customer feedback

• Identifying sentiment, subjects or trends

• Classifying information

• Preparing suggested responses to customer reviews

• Producing summaries and business insights

• Supporting operational workflows

Automated systems may process review text, customer feedback and other information necessary to perform these functions.

Where AI generates suggested content, the output may be subject to client-defined workflows, controls or human review depending on the service configuration.

We do not intentionally use client confidential data or personal data to train general-purpose artificial intelligence models unless this has been specifically agreed and is lawful.

8. Sharing information

We may share personal data with organisations that help us operate Proactive Presence, including providers of:

• Cloud hosting and databases

• Content delivery and network infrastructure

• Business automation

• Customer relationship management

• Communications

• Analytics and monitoring

• Artificial intelligence and machine-learning services

• Payment and accounting services

• Technical support and development services

These organisations act as service providers or subprocessors where appropriate and are expected to protect information in accordance with applicable contractual and legal requirements.

We may also disclose information:

• Where required by law

• In response to a lawful request from a competent authority

• To protect our legal rights

• To investigate suspected fraud or security incidents

• In connection with a merger, acquisition, restructuring or sale of relevant business assets

We do not sell personal information to advertisers or data brokers.

9. International data transfers

Proactive Presence operates using modern cloud and technology services, and personal data may therefore be processed in countries other than the country in which it was originally collected.

Where GDPR or UK GDPR applies and personal data is transferred internationally, we take appropriate steps to ensure that the transfer is lawful.

Depending on the circumstances, these safeguards may include:

• An applicable adequacy decision

• Standard Contractual Clauses

• The UK International Data Transfer Agreement or UK Addendum

• Other transfer mechanisms permitted by applicable data-protection legislation

We also assess our service providers and contractual arrangements as appropriate to the nature of the processing.

10. Data security

We use technical and organisational measures designed to protect personal data against unauthorised access, disclosure, alteration, loss or destruction.

Measures may include:

• Encryption in transit

• Controlled access to production systems

• Authentication and authorisation controls

• Separation of development, testing and production environments

• Secure management of credentials and secrets

• Logging and monitoring

• Data access restrictions

• Database integrity controls

• Backup and recovery measures

• Software-development and change-management controls

• Incident response procedures

No internet-based service can guarantee absolute security, but we design our systems to reduce risks appropriately for the nature of the information being processed.

11. Data retention

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, including providing contracted services and satisfying legal, accounting, security and regulatory requirements.

Retention periods may vary according to:

• The type of information

• The service being provided

• Contractual requirements

• Client instructions

• Legal or regulatory requirements

• Security and audit requirements

• The need to establish, exercise or defend legal claims

Where Proactive Presence acts as a processor, retention may also be governed by our agreement with the relevant client.

When information is no longer required, it will be deleted, anonymised or otherwise disposed of in accordance with our applicable retention procedures.

12. Legal holds

Information that would otherwise be deleted may need to be retained where it is relevant to:

• Actual or anticipated litigation

• Regulatory enquiries

• Investigations

• Legal obligations

• The establishment, exercise or defence of legal claims

Where a legal hold applies, normal deletion processes may be suspended for the affected information until the hold is released.

13. Cookies and similar technologies

Our website and online services may use cookies and similar technologies for purposes such as:

• Essential website functionality

• Security

• Remembering user preferences

• Understanding website usage

• Measuring performance

Where required by applicable law, non-essential cookies will be used only with appropriate consent.

More detailed information may be provided in a separate Cookie Policy or cookie-management interface.

14. Your data-protection rights

Depending on your location and the applicable law, you may have rights concerning your personal data, including the right to:

• Request access to your personal data

• Request correction of inaccurate information

• Request deletion of personal data

• Request restriction of processing

• Object to certain processing

• Request portability of eligible information

• Withdraw consent where processing is based on consent

• Raise concerns about certain automated decision-making

• Lodge a complaint with an appropriate data-protection authority

These rights are not absolute and may be subject to legal exceptions.

Where Proactive Presence processes information solely on behalf of a client, we may refer your request to that client as the relevant data controller.

15. Exercising your rights

To make a privacy request concerning information for which Blagdon Associates S.L. is the controller, please use our Privacy Request Form. You may also contact us in writing at our registered address.

We may need to verify your identity before fulfilling a request.

Please provide enough information for us to identify the relevant records and understand your request.

We will respond within the period required by applicable law.

16. Complaints

If you have concerns about how we process your personal data, please contact us first so that we can investigate. You may also have the right to lodge a complaint with the data-protection supervisory authority applicable to you or the relevant processing.

Nothing in this Privacy Policy affects your statutory rights.

17. Third-party websites and services

Our website and services may contain links to, or integrate with, third-party platforms.

Those organisations operate under their own privacy policies and terms. Proactive Presence is not responsible for the privacy practices of independent third-party services except to the extent required by applicable law or our contractual obligations.

18. Children's privacy

Proactive Presence provides business-to-business services and is not intended for use by children.

We do not knowingly offer our services directly to children or intentionally collect children's personal data through our website for our own purposes.

Client-provided information should not include children's personal data unless its processing is lawful and necessary for the relevant service.

19. Changes to this Privacy Policy

We may update this Privacy Policy to reflect changes to our services, technology, legal requirements or business practices.

When we make changes, we will update the “Last updated” date at the top of this page.

Material changes may also be communicated through other appropriate means.

20. Contact us

For questions about this Privacy Policy or the way Proactive Presence handles personal data, contact:

Blagdon Associates S.L., trading as Proactive Presence

Privacy enquiries and data rights requests:

Please use our Privacy Request Form. You may also contact us in writing at our registered address.

Registered address: Av de les Nacions Undies, 40, Escaldes-Engordany AD700