Privacy Policy

Who are we?

Soho Strategy is a London-based digital strategy, intelligence and products studio. You can find out more about us on our website. We’re a UK (England) registered company, Soho Strategy Ltd, and together with our subsidiaries and affiliates are collectively referred to herein as “SOHO”, the “Company”, “us” or “we”.

Our commitment to privacy

1.  We respect your privacy. This Privacy Statement informs you of our privacy practices and of the choices you can make about the way information about you and your online activity is collected and how that information is used. All collection, use and export of personal information is done with appropriate notice and consent, in a manner consistent with the law. This Privacy Policy should be read together with our Cookie Policy and our Terms of Use.

2.  Use of Your Data. The information SOHO collects may be used in a wide-range of activities, such as product or service activation, order processing and registration, profile creation, user verification, fulfilling information requests, updating you on services and benefits, personalising Soho websites, storing your preferences and allowing you to login to user accounts, communicating with you about products or services, marketing commercial offers and promotions, providing customer support, measuring the efficacy of marketing initiatives, processing contest entries and contacting winners, collating survey information and in the process of hiring individuals. Certain information is only ever used for the purposes of transaction processing and fraud prevention. The information SOHO collects from public or commercial sources may be used along with the information SOHO collects from you directly when you visit or talk to SOHO sites or representatives. When you communicate with SOHO, send SOHO information, or provide content to SOHO or our website, you grant the Company a non-exclusive, worldwide, perpetual, irrevocable, royalty-free, sub-licensable right to exercise all copyright and publicity rights you have in and over the content, in any manner whatsoever, in or through any media now known or which may be created in the future, including in other works and forms not associated with this website.

3.  Online User & Behavioural Tracking. On SOHO’s websites, and affiliated websites, the Company may use or access data stored in cookies, web caches, local objects, HTML5 storage, and web-beacons to enable you to move about the site and provide you with information requested, as well as the complete list of uses outlined in Section 2.2. Such data collected may include certain information that your browser sends to a website, such as your browser headers, browser type and language, access times, and referrer URLs (the address of the website from which you arrived). It may also include your Internet Protocol (IP) address, unique device identifier and clickstream behaviour. Clickstream behaviour collected may include information relating to the specific pages you view in a session and in followup sessions, as well as the links you click, mouse-movement behaviour you exhibit, and other actions taken whilst on SOHO’s websites, or third-party sites.

4.  Other Data Collection. You may be asked to provide SOHO with contact information, such as name, address, telephone number and email address, financial information, such as your credit/debit card number, PayPal account details or other billing details as well as government-issued identification number and other data. Depending on your use of SOHO services you may also be asked to create a user ID and password, or provide an existing user ID and password to login, either directly to SOHO servers, or through third-parties such as Facebook, Twitter, Google, or other OAuth-based login solutions. You may provide SOHO with product and service preferences, contact preferences, educational and employment background, job interest data, personal hobby information such as “likes” and “dislikes” either directly or through your use of third-party solutions to log in to Soho products or services. If you belong to a larger organisation, it is possible that your business contact details may be provided to SOHO by a designated entity within your firm or enterprise (such as a member of your IT department) for the purposes of registration with the Company. SOHO may track when you open emails or other marketing communications and click on links contained within. SOHO may also provide social media features that enable you to share information with your social networks and to interact with the Company on various social media sites. Your use of these features may result in the collection or sharing of information about you, by third-party’s beyond SOHO’s control, and not covered by the scope of this Privacy Agreement. SOHO encourages you to review the privacy policies and settings on the social media sites with which you interact to make sure you understand the information that may be collected, used, and shared by those sites, especially as their policies may materially differ from SOHO’s own. For instance, SOHO endeavours to respect browser-based ‘Do Not Track’ requests, but many social media platforms do not. If you were referred to the SOHO website by a friend, colleague, acquaintance or marketing company, it is possible that they may have shared certain personal information with us in order to facilitate a connection. SOHO requests that this never be done without your consent. SOHO may also collect information from publicly or commercially available sources that it deems credible (e.g. DoubleClick). Such information may include your name, address, email address, preferences, interests, and demographic/profile data.

5.  Reasonable Precautions. If you post, comment, indicate interest or complaint, or share identifiable personal information, including photographs, to any public forum on any SOHO site, social profile, blog post, comment platform or other such outlet viewable by others, please be aware that any information you submit may be read, viewed, collected, downloaded or used by other users of SOHO websites, and could be used to contact you, send you unsolicited messages, or for purposes that neither you nor SOHO have control over. SOHO is not responsible for the personal information you choose to provide in these forums and wishes to highlight the risks associated with the disclosure of personally identifiable information on any publicly viewable platform.

6.  Disclosure of Information. SOHO does not sell, rent or lease your personal information to others except as described in this Statement. SOHO shares personal information only in the following ways:

• SOHO retains service providers and suppliers to deliver complete products, services and customer solutions and to assist SOHO with marketing and communication initiatives. These providers and suppliers include, for example, credit card and payment processors, providers of customer support and live-help, marketing, email service providers, automated data processors, and shipping agents. Suppliers and service providers are required by contract to keep confidential and secure the information received on behalf of SOHO and may not use it for any purpose other than to carry out the services they are performing for SOHO. Such information-sharing may be necessary to ensure payment processing, product delivery and effective followup support.
• Except as described above, SOHO will not share the personal information you provide to the Company with any third parties on any other occasion without your permission, unless to: (i) respond to duly authorised information requests of police and governmental authorities; (ii) comply with any law, regulation, subpoena, or court order; (iii) investigate and help prevent security threats, fraud or other malicious activity; (iv) enforce/protect the rights and properties of SOHO or its subsidiaries; or (v) protect the rights or personal safety of SOHO, our employees, and third parties on or using SOHO property when allowed and in line with the requirements of applicable law.

7.  International Transfer of Data. Your information may be stored and processed in any country in which SOHO maintains facilities or conducts operations, and SOHO may transfer your personal information to other SOHO-owned business entities in the UK, EU and Worldwide (under established International Safe Harbour Privacy Principles). By accessing SOHO websites, products and services and/or registering for an account or service, or otherwise providing the Company with your personal information, you consent to this transfer of your personal information throughout the global SOHO network of entities. As SOHO continue to develop our business, SOHO and its subsidiaries may buy or sell businesses, business-units, or entities, and mergers or acquisitions may occur in which data is transferred. Whether for strategic or other business reasons, if the Company decides to reorganise its businesses in such a way that may involve the disclosure of personal information to prospective or actual purchasers, or the receipt of it from sellers, SOHO will seek appropriate protection for the information concerned. Due the nature of internet networks, your information may pass through multiple jurisdictions on its way to or from SOHO. By using our website, products and services, you consent to any such transfer of information outside of your country. Should your account become inactive, your information may remain in our databases, computers, backups and archives.

8.  Opting Out of Communications. Subscription communications include email newsletters, SMS updates, and “push” notifications (both Operating System and browser-based). These communications are provided at SOHO’s discretion, and generally delivered as a result of obtaining your consent during a registration or sign-up process involving your entering personal information (for example your name, email, phone number or address) on a SOHO website, or partner website. Occasionally SOHO may collect indviduals’ contact details in person at seminars or events, along with the appropriate permission to contact them. If you are in receipt of any sales or marketing communications from SOHO  you may opt out of receiving future communications by using one of the following methods:

• Email unsubscribe: Select the email “opt out” or “unsubscribe” link, usually at the very top or bottom of the email, and follow the opt-out instructions included in each email subscription communication.
• SMS unsubscribe: To unsubscribe from messages delivered to mobile devices by SMS, reply to the message with the words “STOP” or “END.”
• Push unsubscribe: To stop push notifications please see your application or device’s alert settings.
• Alternatives means of unsubscribing: Sometimes it may be possible to return to the web-page(s) where you originally registered your preferences and follow the onscreen opt-out instructions there. Where this is not possible and you have already attempted to unsubscribe by the alternative means mentioned above (where applicable), you may contact SOHO directly to ensure discontinuation of communications. Be sure to provide your full name, relevant contact information, and specific information (where known) regarding which SOHO communications you no longer wish to receive.

Please be aware that when you opt out of receiving certain subscription communications, it may affect the services you have chosen to receive from SOHO where accepting the communications is a condition of receiving the services, or the only means of accessing future information regarding an ongoing product or service subscription/membership.

9.  Accuracy of Information. SOHO strives to keep your personal information accurately recorded in line with UK and EU law and best-practice. SOHO have implemented technology, management processes and policies to help maintain data accuracy. In conformity with UK, European, and international data protection laws, SOHO will provide you with reasonable access to personal information that the Company may hold on you upon request. You have the reasonable ability to review and correct this data at any time, or ask for its anonymisation, blockage, or deletion, as applicable. To protect your privacy and security, SOHO will also take reasonable steps to verify your identity, such as requiring your user ID and password, before granting access to your data. To view and change any personal information that may have been directly provided by you to SOHO, you can typically return to the web page where you originally submitted your data, and follow the instructions on that web page or contact SOHO directly to ensure its update or removal.

10.  Information Security. SOHO takes information security extremely seriously and as data geeks and tech nerds ourselves, we strive to follow the best possible, industry-leading practices to ensure your safety and security online. SOHO takes the trust you place in the Company seriously, and to prevent unauthorised access or disclosure, to maintain data accuracy, and to ensure the appropriate use of information collected, the Company utilises reasonable and appropriate physical, technical, and administrative procedures to safeguard the information collected and processed. SOHO retains data only as required or permitted by local law and while it has a legitimate business purpose. When collecting or transferring sensitive information such as credit card information SOHO uses a variety of additional security technologies and procedures to help protect your personal information from unauthorised access, use, or disclosure.

This page was last updated 2019-06-20.