Your privacy is important to me. It is Surge Marketing’s policy to respect your privacy and comply with any applicable law and regulation regarding any personal information I may collect about you, including across my website,, and other sites I own and operate.

Personal information is any information about you which can be used to identify you. This includes information about you as a person (such as name, address, and date of birth), your devices, payment details, and even information about how you use a website or online service.

In the event my site contains links to third-party sites and services, please be aware that those sites and services have their own privacy policies. After following a link to any third-party content, you should read their posted privacy policy information about how they collect and use personal information. This Privacy Policy does not apply to any of your activities after you leave my site.

This policy is effective as of 6 May 2021.

Last updated: 6 May 2021

Information I Collect

Information I collect falls into one of two categories: ‘voluntarily provided’ information and ‘automatically collected’ information.

‘Voluntarily provided’ information refers to any information you knowingly and actively provide me when using or participating in any of my services and promotions.

‘Automatically collected’ information refers to any information automatically sent by your devices in the course of accessing my products and services.

Log Data

When you visit my website, my servers may automatically log the standard data provided by your web browser. It may include your device’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other details about your visit.

Additionally, if you encounter certain errors while using the site, I may automatically collect data about the error and the circumstances surrounding its occurrence. This data may include technical details about your device, what you were trying to do when the error happened, and other technical information relating to the problem. You may or may not receive notice of such errors, even in the moment they occur, that they have occurred, or what the nature of the error is.

Please be aware that while this information may not be personally identifying by itself, it may be possible to combine it with other data to personally identify individual persons.

Device Data

When you visit my website or interact with my services, I may automatically collect data about your device, such as:

Data I collect can depend on the individual settings of your device and software. I recommend checking the policies of your device manufacturer or software provider to learn what information they make available to me.

Personal Information

I may ask for personal information — for example, when you submit content to me or when you contact me — which may include one or more of the following:

User-Generated Content

I consider ‘user-generated content’ to be materials (text, image and/or video content) voluntarily supplied to me by users for the purpose of publication on my website or re-publishing on my social media channels. All user-generated content is associated with the account or email address used to submit the materials.

Please be aware that any content you submit for the purpose of publication will be public after posting (and subsequent review or vetting process). Once published it may be accessible to third parties not covered under this privacy policy.

Legitimate Reasons for Processing Your Personal Information

I only collect and use your personal information when I have a legitimate reason for doing so. In which instance I only collect personal information that is reasonably necessary to provide my services to you.

Collection and Use of Information

I may collect personal information from you when you do any of the following on my website:

I may collect, hold, use and disclose information for the following purposes, and personal information will not be further processed in a manner that is incompatible with these purposes:

I may combine voluntarily provided and automatically collected personal information with general information or research data I receive from other trusted sources. For example, my marketing and market research activities may uncover data and insights, which I may combine with information about how visitors use my site to improve my site and your experience on it.

Security of Your Personal Information

When I collect and process personal information, and while I retain this information, I will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorised access, disclosure, copying, use or modification.

Although I will do my best to protect the personal information you provide to me, I advise that no method of electronic transmission or storage is 100% secure and no one can guarantee absolute data security.

You are responsible for selecting any password and its overall security strength, ensuring the security of your own information within the bounds of my services. For example, ensuring any passwords associated with accessing your personal information and accounts are secure and confidential.

How Long I Keep Your Personal Information

I keep your personal information only for as long as I need to. This time period may depend on what I am using your information for, in accordance with this privacy policy. For example, if you have provided me with personal information as part of creating an account with me, I may retain this information for the duration your account exists on my system. If your personal information is no longer required for this purpose, I will delete it or make it anonymous by removing all details that identify you.

However, if necessary, I may retain your personal information for my compliance with a legal, accounting, or reporting obligation or for archiving purposes in the public interest, scientific, or historical research purposes or statistical purposes.

Children’s Privacy

I do not aim any of my products or services directly at children under the age of 13 and I do not knowingly collect personal information about children under 13.

Disclosure of Personal Information to Third Parties

I may disclose personal information to:

Third parties I currently use include:

Your Rights and Controlling Your Personal Information

Your choice: By providing personal information to me, you understand I will collect, hold, use, and disclose your personal information in accordance with this privacy policy. You do not have to provide personal information to me, however, if you do not, it may affect your use of my website or the products and/or services offered on or through it.

Information from third parties: If I receive personal information about you from a third party, I will protect it as set out in this privacy policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to me.

Marketing permission: If you have previously agreed to me using your personal information for direct marketing purposes, you may change your mind at any time by contacting me using the details below.

Access: You may request details of the personal information that I hold about you.

Correction: If you believe that any information I hold about you is inaccurate, out of date, incomplete, irrelevant, or misleading, please contact me using the details provided in this privacy policy. I will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading, or out of date.

Non-discrimination: I will not discriminate against you for exercising any of your rights over your personal information. Unless your personal information is required to provide you with a particular service or offer (for example providing user support), I will not deny you goods or services and/or charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, or provide you with a different level or quality of goods or services.

Notification of data breaches: I will comply with laws applicable to me in respect of any data breach.

Complaints: If you believe that I have breached a relevant data protection law and wish to make a complaint, please contact me using the details below and provide me with full details of the alleged breach. I will promptly investigate your complaint and respond to you, in writing, setting out the outcome of my investigation and the steps I will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.

Unsubscribe: To unsubscribe from my email database or opt-out of communications (including marketing communications), please contact me using the details provided in this privacy policy, or opt-out using the opt-out facilities provided in the communication. I may need to request specific information from you to help me confirm your identity.

Use of Cookies

I use ‘cookies’ to collect information about you and your activity across my site. A cookie is a small piece of data that my website stores on your computer, and accesses each time you visit, so I can understand how you use my site. This helps me serve you content based on preferences you have specified.

Please refer to my Cookie Policy for more information.

Business Transfers

If my business or assets are acquired, or in the unlikely event that I go out of business or enter bankruptcy, I would include data, including your personal information, among the assets transferred to any parties who acquire my business. You acknowledge that such transfers may occur, and that any parties who acquire my business may, to the extent permitted by applicable law, continue to use your personal information according to this policy, which they will be required to assume as it is the basis for any ownership or use rights I have over such information.

Limits of This Policy

My website may link to external sites that are not operated by me. Please be aware that I have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.

Changes to This Policy

At my discretion, I may change this privacy policy to reflect updates to my business processes, current acceptable practices, or legislative or regulatory changes. If I decide to change this privacy policy, I will post the changes here at the same link by which you are accessing this privacy policy.

If the changes are significant, or if required by applicable law, I will contact you (based on your selected preferences for communications from me) and all my registered users with the new details and links to the updated or changed policy.

If required by law, I will get your permission or give you the opportunity to opt in to or opt out of, as applicable, any new uses of your personal information.

Additional Disclosures for General Data Protection Regulation (GDPR) Compliance (EU)

Data Controller / Data Processor

The GDPR distinguishes between organisations that process personal information for their own purposes (known as “data controllers”) and organizations that process personal information on behalf of other organizations (known as “data processors”). I, t/as Surge Marketing, located at the address provided in the footer of every page, am a Data Controller with respect to the personal information you provide to me.

Legal Bases for Processing Your Personal Information

I will only collect and use your personal information when I have a legal right to do so. In which case, I will collect and use your personal information lawfully, fairly and in a transparent manner. If I seek your consent to process your personal information, and you are under 16 years of age, I will seek your parent or legal guardian’s consent to process your personal information for that specific purpose.

My lawful bases depend on the services you use and how you use them. This means I only collect and use your information on the following grounds:

Consent From You

Where you give me consent to collect and use your personal information for a specific purpose. You may withdraw your consent at any time using the facilities I provide; however this will not affect any use of your information that has already taken place. You may consent to providing your name and contact details for the purpose of entering a giveaway or promotion. While you may withdraw your entry at any time, this will not affect any selection or judging that has already taken place. If you have any further enquiries about how to withdraw your consent, please feel free to enquire using the details provided in the Contact Me section of this privacy policy.

Performance of a Contract or Transaction

Where you have entered into a contract or transaction with me, or in order to take preparatory steps prior to my entering into a contract or transaction with you. For example, if you contact me with an enquiry, I may require personal information such as your name and contact details in order to respond.

My Legitimate Interests

Where I assess it is necessary for my legitimate interests, such as for me to provide, operate, improve and communicate my services. I consider my legitimate interests to include research and development, understanding my audience, marketing and promoting my services, measures taken to operate my services efficiently, marketing analysis, and measures taken to protect my legal rights and interests.

Compliance with Law

In some cases, I may have a legal obligation to use or keep your personal information. Such cases may include (but are not limited to) court orders, criminal investigations, government requests, and regulatory obligations. If you have any further enquiries about how I retain personal information in order to comply with the law, please feel free to enquire using the details provided in the Contact Me section of this privacy policy.

International Transfers Outside of the European Economic Area (EEA)

I will ensure that any transfer of personal information from countries in the European Economic Area (EEA) to countries outside the EEA will be protected by appropriate safeguards, for example by using standard data protection clauses approved by the European Commission, or the use of binding corporate rules or other legally accepted means.

Your Rights and Controlling Your Personal Information

Restrict: You have the right to request that I restrict the processing of your personal information if (i) you are concerned about the accuracy of your personal information; (ii) you believe your personal information has been unlawfully processed; (iii) you need me to maintain the personal information solely for the purpose of a legal claim; or (iv) I am in the process of considering your objection in relation to processing on the basis of legitimate interests.

Objecting to processing: You have the right to object to processing of your personal information that is based on my legitimate interests or public interest. If this is done, I must provide compelling legitimate grounds for the processing which overrides your interests, rights, and freedoms, in order to proceed with the processing of your personal information.

Data portability: You may have the right to request a copy of the personal information I hold about you. Where possible, I will provide this information in CSV format or other easily readable machine format. You may also have the right to request that I transfer this personal information to a third party.

Deletion: You may have a right to request that I delete the personal information I hold about you at any time, and I will take reasonable steps to delete your personal information from my current records. If you ask me to delete your personal information, I will let you know how the deletion affects your use of my website or products and services. There may be exceptions to this right for specific legal reasons which, if applicable, I will set out for you in response to your request. If you terminate or delete your account, I will delete your personal information within 30 days of the deletion of your account. Please be aware that search engines and similar third parties may still retain copies of your personal information that has been made public at least once, like certain profile information and public comments, even after you have deleted the information from my services or deactivated your account.

Contact Me

For any questions or concerns regarding your privacy, you may contact me using the following details:

John Allsopp