Privacy & Cookies

This privacy notice tells you about the information we collect from you when you use our website. In collecting this information, we are acting as a data controller and, by law, we are required to provide you with information about us, about why and how we use your data, and about the rights you have over your data.

Who are we?

We are Ginger Publicity Ltd, registered at 193 Lordship Lane, London SE22 8HA
You can contact us by email at

At Ginger Comms we are committed to protecting the privacy of our website visitors, clients and, as a market research group, the privacy of research respondents. We want to provide a safe and secure service where we deal with your personal information. This means information that identifies you personally such as your name, photo, contact details, or data that can be linked with such information in order to identify you.

We are not required to have a data protection officer, so any enquiries about our use of your personal data should be addressed to the contact details above.

Information you give us

If you’re filling in the contact forms on our website

We will always ask for your consent when adding you to lists and you should know what you’re signing up for – be it, marketing mail or receiving content relevant to you from us.

If you’re completing a survey or engaging in a questionnaire

We collect information for market research purposes only.

The information you provide will normally be used to help a client better understand how well they’re doing in the marketplace, or to help them improve a service or similar. Data is presented back to our client in an aggregated, anonymised, format, unless you consent to us providing them your data with any contact information appended e.g. email address, phone number and so on. This would be freely given and not a requirement of conducting market research, unless the research required it for a specific lawful reason e.g. to pay you your incentive after completing the survey, or to conduct face-to-face research which you would opt-in to and so on.

If you apply for a job with us:

We will receive the personal data that you provide when you apply. We will use that data to process and consider your application. If your application is successful, then we’ll give you separate information about our treatment of employee data. Otherwise, we keep information about job applicants for the duration of the recruitment process and for 12 months afterwards, in case of issues or disputes. We do this on the basis that it is necessary for taking steps prior to entering into a contract. If you don’t provide the personal data when we ask for it we may not be able to process your application or contact you in relation to your application. If you have any concerns about whether you need to provide the personal data please contact our data protection team (see contact details above).

Information we collect automatically

If you’re accessing our websites

We collect IP addresses of users of our website and we may also store your browser’s environment variables (this is freely available when you browse the web and contains information like your operating system, the device you are on, the browser version and so on). This information is kept for security reasons to allow us to block fraudulent members of the public, but also to help improve your user experience when you visit our sites, for example serving up different web pages if you’re on a mobile vs. a tablet vs. a laptop.


Information we receive from third parties

There will be occasions where our clients request that we contact individuals on their databases. This information may contain behaviour which our client may have collected on you e.g. number of store visits, a loyalty band / tier, or an internal value pertaining to the segment you are in. Upon completion of a survey we may append some of this information on to the answers you have provided to help our client better understand their customer database, and to help us analyse the data more efficiently. Data is generally presented to our client in an anonymised, aggregated, format and, unless the reward for completing a survey requires it, or you opted in to do so, your participation in the research will never be shared.

There may also be instances where we have lawfully received your data from a sample supplier that has lawfully collected your details and has the right to sell this on. In these instances we would be contacting you as an unknown third party, but the basis for processing is as per the above, only we would be provided with far less information on you, for example just a name and email address.

How do we use your personal information?

To provide a requested service or carry out a contract with you.

For example, where you have entered a competition with us and we are processing your personal data to deliver your prize.

Where we have your consent

If you have signed up with us for marketing, or to receive market research surveys or services.

Where we have a legitimate interest

If we have legally received your data from a third party for the purpose of market research.

Where we have a legal obligation

We may also store or use personal information where we have a legal obligation to do so.

How long do we keep your personal information for?

We keep your information for the following periods:

We have our own retention policy for all types of personal data used throughout Ginger Comms. We will only keep data for as long as reasonably necessary.

For example, we hold our client order information for 90 days following the end of a contract unless a contract with our client specifies we must hold it for longer.

Who do we share your personal information with?

We share your personal information with trusted third parties where we have retained them to provide services that you or our clients have requested, such as recruitment for qualitative work, face-to-face interviews, or other services we are unable to provide in-house. While Ginger Comms strive to carry out all functions internally, there are instances where this simply isn’t feasible.

We share your personal information with third parties who perform functions on our behalf and who also provide services to us, such as professional advisors, IT consultants carrying out testing and development work on our business technology systems, research and mailing houses and function co-ordinators.

We share your personal information with our other Group companies for internal reasons, primarily for business and operational purposes. As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or merges with us your personal information will be disclosed to such entity. Also, if any bankruptcy or reorganisation proceeding is brought by or against us, all such information will be considered an asset of ours and as such it is possible they will be sold or transferred to third parties.

Where required we share your personal information with third parties to comply with a legal obligation; when we believe in good faith that an applicable law requires it; at the request of governmental authorities conducting an investigation; to verify or enforce our Terms of Use or other applicable policies; to detect and protect against fraud, or any technical or security vulnerabilities; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of third parties, visitors to the our website, our business or the public.

What happens if you do not provide us with the information we request or ask that we stop processing your information?

If you do not provide the personal information necessary, or withdraw your consent for the processing of your personal information, where this information is necessary for us to provide services to you, we will not be able to provide these services to you.

Do we make automated decisions concerning you?

We don’t perform any automated decision making concerning clients, survey respondents or website users.

Do we use Cookies to collect personal data on you?

To provide better service to you on our websites, we use cookies to collect your personal data when you browse. See our cookie policy above for more details.

Do we transfer your personal information outside the EEA?

All the data you provide us sits on our secure servers in the EEA. However, as a global company with offices in the USA your data may be transferred outside of the EEA. In a scenario where your processing would be done outside of the EEA, we will ensure that the transfer is lawful and that there are appropriate security arrangements in place.

What are your rights?

By law, you have a number of rights when it comes to your personal information. Further information and advice about your rights can be obtained from the data protection regulator in your country.


What does this mean?

1. The right to object to processing
You have the right to object to certain types of processing, including processing for direct marketing (i.e. if you no longer want to be contacted with potential opportunities).

2. The right to be informed
You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Policy.

3. The right of access
You have the right to obtain access to your information (if we’re processing it), and certain other information (similar to that provided in this Privacy Policy).

This is so you’re aware and can check that we’re using your information in accordance with data protection law.

4. The right to rectification
You are entitled to have your information corrected if it’s inaccurate or incomplete.

5. The right to erasure
This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.

6. The right to restrict processing
You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.

7. The right to data portability
You have rights to obtain and reuse your personal information for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability.

8. The right to lodge a complaint
You have the right to lodge a complaint about the way we handle or process your personal information with your national data protection regulator.

9. The right to withdraw consent
If you have given your consent to anything we do with your personal information, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal information with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal information for marketing purposes.

We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:

baseless or excessive/repeated requests, or
further copies of the same information.
Alternatively, we may be entitled to refuse to act on the request.

Please consider your request responsibly before submitting it. We’ll respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we’ll come back to you and let you know.

How will we contact you?

We may contact you by phone, email or social media. If you prefer a particular contact means over another, please just let us know.

How can you contact us?

If you have any enquires you can contact us at: or by writing to us at:

Ginger Comms
193 Lordship Lane
SE22 8HA

Your right to complain

If you have a complaint about our use of your information, we would prefer you to contact us directly in the first instance so that we can address your complaint. However, you can also contact the Information Commissioner’s Office via their website at or write to them at:

Information Commissioner’s Office
Wycliffe House
Water Lane

Updates to this privacy policy

We regularly review and, if appropriate, update this privacy policy from time to time, and as our services and use of personal data evolves. If we want to make use of your personal data in a way that we haven’t previously identified, we will contact you to provide information about this and, if necessary, to ask for your consent.

We will update the version number and date of this document each time it is changed.

v2.0 – 14th June 2022