Privacy Policy

Audience Acquisitions Squared Limited (Company Number: 15642064)

ICO Registration Number: ZB746814

Welcome to our website. If you continue to browse and use this website, you are agreeing to comply with and be bound by the following terms and conditions of use, which together with our privacy policy govern Audience Acquisitions Squared Limited's relationship with you in relation to this website. If you disagree with any part of these terms and conditions, please do not use our website.

Audience Acquisitions Squared Limited may trade under the brand name 'B-Smart'. The terms 'B-Smart', 'Audience Acquisitions Squared Limited', 'us' or 'we' refer to the owner of the website, whose registered office is 10 Orange Street, London WC2H 7DQ. Our company registration number is 15642064. The term 'you' refers to the user or viewer of our website.

General terms of use

The content of the pages of this website is for your general information and use only. It is subject to change without notice.

This website uses cookies to monitor browsing preferences. If you do allow cookies to be used, the following personal information may be stored by us for use by third parties such as Google Analytics.

Neither we nor any third parties provide any warranty or guarantee as to the accuracy, timeliness, performance, completeness or suitability of the information and materials found or offered on this website for any particular purpose. You acknowledge that such information and materials may contain inaccuracies or errors and we expressly exclude liability for any such inaccuracies or errors to the fullest extent permitted by law.

Your use of any information or materials on this website is entirely at your own risk, for which we shall not be liable. It shall be your own responsibility to ensure that any products, services or information available through this website meet your specific requirements.

This website contains material which is owned by or licensed to us. This material includes, but is not limited to, the design, layout, look, appearance and graphics. Reproduction is prohibited other than in accordance with the copyright notice, which forms part of these terms and conditions.

All trade marks reproduced in this website which are not the property of, or licensed to, the operator are acknowledged on the website.

Unauthorised use of this website may give rise to a claim for damages and/or be a criminal offence.

From time to time this website may also include links to other websites. These links are provided for your convenience to provide further information. They do not signify that we endorse the website(s). We have no responsibility for the content of the linked website(s).

Your use of this website and any dispute arising out of such use of the website is subject to the laws of England, Northern Ireland, Scotland and Wales.

Why we process your personal data (purposes of processing)

We use your personal data for the following purposes. Each purpose is matched to the lawful basis we rely on — see “The lawful basis for our processing” below.

1. To market our own products and services to you directly

We use your personal data to send you direct marketing about our own products and services (for example, energy, broadband, insurance, financial products, and other offers described in this policy), by phone, email, SMS or post, where you have consented to this or where we have another valid lawful basis to do so.

2. To pass your details to selected third-party companies for their own direct marketing

Where, during a telephone survey or online enquiry, you give clear and informed consent for us to share your details with a named third party (or a category of third parties operating in a specified sector), we pass your personal data to that organisation so they can contact you directly about their own products and services.

3. To manage your registration, account, or service request

Where you register for a website, apply for a job, sign up to a digital product, enter a competition, or hold an account with us, we use your personal data to set up, administer, and deliver that product, service, or account.

4. To improve and personalise the advertising and content we show you

We use technical and behavioural data (such as cookies, device information, and online activity) to enhance the relevance of the advertising and website content we provide to you.

5. To verify and enrich the data we hold, and to identify relevant business contacts

We combine data from our own records with information from other organisations or publicly available sources (e.g. to check a postal address is correct, or to identify business contacts likely to be interested in our products and services).

6. To meet our legal and regulatory obligations

We process personal data where necessary to comply with our obligations under data protection law, telecommunications regulation (including PECR), and other applicable law, and to respond to regulators such as the ICO.

7. To manage opt-outs, objections, and complaints

We keep records of your marketing preferences, opt-outs, and any objections you raise, so that we can honour them on an ongoing basis.

The lawful basis for our processing

Under UK GDPR there are six lawful bases available to organisations. We rely on the following four, depending on the purpose:

Lawful basis

Consent

You have given clear, informed, affirmative consent (e.g. a definitive 'yes' during a telephone survey, or ticking a box online).

Purpose 1 (where based on consent); Purpose 2

Contract

Processing is necessary to enter into or perform a contract with you.

Purpose 3

Legitimate Interests

Processing is necessary for our (or a third party's) legitimate business interests, provided this does not override your rights and interests, and you would reasonably expect it.

Purpose 1 (where based on legitimate interests); Purposes 4, 5, 7

Legal Obligation

Processing is necessary to comply with a legal or regulatory requirement.

Purpose 6

Our legitimate interests, explained

Where we rely on legitimate interests, these are:

Direct marketing of our own similar products and services to existing customers, where you have not opted out (in line with PECR 'soft opt-in' rules) and where you would reasonably expect this contact.
Improving and personalising website content and advertising, so that what we show you is more relevant.
Verifying and correcting the data we hold about you, to keep our records accurate.
Maintaining suppression and opt-out records, so we can reliably stop contacting people who have objected.

In each case, we have considered whether this processing is necessary, whether it is proportionate, and whether it is outweighed by your rights and interests. We do not rely on legitimate interests for special category data, for marketing to individuals who have opted out, or where you would not reasonably expect the processing. You have the right to object to processing based on legitimate interests at any time — see “Individual rights” below.

Where your personal data comes from

Directly from you

Most of the personal data we hold is provided directly by you — for example, when you register on one of our websites, respond to a telephone survey, apply for a job, or sign up to a service (see the full list under “Collection of your personal data” below).

From other organisations or publicly available sources

We sometimes combine information collected from our websites or other sources with information received from other organisations. This is used to:

Verify the personal data we hold for you (e.g. to check your postal address is correct).
Enhance the content and relevance of the advertising we provide to you.

We may also research publicly available sources (e.g. websites and LinkedIn) and use external suppliers to identify business contacts who are likely to be interested in the products and services we have to offer. We will only collect the minimal amount of information required for this purpose (e.g. name, job title, company, and contact details), and when we contact you we will always provide an easy way to object to us continuing to retain your personal data.

Is providing your data a statutory or contractual requirement?

In most cases, providing your personal data to us is voluntary and there is no statutory or contractual obligation to do so. If you choose not to provide certain data, we may simply be unable to offer you the specific product, service, or opportunity you have enquired about (for example, we cannot process a job application without contact details, or register you for an event without your name).

Where we ask for data as part of entering into a contract with you (for example, to set up an account or process a switch of energy/broadband supplier), providing that data is necessary to perform the contract; if you do not provide it, we may not be able to provide that specific product or service to you.

We do not currently collect any personal data under a statutory obligation that requires you, personally, to provide it to us.

Automated decision-making and profiling

We do not currently use fully automated decision-making (including profiling) that produces legal effects concerning you, or similarly significantly affects you, without human involvement.

We may use basic automated processes (such as filtering or sorting enquiries by sector or preference) to help direct your enquiry to the right team or third party. These processes support, but do not replace, human decision-making, and do not have a legal or similarly significant effect on you. If this changes, we will update this policy and provide you with information about the logic involved, the significance, and the envisaged consequences of that processing, together with your right to obtain human intervention.

Collection of your personal data

We collect personal data from you when you enquire about or request a product or service directly from us. For example, you will provide personal data to us when you:

register on one of our websites
join online forums
switch Energy / Broadband
subscribe to a product
apply for a job
sign up for a digital product or service
register to attend a conference, an award, or forum event
request a newsletter/bulletin
enter a competition or prize draw
complete a survey
hold an account where you can buy products through

The information we routinely collect will include your contact details (e.g. name, email address, phone number, and postal address). We will also collect specific information where relevant for a particular service.

When you register to attend one of our events, we may also collect details about your dietary and accessibility requirements. We only collect this information with your explicit consent and will only use it for the purposes of your attendance at the event.

When you visit our websites, technical information such as the IP address used to connect to the internet, the type of device, the browser, and the operating system will be collected. Unique identifiers stored within cookies and mobile device identifiers such as Google's Advertising ID (GAID) and Apple's Advertising ID (IDFA) are also collected where you have given your permission.

Categories of personal data

The different types of personal data we collect and process about you will be part of one of the following categories:

Identity Details (e.g. UIDs, cookie IDs, IP address)
Personal Details (e.g. first name, last name)
Address Details (e.g. address line 1-4, postcode)
Contact Details (e.g. email address, phone number)
Demographic Details (e.g. job function, vehicle details)
Transactional Details (e.g. website registration, datetime stamp)
Permission Details (e.g. marketing preferences)
Payment Details (e.g. payment card or direct debit info)
Online Activity Details (e.g. page visit, email event)
Employment Details (e.g. CV, job applications)
Education and Training Details (e.g. course name, date attended)

Registration statement for lead generation for other parties

At AA2, we take data collection and security seriously. We generate leads via telephone surveys where all data is collected with an appropriate legal basis. During these calls, customers are asked a series of questions to establish their interests, and where a clear and definitive “YES” is provided we rely on your consent to pass your information to the appropriate named controller. We also process your information using Legitimate Interest where this is appropriate and where the processing would be in your reasonable expectations. Where we use Legitimate Interest you will only receive communications from companies within the sectors listed within this privacy policy. At the conclusion of each survey, customers are asked to confirm if they are satisfied, if they have any questions, and given the opportunity to object or opt-out of receiving marketing from us and 3rd parties.

Opt-in and opt-out process

Customers can opt out of contact from AA2 or associated third parties at any time. They are provided with a contact number, email address, and a link to our privacy policy for easy opt-out management.

Metadata documentation

Data Source: Telephone surveys.
Data Type: Customer preferences, interests, and opt-in consent for third-party marketing.
Data Ownership: AA2 is the primary data controller.
Data Usage: Data is shared with third-party companies operating in relevant sectors as specified by customer consent.
Opt-Out Documentation: Clear tracking of opt-in/opt-out statuses, ensuring compliance with customer preferences and regulations.

Sectors covered for lead generation & data gathering

Consumer Goods
Energy Switching
Telecommunications
Business Services
Medical
Lifestyle
Sports Equipment
Housing Disputes & Disrepair
Personal Injury
Mis-sold Policies
Automotive
Charity
Gaming
Leisure
Financial Products
Insurance
Health/Mobility
Home Improvements
Wills
Mail Order
Market Research
Media
Retail
Telecoms
Travel
Education
Utilities

This registration process ensures transparency, compliance, and ease of data discovery, allowing customers to fully understand and manage their interactions with AA2 and third-party companies while safeguarding their data.

Retention periods for personal data

We retain personal data only as long as necessary to fulfil the purposes for which it was collected or as required by applicable laws or regulations. Specific retention periods depend on the nature of the data and the purposes for which it was processed. In general:

Transactional Data: Retained for up to seven years for regulatory and audit purposes.
Marketing Data: Retained until you withdraw consent or opt out of receiving communications.
Account and Profile Data: Retained as long as your account remains active or as necessary to provide you with services.

Data that is no longer needed will be securely deleted or anonymised.

Individual rights in respect of data processing

Under the GDPR and other applicable data protection laws, you have the following rights regarding your personal data:

Right to Access: You may request a copy of the data we hold about you.
Right to Rectification: You can ask for corrections to your personal data if it is inaccurate or incomplete.
Right to Erasure: You can request the deletion of your personal data, subject to legal limitations.
Right to Restrict Processing: You have the right to request that we limit processing of your personal data under certain conditions.
Right to Data Portability: You may request that we transfer your data to another organisation or directly to you.
Right to Object: You have the right to object to our processing of your data based on legitimate interests or direct marketing purposes.
Right to Withdraw Consent: Where consent is the basis for processing, you may withdraw it at any time without affecting the legality of prior processing.

To exercise these rights, please contact us using the information provided in the “Contact Us” section below.

Right to lodge a complaint

If you believe we have processed your personal data in violation of data protection laws, you have the right to lodge a complaint with a supervisory authority. In the United Kingdom, this is the Information Commissioner's Office (ICO). Visit www.ico.org.uk for more information.

International data transfers

Where applicable, personal data may be transferred to and processed in countries outside the UK or EEA. Any transfers of data to third countries or international organisations are conducted in compliance with GDPR standards, including the use of Standard Contractual Clauses and other lawful safeguards to ensure data security and protection.

Contact us

If you have questions about our privacy practices, wish to exercise your rights, or need further details, please contact:

Audience Acquisitions Squared Limited

10 Orange Street, London, WC2H 7DQ

0203 740 0717

Audience Acquisitions Squared Limited. Company Number: 15642064