PRIVACY POLICY

1. Introduction

This Digital Privacy Policy explains how Digital Movement (“we”, “us”, or “our”), operating at https://digitalmovement.uk, collects, uses, stores, and protects personal data in connection with our digital advertising activities on Google Ads and Meta (Facebook and Instagram) advertising platforms.

This policy applies to all individuals whose personal data is collected, processed, or used through our paid advertising campaigns, website tracking technologies, and related analytics. It is designed to comply with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and the Privacy and Electronic Communications Regulations (PECR).

2. Data Controller Information

Company Name: Digital Movement

Registered Address: 128 City Road, London, EC1V 2NX, United Kingdom

Website: https://digitalmovement.uk

Email: office@digitalmovement.uk

Telephone: 07446 967403

Digital Movement acts as the Data Controller for personal data collected through our advertising campaigns and website analytics. We are responsible for determining the purposes and means of processing personal data in accordance with applicable data protection laws.

3. Google Ads — Paid Advertising & Data Collection

3.1 Overview of Google Ads Data Collection

When we run paid advertising campaigns through Google Ads (including Search, Display, Shopping, Video, and Performance Max campaigns), certain data about users who interact with our advertisements is collected. This data collection is facilitated through Google’s advertising technologies, including cookies, tracking pixels, and conversion tags installed on our website.

3.2 Types of Data Collected via Google Ads

3.3 Google Ads Tracking Technologies

We use the following Google technologies on our website:

• Google Ads Conversion Tracking Tag — Measures actions taken on our website after a user clicks on one of our Google advertisements.
• Google Remarketing Tag — Enables us to show targeted advertisements to users who have previously visited our website as they browse other sites within the Google Display Network.
• Google Analytics 4 (GA4) — Collects anonymised and aggregated data about website traffic, user behaviour, and audience demographics.
• Google Tag Manager — Manages the deployment of tracking tags and scripts on our website.
• Enhanced Conversions — Uses hashed first-party data (such as email addresses) to improve conversion measurement accuracy.

3.4 Legal Basis for Google Ads Data Processing

We process personal data collected through Google Ads under the following legal bases as defined by Article 6 of the UK GDPR:

• Consent (Article 6(1)(a)) — Where users have provided clear, affirmative consent through our cookie consent mechanism before any non-essential tracking cookies are placed on their device.
• Legitimate Interests (Article 6(1)(f)) — Where processing is necessary for our legitimate business interests in marketing our services effectively, provided these interests are not overridden by the data subject’s rights and freedoms.

3.5 Google Ads Data Sharing & Third Parties

Data collected through Google Ads may be shared with Google LLC and its affiliates for the purposes of ad delivery, optimisation, reporting, and fraud detection. Google processes this data in accordance with its own privacy policy and advertising data terms. We do not sell personal data collected through Google Ads to any third party. Data may be transferred outside the UK where Google maintains data processing facilities, subject to appropriate safeguards such as Standard Contractual Clauses (SCCs).

3.6 Google Ads Data Retention

Conversion data and audience lists are retained for a maximum of 540 days in Google Ads, after which they are automatically removed. Google Analytics data is retained in accordance with our configured retention settings, which we review periodically to ensure compliance.

4. Meta (Facebook & Instagram) — Paid Advertising & Data Collection

4.1 Overview of Meta Advertising Data Collection

When we run paid advertising campaigns on Meta platforms (including Facebook, Instagram, Messenger, and the Meta Audience Network), data about users who view or interact with our advertisements is collected. This collection is facilitated by Meta’s advertising technologies, including the Meta Pixel, Conversions API (CAPI), and SDK integrations.

4.2 Types of Data Collected via Meta Advertising

4.3 Meta Tracking Technologies

We use the following Meta technologies on our website and in our advertising campaigns:

• Meta Pixel (formerly Facebook Pixel) — A JavaScript code snippet placed on our website that tracks user actions after viewing or clicking on our Meta advertisements.
• Conversions API (CAPI) — A server-side integration that sends conversion event data directly from our server to Meta, improving data accuracy and reducing reliance on browser-based cookies.
• Custom Audiences — We may upload hashed customer lists (email addresses, phone numbers) to Meta to create targeted audience segments for advertising.
• Lookalike Audiences — Meta uses data from our Custom Audiences to identify and target users with similar characteristics and behaviours.
• Meta Events Manager — Used to configure, monitor, and troubleshoot event tracking across our Meta advertising campaigns.

4.4 Legal Basis for Meta Advertising Data Processing

We process personal data collected through Meta advertising under the following legal bases:

• Consent (Article 6(1)(a)) — Where users have provided explicit consent through our cookie consent mechanism before the Meta Pixel or similar tracking technologies are activated on their device.
• Legitimate Interests (Article 6(1)(f)) — For server-side processing via Conversions API where we have a legitimate interest in measuring advertising effectiveness, provided appropriate safeguards are in place.
• Contractual Necessity (Article 6(1)(b)) — Where data processing is necessary to fulfil a service enquiry or transaction initiated by the user through our Meta advertisements.

4.5 Meta Advertising Data Sharing & Third Parties

Data collected through Meta advertising is shared with Meta Platforms, Inc. and its affiliates for ad delivery, optimisation, measurement, and reporting. Meta processes this data in accordance with its Data Policy and Business Tools Terms. We do not sell personal data collected through Meta advertising. International data transfers are governed by Meta’s approved data transfer mechanisms, including Standard Contractual Clauses and any applicable adequacy decisions.

4.6 Meta Advertising Data Retention

Custom Audience lists are refreshed or deleted within a maximum of 180 days. Meta Pixel data and event data are retained by Meta for up to two years for aggregated reporting purposes. We periodically review and purge audience lists that are no longer required for active campaigns.

5. Cookie Policy & Consent Management

Our website uses cookies and similar tracking technologies to support our Google Ads and Meta advertising activities. These include:

Non-essential cookies (analytics and advertising) are only activated after the user has provided explicit, informed consent through our cookie consent banner. Users may withdraw their consent at any time by adjusting their cookie preferences through the consent management tool displayed on our website, or by contacting us directly.

6. Your Rights Under UK GDPR

As a data subject, you have the following rights in relation to personal data we collect through our advertising activities:

• Right of Access (Article 15) — You may request a copy of the personal data we hold about you.
• Right to Rectification (Article 16) — You may request correction of inaccurate or incomplete data.
• Right to Erasure (Article 17) — You may request deletion of your personal data in certain circumstances.
• Right to Restriction of Processing (Article 18) — You may request that we limit the processing of your data.
• Right to Data Portability (Article 20) — You may request your data in a structured, machine-readable format.
• Right to Object (Article 21) — You may object to processing based on legitimate interests, including profiling for direct marketing.
• Right to Withdraw Consent — Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of processing carried out before withdrawal.

To exercise any of these rights, please contact us at office@digitalmovement.uk. We will respond to your request within one calendar month.

7. Opt-Out of Targeted Advertising

Users who wish to opt out of personalised advertising from Google and Meta can do so through the following mechanisms:

7.1 Google Ads Opt-Out

• Google Ads Settings: https://adssettings.google.com
• Google Analytics Opt-Out Browser Add-on: https://tools.google.com/dlpage/gaoptout
• Network Advertising Initiative Opt-Out: https://optout.networkadvertising.org

7.2 Meta Advertising Opt-Out

• Facebook Ad Preferences: https://www.facebook.com/adpreferences
• Instagram Settings: Navigate to Settings > Ads > Ad Preferences
• Digital Advertising Alliance Opt-Out: https://optout.aboutads.info

Please note that opting out of personalised advertising does not prevent you from seeing advertisements; it means the advertisements shown to you may be less relevant to your interests.

8. Data Security Measures

We take appropriate technical and organisational measures to protect the personal data collected through our advertising platforms, including:

• Encryption of data in transit (HTTPS/TLS) across our website and all advertising platform integrations.
• Hashing of personal identifiers (email addresses, phone numbers) before transmission to advertising platforms via Enhanced Conversions and Conversions API.
• Role-based access controls limiting access to advertising accounts and analytics data to authorised personnel only.
• Regular audits of tracking tags, pixels, and data collection practices to ensure compliance.
• Secure storage and processing of any first-party data used for Custom Audience creation.

9. International Data Transfers

Both Google and Meta may process personal data outside the United Kingdom, including in the United States and other jurisdictions. Where such transfers occur, they are subject to appropriate safeguards including Standard Contractual Clauses (SCCs), the UK International Data Transfer Agreement (IDTA), and any relevant adequacy decisions issued by the UK Secretary of State under Section 17A of the Data Protection Act 2018.

10. Children’s Privacy

Our advertising campaigns and services are not directed at individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that we have inadvertently collected personal data from a minor, we will take immediate steps to delete that information. Our Google Ads and Meta advertising campaigns are configured to target adult audiences only.

11. Changes to This Privacy Policy

We may update this Digital Privacy Policy from time to time to reflect changes in our advertising practices, applicable legislation, or regulatory guidance. Any material changes will be communicated by updating the “Last Updated” date at the top of this document and, where appropriate, by providing notice on our website. We encourage you to review this policy periodically.

12. Complaints

If you are dissatisfied with how we have handled your personal data or believe that we have not complied with our data protection obligations, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO):

Website: https://ico.org.uk

Telephone: 0303 123 1113

Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

13. Contact Us

If you have any questions, concerns, or requests regarding this Digital Privacy Policy or our data collection practices in connection with Google Ads or Meta advertising, please contact us:

Email: office@digitalmovement.uk

Telephone: 07446 967403

Post: Digital Movement, 128 City Road, London, EC1V 2NX, United Kingdom