1.2.When we refer to “Hint Media”, “we” or “us”, we mean the relevant trading entity within the Hint Media Ltd that acts as the controller or processor of your information.
1.4.Personal data may be collected when you:
a)register for, purchase or use any of our products and/or services (the Products);
b)use any of Hint Media’s websites including any subdomains that may be made available by us from time to time and including (but not limited to) websites containing the URL ‘hintmedia.co.uk’ and the following websites (Websites):
c)use any of Hint Media’s social media channels including (but not limited to) Twitter, Instagram, Facebook and LinkedIn (Social Media Channels);
d)use the “Contact Us” section on the Websites or contact or interact with Hint Media by any other means;
e)use the Olark chat functionality or other chat or interactive functionality on the Websites;
f)email or call Hint Media for any purpose; or
g)send personal data to Hint Media by any other means.
2.What is personal data?
2.2.Personal data includes information which can identify you as a living individual, whether by itself or when used in conjunction with other information which we hold.
3.What is sensitive personal data?
3.1.This category of personal data is more sensitive and relates to, for example, a person’s race, sexual orientation, criminal allegations or offences, trade union memberships or their mental or physical health.
3.2.Sensitive personal data may be collected by us from you if you place an order with us, enter into specific research activities, when you wish to attend an event with us or otherwise with your consent.
3.3.We have in place additional measures to protect your sensitive personal data and its confidentiality. We may use your sensitive personal data in order to deliver our Products to you, to meet your requirements or to deal with any requests made by you.
4.What personal data do we collect and what do we do with it?
4.1.Depending on how you use the Websites, Products and Social Media Channels or otherwise interact with us, we will ask you to provide us with certain personal data which identifies you (whether by itself or together with other information that Hint Media holds) and which may affect your privacy. In order to supply the Websites and Products to you and to continue interacting with you, Hint Media have a legitimate interest under the Act to collect and retain such personal data.
4.2.Personal data may include data collected in the following circumstances (this is not a definitive list):
a)fulfilling and contacting you about your requests for Products, other services, and information, including to send you electronic newsletters and to complete transactions that you have requested;
b)detecting and preventing fraudulent activity;
c)providing you with electronic newsletters, information, special offers and promotional materials about us (including the Websites) and on behalf of Hint Media, in accordance with applicable law;
d)research and analysis of the use of Websites and information about visitors to the Websites to understand and improve our service offerings and, in accordance with our sharing policies, to produce anonymous, pseudonymised or aggregated data and statistics that might help third parties develop our or their own products and service offerings;
e)customising the content you see when you visit a Website;
f)developing and providing advertising tailored to your interests;
g)developing and improving our business (including developing new Products and services; managing our communications; determining the effectiveness of and optimising our advertising; analysing our products, services, Websites Social Media Channels, mobile applications and any other digital assets; facilitating the functionality of our Websites, mobile applications and any other digital assets) and performing accounting, auditing, billing, reconciliation and collection activities;
h)we may record telephone calls and our Olark Website chats with you for training and/or monitoring purposes;
i)evaluating your interest in employment with Hint Media and contacting you regarding possible employment with Hint Media;
k)as may be required by applicable laws and regulations or requested by any judicial process or governmental agency having or claiming jurisdiction over Hint Media;
l)complying with industry standards and our policies;
m)providing and operating our competitions, events and promotions;
n)promoting and marketing Products and services of ours and our Hint Media partners;
o)complying with our legal obligations; and
p)for any other purposes disclosed to you at the time we collect your information or with your consent.
4.3. The personal data we ask for may include:
c)Date of birth;
f)Where you heard about us;
g)Information regarding your personal or professional interests, needs or opinions, demographics, experiences with our Products and contact preferences. Some of this information may constitute sensitive personal data (e.g. if your personal interests relate to your religious or other beliefs or your racial or ethnic origin) which is further defined below;
h)Credit/debit card information, billing information and/or delivery address information (if you order Products on the Websites); and/or
i)Information you provide in any “free text” boxes on the Websites or Social Media Channels (i.e. blank spaces where you are free to insert comments).
4.4.We may also collect other information about you automatically with regard to each of your visits to the Websites or use of our other Social Media Channels. This may include:
a)technical information, including the IP address used to connect your computer to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
b)information about your visit, including the Google Analytics, through and from the Websites or Social Media Channels (including date and time), Products you viewed or searched for, page response times, download errors, lengths of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs) and methods used to browse away from the page and any phone number used to call our customer services numbers.
4.5.We may also receive information about you from other sources. These may include:
a)your employer; and
b)other third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, overseas agents and credit reference agencies).
4.6.These lists of personal data are not exhaustive and further information may be requested from you when Hint Media considers it is fair and necessary to do so. Further, the personal data requested by Hint Media may include sensitive personal data (see “what is sensitive personal data?” below) and it may change or be updated in accordance with the nature of our services and in accordance with legal, regulatory and other good governance requirements.
4.7.Wherever reasonably practicable we will distinguish between personal data that you must provide or which must be collected from you in order to be granted the access to the relevant Website, Product or Social Media Channel and any information which you may provide at your discretion.
a)estimate our audience size and usage pattern;
b)store information about your preferences, and so allow us to customise our site according to your individual interests;
c)speed up your searches; and
d)recognise you when you return to our site.
5.5.Google Analytics stores information about:
• how you came to our site
• what you click on the site
• the pages you visit
• how long you spent on the site
a)We don’t collect or store any personal information that would identify you, such as your name, address or email address.
b)You can opt out of Google Analytics cookies at any time. Please visit the Google Analytics website for more information.
6.Who do we share your data with?
6.1.Hint Media is committed to maintaining your trust and we want you to understand when and with whom we may share information collected about you.
6.2.We may share your data in the following ways:
a)in accordance with your instructions or with consent (as applicable according to the sensitivity of the data), including in accordance with any applicable terms in our General, Experiential, Purchase Order or other Terms and Conditions and in compliance with applicable law and legal process;
b)to authorised companies who work on our behalf to provide your nominated Hint Media service. These companies will only use your information to help us provide the Products to you and for no other purposes;
c)to other trading companies within the Hint Media Ltd;
d)to sponsors and third parties who assist with our research, sweepstakes, contests or promotions. These companies may design, administer and implement a promotion, including in connection with winner selection, prize fulfilment and aggregated data analysis. By entering a promotion, you agree to these terms, as well as any promotion specific terms found on our website from time to time;
e)in an aggregated or de-identified form with prospects or partners for business or research purposes;
f)as part of a substantial corporate transaction, such as a sale of a Website, a merger, consolidation or sale of the business;
g)to government, law enforcement agencies, the courts and regulatory bodies when legally obliged to;
h)to defend and protect the legal rights, interests and safety of the Websites, Hint Media and our employees; and
7.How do we protect your personal information?
7.1.We hold your personal information in a combination of electronic and hard copy files. We may store your personal information with a third-party data storage provider.
7.2.We take all reasonable steps to ensure that the personal information we hold is protected from misuse, interference and loss, and unauthorised access, modification or disclosure by the use of various methods, including secure storage. Where we store your personal information with a third-party data storage provider, we require them to keep it secure and only use or disclose it for the purpose for which it was provided.
7.3.Please contact us immediately if you become aware or have reason to believe there has been any unauthorised use of your personal information that we hold.
7.4.We will only keep information about you for as long as we need for the purpose for which it was collected and we will take reasonable steps to ensure that any third party to which we have disclosed your information does the same.
8.Retention of your personal data
8.1.We will not keep your personal data or other information for longer than is necessary for the purposes for which it was provided by you unless we are required by law or we have other legitimate interests to keep it longer (for example, if it is necessary to do so for the purposes of legal proceedings).
9.Ensuring that your personal data is accurate
9.1.If you have reason to believe that any personal data that we have about you is out of date or inaccurate, please send an email to email@example.com or write to us to notify us of any changes that should be made. We will amend your personal data if you tell us to or if we consider that it contains factual errors or is out of date.
10.How can you withdraw your consent or request not to receive direct marketing?
10.1.You can withdraw your consent to our collection, use and disclosure of your personal information at any time by sending us an email at firstname.lastname@example.org. We will action your request as soon as we reasonably can. However, we may not be able to continue to provide the nominated Hint Media Product or other service to you.
10.2.If you’ve previously indicated to us that you’d like to hear about Hint Media Products or other services, we may contact you by post, telephone, email or SMS. You can change your preferences or unsubscribe at any time – just send us an email to the address above. We’ll action your request as soon as we reasonably can.
11.International Data Transfers
11.3.Although personal data may be transferred to other trading companies within the Hint Media Ltd, to affiliates and trusted third parties, the Lead Supervisory Authority in respect of cross border transfers to and from trading companies within the Hint Media Ltd will be the Information Commissioner’s Office (ICO) in the United Kingdom. Hint Media (UK) Limited is registered at Companies House and at the ICO as a data controller.
12.1.The Websites are intended for a general audience and do not knowingly collect or store personal information about children under the age of 18.
14.Third Party Sites
14.2.You should review the privacy policies of those third-party sites before providing any information to them. We are not responsible or liable for the privacy practices or policies of any websites not operated by Hint Media or any of its wider Group.
15.Requesting your personal data
15.1.You can ask to access personal data that the relevant Hint Media company (i.e. the company to which your personal data is directed to through the Websites or the company to which you have supplied that personal data) may hold about you. Under UK law you are entitled to:
a)access, update or amend the information that we hold about you;
b)object to the processing of your information by Hint Media, including for marketing purposes or otherwise where you have a legitimate reason for doing so
c)ask for a copy of any of your personal data in a machine-readable form (such as .CSV) so you can use it elsewhere; and/or
d)ask us to delete your information. Please note that we may need to retain some information about you in order to satisfy our legal or security obligations or legitimate internal requirements.
15.2.Please Contact Us if you wish to exercise any of these rights.
16.2.Please note that your access to the Products or any other services or materials offered on the Website or Social Media Channels or otherwise may be restricted if you do not submit personal data when we ask you to do so.
Data Protection (c/o Legal Department)
Hint Media Limited
St Martin House
7 Peacock Lane
Alternatively, please visit the appropriate Hint Media website and click “contact us” to be put in touch with someone in our local markets.
If you require further information on privacy and data protection generally, please visit the ICO website which oversees data protection compliance in the United Kingdom: https://ico.org.uk/