Last updated: July 2018
1. About Alder
We are Alder Media Limited (Alder, we, our or us) a company registered in England and Wales under company number 07470843 whose registered office is at Connect House 133-137 Alexandra Road, Wimbledon, London SW19 7JY. We are registered as a data controller with the Information Commissioner’s Office in the UK and our registration number is ZA440186.
3. What Personal Data Do We Collect About You
This section informs you of what information we collect about you and why. Personal data means any information about an individual from which that individual can be identified.
We collect personal data about you if you send us
Personal data we may process about you:
- Email address
- Phone number
- Job title
- IP address
- Technical Data including internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Site.
- Marketing and Communications Data including your preferences in receiving marketing from us and your communication preferences.
Special Category Data means details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not seek to collect or otherwise process your Special Category Data
4. How is Your Personal Data Collected
We use different methods to collect data from and about you including through:
We collect personal data about you if you correspond with us through the Site, by telephone, email or otherwise. This includes information you provide when you:
- send us an
- buy our products or services;
- enter a
- report a problem with our Site or give us feedback.
We may process personal data that you manifestly choose to make public, including via social media (e.g. we may collect information from your social media profile(s
Automated technologies or interactions:
If you use our Site, we automatically collect the following information:
- web usage information (e.g. IP address), browser type and version, time zone setting, operating system and platform; and
- Information about your visit, including the full Uniform Resource Locators (URLs) clickstream to, through and from our Site (including date and time); time on page, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks
Where we collect information about you in the ways described above, we do so on the basis that it is in our legitimate interests to collect and process this data. In most
No automated decision-making or profiling will take place using your personal data.
Information we receive from other sources:
We are also working closely with third parties, (including, for example, business partners, sub-contractors, analytics providers and search information providers) and may receive information about you from them.
When we receive information from other sources, we rely on them having the appropriate provisions in place telling you how they collect data and who they may share it with. We carefully check our sources to ensure that we only receive your information when it is lawful for us to do so.
5. Purposes For Which We Will Use Your Personal Data
This section explains how we will use
We use the information held about you in the following ways:
- carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products
andservices that you request from us;
- respond to your
enquiriesor to process your requests in relation to your information;
- let you know about important changes or developments to the Site or our services;
- provide and
personaliseour services generally;
- administer records of our services;
- carry out market research campaigns;
- provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about; and
- contact you to let you know about other products and services that we offer and feel may be of interest, as set out in the section on Communications;
Information we collect about you. We will use this information to:
- administer the Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- improve the Site to ensure that content is presented in the most effective manner for you and for your computer; and
- be used as part of our efforts to keep the Site safe and secure;
Information we receive from other sources. We may combine this information with information you give to us and
We must have a lawful basis for processing your personal data. We consider that we have a lawful basis where:
- you have given us consent to do so for the specific purposes which we have told you;
- it is necessary for us to do so to enable us to provide you with the services that you have requested from us – for example, responding to your
- it is necessary in order to
fulfilour legitimate interests (or those of a third party), and your interests and fundamental rights do not override those interests; or
- the law otherwise permits or requires it.
Where we process your personal data on the basis of our legitimate interests, these are our (or our third party’s) interests in providing our services to you in an efficient and secure manner.
This section is to explain how we will ensure that you only receive communications that you wish to receive.
We want to ensure that you are informed and aware of the best products, services, promotions
If you have provided your consent to receive marketing communications from us and you change your mind, you can change your preferences and unsubscribe at any time by following the unsubscribe instructions provided in the materials or contacting us at firstname.lastname@example.org.
We may send you communications such as those which relate to any service updates (e.g. service disruption) or provide customer satisfaction surveys. We consider that we can lawfully send these communications to you as we have a legitimate interest to do so, namely to effectively provide you with the best service we can and to grow our business.
7. Who Will Have Access To Your Personal Data
We take your privacy seriously and have implemented appropriate physical, technical and
8. Who Else Might We Share Your Personal Data With
We may share your personal data with you, and where we have obtained your consent to do so, your associates and your representatives.
We may disclose your personal data to law enforcement agencies or court to the extent necessary for purposes including preventing, investigating, detecting, and prosecuting criminal
We may share your personal data with the following third parties who assist us with administering the provision of our services to you:
- business partners, suppliers
andsub-contractors for the performance of any contract we enter into with them or you analytics and search engine providers that assist us in the improvement and optimisationof our site;
- agents we engage to perform functions on our behalf including sending customer communications,
analysingdata, providing marketing assistance, processing payments, collecting debts owed to us, researching customer satisfaction and providing customer service .Theyhave access to personal data needed to perform their functions, but may not use it for other purposes.
We may also pass aggregated data (such as statistical or demographic) on the usage of our site (e.g. we might disclose the numbers of visitors to our site that come from different geographic areas) to third parties but this will not include information that can be used to identify you personally.
If a business transfer or change of business ownership takes place or is envisaged, we may transfer your personal data to the new owner (or a prospective new owner). If this happens, you will be informed of this transfer.
9. How Do We Protect Your Personal Data
This section explains how we keep your personal data safe and where it will be held.
We take your privacy seriously and are committed to maintaining the privacy and security of the personal data you provide to us, and the choices you have regarding our collection and use of your personal data.
Once we have received your personal data, we follow strict security procedures as to how your personal data is stored and used, and who sees it, to help stop any
We shall not transfer your personal data outside of the European Economic Area (EEA). If the United Kingdom ceases to be part of the EEA, we shall not transfer your personal data without implementing measures to ensure an adequate level of protection for your personal data.
Unfortunately, the transmission of your personal data via the internet is not completely secure and although we do our best to protect your personal data, we cannot guarantee the security of your data transmitted to us over the internet and you acknowledge that any transmission is at your own risk.
10. How Long Do We Keep Your Personal Data?
This section explains the length of time that we will retain your personal data.
We will keep your personal data for no longer than is necessary for the purposes for which it was obtained. [The criteria for determining the duration for which we will retain your personal data are as follows:
- we will retain your personal data in a form that permits identification only for as long as:
- we maintain an ongoing relationship with you; or
- your personal data is necessary
inconnection with the lawful purposes set out in this policy for which we have a valid legal basis.
- the duration of:
- any applicable limitation period under applicable law (i.e. any period during which any person could bring a legal claim against us in connection with your personal data, or to which your personal data may be relevant); or
- an additional reasonable period following the end of such applicable limitation period.
- in addition, if any relevant legal claims are brought, we may continue to process your personal data for such additional periods as are necessary
inconnection with that claim.
During the periods in paragraphs 2(a) and 2(b) above, we will restrict our processing of your personal data to the storage of, and
After this period your personal data will be
Any third parties that we engage will keep your data stored on their systems for as long as is necessary to provide the relevant services to you or us. If we end our relationship with any third party providers, we will make sure that they securely delete or return your personal data to us.
We may retain personal data about you for statistical purposes. Where data is retained for statistical purposes it will always be
11. What Are Your Rights?
This section explains that you have a number of rights in relation to your personal data. There are circumstances in which your rights may not apply. You have the right to request that we:
- provide you with a copy of the information we hold about you;
- update any of your personal data if it is inaccurate or out of date;
- delete the personal data we hold about you – if we are providing services to you and you ask us to delete personal data we hold about you then we may be unable to continue providing those services to you;
- restrict the way in which we process your personal data;
- stop processing your data if you have valid objections to such processing; and
- transfer your personal data to a third party.
For more information on your rights and how to use them, or if you would like to make any of the requests set out above, please contact us using the details provided in section 13.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
As explained in section 6 on Communications even if you consented to the processing of your personal data for marketing purposes (by ticking the relevant box or by requesting information about services), you have the right to ask us to stop processing your personal data for such purposes. You can exercise this right at any time by contacting us at email@example.com.
We use Google Analytics which collects information about how visitors use the Site. The cookies collect information in an anonymous
13. Who Can You Ask For More Information?
If you have any questions or concerns about how we handle your personal data, you can contact us at firstname.lastname@example.org or 020 7692 565.
If you are unsatisfied with our response to any data protection issues you raise with us, you have the right to make a complaint to the Information Commissioner’s Office (ICO). The ICO is the authority in the UK which is tasked with the protection of personal data and privacy.