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ALDER Media Limited Privacy Policy

Last updated: July 2018

1. About Alder

We are Alder Media Limited (Alderweour or us) a company registered in England and Wales under company number 07470843 whose registered office is at 30 Stamford Street, London, SE1 9LQ. We are registered as a data controller with the Information Commissioner’s Office in the UK and our registration number is ZA440186.

2. About This Privacy Policy

This privacy policy applies to the personal data we collect about you through our website (www.alder-uk.com) (Site), by post, by telephone, by email, through our social media platforms and when you otherwise communicate with us.

This privacy policy may change from time to time and, if it does, the up-to-date version will always be available on our Site. We will also tell you about any important changes to our privacy policy.

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 enquiries through the Site or correspond with us by phone, email or otherwise. This also includes information you provide when you request information, voluntarily complete surveys, provide feedback and when you report a problem with our Site.

Personal data we may process about you:

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:

Direct interactions:

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:

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), to the extent that you choose to make your profile visible).

Automated technologies or interactions:

If you use our Site, we automatically collect the following information:

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 situations this will be anonymised but we collect and process this data to ensure that our site is functioning properly and that our customer experience is to the standard that you and we expect.

We also use cookies on our Site. Please see section 12 on cookies for more information.

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 personal data you provide to us in order to carry out the activities relevant to the provision of our services to you.

We use the information held about you in the following ways:

Information you give to us. We will use this information to:

Information we collect about you. We will use this information to:

Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).

We must have a lawful basis for processing your personal data. We consider that we have a lawful basis where: 

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.

5. Communications

This section is to explain how we will ensure that you only receive communications that you wish to receive.

Marketing communications

We want to ensure that you are informed and aware of the best products, services, promotions and events that we can offer you. By consenting to receive additional communications (by mail, telephone, SMS, text/picture/video message, app push notifications or email) from us and any named third parties that feature at the point of obtaining consent in respect of such information, we will process your personal data in accordance with this privacy policy.

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 [email protected].  

Service communications

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

This section is to explain who, within Alder, will have access to your data. Your personal data will only be seen or used by our employees who have a legitimate business need to access your personal data for the purposes set out in this privacy policy.

We take your privacy seriously and have implemented appropriate physical, technical and organisational security measures designed to secure your personal data against accidental loss, destruction or damage and unauthorisedaccess, use, alteration or disclosure.

8. Who Else Might We Share Your Personal Data With

This section will inform you of who we share your personal data with and why. Except as explained in this privacy policy, we will not share your personal data without your consent unless required to do so by law.

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 offences; preventing threats to public security in accordance with applicable law; or validating a claim.

We may share your personal data with the following third parties who assist us with administering the provision of our services to you:

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 unauthorised access.

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:

  1. 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 in connection with the lawful purposes set out in this policy for which we have a valid legal basis.

                                    plus

  1. 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.

                                    and

  1. in addition, if any relevant legal claims are brought, we may continue to process your personal data for such additional periods as are necessary in connection 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 maintaining the security of, those data, except to the extent that those data need to be reviewed in connection with any legal claim or obligation under applicable law.

After this period your personal data will be anonymised so that you are no longer identified or identifiable from such information, or securely deleted/destroyed.

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 anonymised, meaning that you will not be identifiable from that data.

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:

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 protected].

12. Cookies

This section explains how the Site uses cookies. Cookies are text files containing small amounts of information which are downloaded to your personal computer, mobile or other device when you visit a website. Alder may set and access cookies on your computer or mobile device to track and store preferential information about you. We may gather anonymous information about users through cookie technology on an individual and aggregate level. Such information is used within Alder internally and is only shared with third party advertisers, if any, on an aggregated or non-personally identifiable basis.

We use Google Analytics which collects information about how visitors use the Site. The cookies collect information in an anonymous form, and tell us about users’ behaviour overall, such as the length of stay on our Site or the average number of pages a user views. We use the information to compile information which helps us to improve the Site. For more information about Google Analytics’ privacy policy please click here.

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 [email protected] 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.