PRIVACY POLICY
We at MediaBase Direct Limited (‘MBD’
and the Data Controller) respect the privacy of our visitors and Customers and
are committed to preserving your online safety by preserving your privacy at
any time you visit or communicate with our site.
Our Terms of Use and Privacy Policy
sets out the data processing practices carried out through the use of internet
and other electronic devises by the Company.
This Privacy Policy is reviewed annually
and we recommend that you therefore regularly review this Policy. The version
was last updated on 25th May 2018.
All personal data captured will be
processed and held in accordance with the requirements of the General Data
Protection Regulation (‘GDPR’). MBD is
registered under the Data Protection Act with registration number Z7133579.
The Data Controller is Anil Jain who
can be contacted at info@mediabasedirect.com.
We have
appointed a data protection officer (DPO) who is responsible for overseeing
questions in relation to this privacy notice. If you have any questions about
this privacy notice, including any requests to exercise your legal rights
contact the DPO Anil Jain at info@mediabasedirect.com.
1.
Definitions:
1.1.1 Automated Processing shall mean any form of automated processing of Personal Data to evaluate
aspects relating to an individual and analyse or predict aspects of
individuals.
1.1.2 Personal Data shall mean any information relating to an identified or Identifiable
Natural Person. Personal Data includes special categories of Personal Data and pseudonymised
Personal Data but evades anonymous data, or data that has had the identity of
an individual permanently removed.
1.1.3 Pseudonymised Data: Shall mean replacing information that directly or indirectly identifies
an individual with one or more artificial identifiers or pseudonyms so that the
person to whom the data relates cannot be identified without the use of
additional information.
1.1.4 Identifiable Natural Person shall mean a person who can be identified, directly or indirectly by
reference to an identifier such as a name, identification number, location
data, online identifier, one or more factors specific to the physical,
physiological, genetic, mental, economic, cultural or social identity of that
natural persons.
1.1.5 Special Categories of Personal Data shall mean Personal Data revealing racial or ethnic origin, political
opinions, religious or philosophical beliefs, or trade union membership,
processing of genetic data, biometric data for the purpose of identifying an
Identifiable Natural Person, data concerning health, sex life, sexual
orientation.
1.1.6 Data shall
mean " means information of any kind,
however represented whether comprising words, database entries, numbers,
graphs, maps, pictures, sketches or otherwise in any other form and on any
media
1.1.7 Processing shall mean any operation or set of operations which is performed on
Personal Data or on sets of Personal Data whether or not by automated means
such as collection, recording, organization, structuring, storage, adaption,
alteration, retrieval, consultation, use, disclosure by transmission,
dissemination, restriction, erasure or destruction.
1.1.8 Profiling
shall mean any form of automated processing of Personal Data consisting of the
use of Personal Data to evaluate certain personal aspects relating to a natural
person, in particular to analyses or predict aspects concerning the natural
person’s performance at work, economic situation, health, personal preferences,
interests, reliability, behavior, location or movements
1.1.9 App
shall mean any computer and mobile based application
1.1.10 Website
shall mean an internet website for MBD
1.1.11 MBD
shall mean Media Base Direct Limited (company number 2651463) whose registered
office is at TML House, The Anchorage, Gosport, Hampshire PO12 1LY. MBD also trades under a number of Trading Styles.
1.1.12 Trading Style is when MBD trades under any name other than MediaBase Direct
Limited. MBD also trades as ‘leadr’
‘Refinemydata’ ‘CUSTR’ and ‘bookmysunbed’.
2.
Data
MBD may collect and process Data and
Personal Data from you, either automatically or manually during the operations
of our Websites, Apps, forms you may fill out (including part completed forms)
2.1 Manually requested Data and Personal
Data Collected from You
2.1.1 MBD may request the following manual information direct from you:
1)
Identity data such as first name,
maiden name, last name, marital status, title, date of birth and gender
2)
Contact data such as billing address,
delivery address, email address and telephone number.
3)
Financial data such as bank account
and payment card details.
4)
Personal descriptions
5)
Details about the nature of your
enquiry.
6)
Photographs (only if required in
order for MBD to provide the service)
7)
Transaction data including details about
payments to and from you and other details of products /services purchased from
us.
8)
Technical data including IP address,
login data, browser type and version, time zone setting and location, browser
plug in types, operating system and platforms and other devices used to access
the company or any Trading Style Websites.
9)
Profile data including username,
password, feedback and survey responses.
10)
Usage data including how you use our
website products and services.
11)
Marketing and communications data.
2.1.2 Personal Data is collected on any forms (including part completed forms)
you may fill out on our Website or Apps.
2.1.3 If for any reason you communicate with our personnel, MBD may collect
information as listed above.
2.1.4 You
may give the MBD any Data and Personal Data by submitting any information (as
listed above) or Data Upload onto any App, Website, Company server or other
device owned by the Company. The Data may include information you provide when
you report a problem with any App, Website or other device owned by the
Company.
Data and Personal Data which may be Automatically
collected:
2.2
Information about your visit to any App,
Website or other device collected through the use of Cookies, Web server logs,
including (but not limited to) IP address, the full Uniform Resource Locators
(URL) clickstream to through and from our site (including date and time);
products you viewed or searched for; page response times, download information
errors, length 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 service number. Such
information is necessary to enable the function of the Live Chat feature
offered to any person visiting MBD’s Websites, Apps or other devices.
2.3
Technical Data
2.4
Profile Data
2.5
Usage Data
2.6
We also collect, use and share aggregated data
such as statistical or demographic data for any purpose. Such data does not directly
or indirectly reveal your identity.
2.7
Where we need to collect personal data by law
or under the terms of the contract with you and you fail to provide data when
requested we may not be able to perform the contract we have or trying to enter
into with you. In this case we may have to cancel a product or service you have
with us.
The Company may receive information about
you if you use any of the other Websites operated or the other services MBD
provide.
The information and Personal Data
collected is limited to what is necessary for MBD to provide a service to you.
The information MBD hold will be
accurate, and kept up to date (where necessary) however MBD are not responsible
if you have inputted incorrect Data but you will have the right of
rectification of inaccurate Personal Data.
MBD will not collect Special
Categories of Personal Data.
3.
Cookie Usage
There are instances where we may use
cookies to gather information regarding our services in a mathematical
collection for our website and our advertisers.
Any information collected will not
have any identifying data. It is statistical data about our visitors and how
they have used our site. No Personal Data will be shared that could identify
you.
We may assemble information about
your common internet use with a cookie file. When used, the cookies are
downloaded to your computer automatically. The cookie is stored on the hard
drive, with transferred information. The data sought by the cookie helps us
improve our website and any service offered to you.
We use cookies to identify you when
you visit any website of MBD and any of its Trading Styles and to keep track of
your browsing patterns.
Your browser has the ability to
decline cookies. This is done by setting your browser options to decline all
cookies.
Our advertisers may download cookies
to which we have no control. If used, these cookies are downloaded by clicking
on an advertisement found on our website
|
Site |
Cookies |
Description |
|
svSession |
This
cookie is essential for the CMS system to recognise you in the system once
you have logged in. |
|
|
__utma |
This
cookie is essential for the CMS system to recognise you in the system once
you have logged in. |
|
|
X-Auth-Token |
This
cookie is essential for the CMS system to recognise you in the system once
you have logged in. |
|
|
laravel_session |
This
cookie is essential for the CMS system to recognise you in the system once
you have logged in. |
|
|
laravel_session |
This
cookie is essential for the CMS system to recognise you in the system once
you have logged in. |
|
|
__lc.visitor_id.8012441 |
This
cookie is essential for the online chat to recognise you in the system once
you have logged in. |
|
|
_datacapturev2_session |
This
cookie is essential for the CMS system to recognise you in the system once
you have logged in. |
Cookies
we use:
|
__livechat |
This cookie is
essential as it remembers the info of the visitor entering your website. |
|
|
____livechat_lastvisit |
This cookie is
essential as checks visitor's last visit. |
|
|
common_iwcs_0 |
This cookie is essential
as it synchronises the communication between opened chat tabs. |
|
|
incap_ses_ |
This cookie is
essential as it provides DDoS LiveChat protection |
|
|
notification[new_messages] |
This cookie is
essential as it informs about the pending LiveChat messages. |
|
|
message_text |
This cookie is
essential as it keeps text that is written in textbox. |
|
|
SERVERID_L |
This cookie is
essential as it is used by LiveChat's load balancer. |
|
amplitude |
This cookie is
essential as it provides web and mobile analytics for LiveChat. |
|
|
__adroll |
This cookie is
essential to be able to use AdRoll’s retargeting platform. |
|
|
_________________________________ |
_________________ |
______________________________ |
|
|
|
|
|
|
|
|
4.
Data
Use- Why :
4.1 The
Personal Data collected is used for a specified purpose and is necessary for the
performance of our Services, a legitimate interest pursued by MBD or to comply
with a legal obligation to which MBD is subject.
4.2 We have set
out below on table format, a description of some of the ways we plan to use
your personal data and the legal basis we rely on to do so.
|
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate
interest |
|
To register you as a new customer |
(a) Identity (b) Contact |
Performance of a contract with you |
|
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due
to us) |
|
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records
updated and to study how customers use our products/services) |
|
To enable you to partake in a prize draw, competition or
complete a survey |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how
customers use our products/services, to develop them and grow our business) |
|
To administer and protect our business and this website
(including troubleshooting, data analysis, testing, system maintenance,
support, reporting and hosting of data) |
(a) Identity (b) Contact (c) Technical |
(a) Necessary for our legitimate interests (for running our
business, provision of administration and IT services, network security, to
prevent fraud and in the context of a business reorganisation or group
restructuring exercise) (b) Necessary to comply with a legal obligation |
|
To deliver relevant website content and advertisements to you
and measure or understand the effectiveness of the advertising we serve to
you |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests (to study how customers
use our products/services, to develop them, to grow our business and to
inform our marketing strategy) |
|
To use data analytics to improve our website, products/services,
marketing, customer relationships and experiences |
(a) Technical (b) Usage |
Necessary for our legitimate interests (to define types of
customers for our products and services, to keep our website updated and
relevant, to develop our business and to inform our marketing strategy) |
|
To make suggestions and recommendations to you about goods or
services that may be of interest to you |
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile |
Necessary for our legitimate interests (to develop our
products/services and grow our business) |
4.3 Please note that your Personal Data may be used to
send you details of the products and or services we offer and have identified
as likely to be of interest to you. We
will not do so without first obtaining your Consent. You will be provided with the Opt-In
statement before MBD collects any information.
If it any point you would like to opt out of receiving communications
from us please contact info@mediabasedirect.com.
4.4 You are able to withdraw your Consent at any time.
4.5 From time to time we would like to send you offers
from selected third party companies that offer goods and services that we feel
would be of interest to you. You may at
any time withdraw your consent by contacting info@mediabase.com
5.
Personal Data Storage
5.1 Personal Data will be stored on
secure servers. Transaction data is encrypted for your safety.
5.2 You should understand Data via
online transmission is not completely secure. We cannot guarantee full
protection and security, only that we take all reasonable action to protect
information sent to us electronically. Transmission of any data by you is at
your own risk. Where applicable you may be given access to sections of our site
that require a password. You are responsible for the passwords safety and
confidentiality.
5.3 MBD will only retain your
Personal Data for as long as necessary to fulfill the purpose we collected it
for including for the purposes of satisfying any legal, accounting or reporting
requirements
5.4 To determine the appropriate
retention period for Personal Data we consider the amount, nature and
sensitivity of the Personal Data, the potential risk of harm from unauthorised
use or disclosure of your personal data and whether we can achieve those
purposes through other means.
5.5 In some circumstances we may
anonymise your personal data (so that it can no longer be associated with you)
for research or statistical purposes in which case we may use this information
indefinitely without further notice to you.
6.
Disclosing
Customer Data:
We require
third parties to respect the security of your data and to treat it in
accordance with the law
7.
Third Party Links
Third party links may be discovered
on our site. These third party links have their own privacy policy, which you
agree to when you click on the link. We are not responsible nor do we accept
responsibility for third party links. Our liability covers us only on our site,
and thus we do not accept liability for third party links as we have no control
over them.
8.
Profiling
MBD will not process your Personal
Data by Profiling.
9.
Your Rights
9.1 Information Accessibility:
1. You have a
right to see your Personal Data unless providing a copy adversely affects the
rights and freedoms of others. If you request additional copies of Data a
reasonable fee may be charged.
2. The Data
Controller must respond within one month.
This may be extended by a further two months if the request is complex
or there are numerous requests and the Data Controller will inform you of such
a delay.
3. You have a
right to obtain info about the Data Controller processing including:
a) The purpose of data processing
b) Categories of data processing
c) Recipients of the data
d) How long the data is stored.
e)
The source of the Personal Data if it has not come from you.
9.2 Right to Rectification:
1.
You have the right to rectification of any inaccurate Personal Data.
2.
You have the right to request incomplete information is completed.
9.3
Right to Erasure:
1.
You have a right for MBD to erase your Personal Data in the following
circumstances:
a. the Personal
Data is no longer required for the purpose in which they were requested.
b. You withdraw
your Consent.
c. You object to
the processing of your Personal Data
2. MDB may refuse
to act on the request if continued retention of the Personal Data is necessary
for:
a.
Exercising the right of freedom and expression.
b.
Complying with a legal obligation
c.
Performance of a task carried out in public interest.
d.
Establishment exercise or defense of legal claims.
e.
Exercising official authority vested in Data Controller
f. Public health reasons
consistent with the exceptions for processing Personal
Data such as health
information.
9.4 Right to Restrictions of Processing
1. You have the right to restrict the processing
of your Personal Data under certain circumstances:
a. If you contest to the accuracy of the data the Data Controller must
restrict the processing until it can verify its accuracy.
b. The processing is unlawful
c. The Data Controller no longer needs to process the data and the Data
Subject needs the data for establishment, exercise or defense of legal claims.
b.
Where you object to processing that
relies on public interest or a third party’s legitimate interest the Data
Controller must restrict processing until it can verify whether the third
party’s or Data Controller’s legitimate interest overrides your interest.
5.
Where you exercise the right of
restriction the company can continue to store the Personal Data but will only
process it:
a.
With your consent
b.
To establish, exercise or defend
legal claims
c.
To protect the rights of another
individual or legal entity
d.
For important public interest reasons
9.5
You can object to Data Processing under certain circumstances, including:
a) For direct
marketing purposes
b) For
scientific, or historical research or statistical purposes
c) Profiling in
order to perform a task in the public interest or the Data Controller or Third
Party’s legitimate interests unless the Data Controller demonstrates a
compelling legitimate ground for processing the Personal Data that overrides
your interest or if the Data Controller needs to process the data to establish
exercise or defend legal claims.
9.6
Data Portability
1. You have the right to:
a. Receive a copy of the Personal Data in a commonly used & readable
format
b. Transmit the Personal Data to another Data Controller
c. Have the personal data transmitted directly from one Data Controller to
another where technically possible.
2. You can only exercise this right if:
a. The personal data relates to you and can clearly be linked to you
b. The personal data was provided to the Data Controller by you
3. The Data Controller can refuse or restrict this right if data
portability will adversely affect the rights of third parties.
9.7
Automated Decision Making Objection Rights
1. You have a right to not be subject
to automated decision making including profiling unless the automated decision
is necessary for exercising or performing a contract with you or if you have
provided consent.
10.
Contacting Us
Please feel free to contact us with
queries, requests, or comments you may have about our Privacy Policy. We
welcome any communication via the email address supplied here: info@mediabasedirect.com
Last reviewed: 25th
May 2018
11. How to exercise your rights:
11.1 If you wish to exercise any of
the rights outline in Clause 9 of this policy please contact the Data
Controller at info@mediabasedirect.com
12.
Disputes
1. You have the right to make a
complaint at any time to the Information Commissions Office (ICO), the UK
supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns
before you approach the ICO so please contact us in the first instance.