At European Dissemination Media Agency Limited, privacy is a serious matter and we are committed to protecting it.
1. ABOUT THIS POLICY
This policy outlines how European Dissemination Media Agency Limited handles your personal information. This includes when and why it is collected, how it is used, disclosed, and how it is protected. This policy adheres to the enhanced rights data subjects (living individuals in respect of whom personal information is processed) are now granted by the General Data Protection Regulation (GDPR) (EU 2016/679).
In accordance with GDPR, this policy explains when, why and how our company is governed by this Regulation:
- collect personal data about individuals;
- use this information;
- disclose this kind of data to others, when this is necessary and under certain conditions;
- keep secure and confidential this personal data.
1.2 WHAT ARE THE POLICY CHANGES
This policy may evolve over time so please check the date on this page to make sure that you have the latest version.
This policy was last updated on 14th of June 2018.
2. WHO WE ARE
European Dissemination Media Agency Limited (hereafter “EDMA”) is a private UK company. Whenever you deal with EDMA, the controller of your personal information will be EDMA. A ‘controller’ is a company that manages and decides why and how your personal information is processed.
Where this policy refers to “we”, “our” or “us” below, unless stated otherwise, it refers to the particular Company that is the controller of your personal information
3. HOW AND WHAT PERSONAL INFORMATION WE COLLECT
We may collect and process the following personal data:
Personal information you give to us: this is information about you that you give to us, entirely voluntarily, by entering information via:
- one of our websites;
- our mobile applications;
- social media platforms;
- corresponding with us by phone, email or otherwise.
The information is provided by you voluntarily. If you communicate with us, we may process the information contained in your communication. This information may include your name and contact information, the content of your communication and any metadata our website generates where you communicate with us using the contact form available on our website.
We will process that information so we can correspond with you and keep records of such correspondence. The reason we are processing this data is to ensure the proper administration of our business our “legitimate interest”.
Personal information we collect about you: We may automatically collect the following personal information:
- Details about your visits to our website(s), including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources you access;
- technical information, automatically collected, including anonymous data collected by the hosting server for statistical purposes, the Internet protocol (IP) address used to connect your computer or device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform. Please see our Cookies Policy for further information;
- any personal data which you allow to be shared that is part of your public profile or third party social network.
Personal information we may receive from other sources: We may obtain certain personal information about you from sources outside of our business from other third party companies; the personal information that is received may include, but not limited to name, email address and contact telephone numbers.
The remaining provisions of this policy also apply to any personal data we obtain from these sources.
4. HOW WE USE YOUR PERSONAL INFORMATION
We use the information we hold on you for the following purposes:
- For account administration: including opening up an account, verifying your identity, undertaking credit related searches, invoicing, managing credit limits and payments.
- For managing and performing our contracts with you: including answering enquiries, providing quotations, dealing with copy and specifications, placing orders, delivering goods to you or your customers and dealing with any issues arising.
- For marketing: monitoring your transactions with us to enable us to provide you with the most relevant offers and information to you and marketing to you unless you’ve told us not to.
4.2 THE LEGAL BASIS FOR OUR USES OF YOUR PERSONAL INFORMATION
|Legal basis||Type of processing|
Our legitimate interests are:
|Performance of a contract
The personal information you provide may be processed when it is necessary in order for us to:
|Compliance with legal obligations
Where we are under a duty to disclose or share your personal information in order to comply with a request from government or law enforcement officials.
Where we rely on your consent as the legal basis for processing your personal information, you may withdraw your consent at any time by contacting us using the details at the end of this Privacy e. If you withdraw your consent, our use of your personal information before you withdraw is still lawful
5. OTHERS WHO MAY RECEIVE OR HAVE ACCESS TO YOUR PERSONAL INFORMATION
5.2 OUR SUPPLIERS AND SERVICE PROVIDERS
We may disclose your information to our third party service providers, agents, subcontractors and other organisations for the purpose of providing products and/or services to us or directly to you on our behalf. These third parties may include cloud services providers (for hosting and email management), advertising agencies, administrative services or supplementary third parties that provide additional services to us.
When we use third party service providers, we only disclose personal information that is necessary for them to provide their service. We have a contract in place that requires them to protect your information and not to use it other than in accordance with our specific instructions and requests.
5.3 THIRD PARTIES
We work closely with various third parties to bring you a range of products and services which are complementary to those which we provide.
When you enquire about or purchase one or more of these products or services through us, the relevant third party may use your details to provide you with information and to carry out their obligations arising from any contracts you have entered into with them.
We may also disclose your personal information to third parties in the following circumstances:
- If we sell or buy any business or assets, in which case we may need to disclose certain personal data to the prospective seller or buyer of such business or assets.
- if all or most of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets.
- if we are under a duty to disclose or share it in order to comply with any legal obligation or when this disclosure is required by applicable laws, court orders or government regulations, to detect or report a crime, to enforce or apply the terms of our contracts or to protect the rights, property or safety of our visitors and customers;
- if you have consented to the disclosure.
However, we will always take steps to ensure that your privacy rights continue to be protected.
6. WHERE WE STORE YOUR PERSONAL INFORMATION
Your data is held in a secure database with restricted access and multi-factor authentication. Systems are in place to ensure protection against unauthorised or unlawful processing and against accidental loss, destruction or damage. We will always take necessary steps to ensure that appropriate security measures are taken so that your privacy rights continue to be protected.
Your data will remain within the European Economic Area (EEA) However, due to the global nature of the products and services we offer we may transfer your data outside of the EEA. If we do transfer your information outside of the EEA, we will always take necessary steps to ensure that appropriate security measures are taken so that your privacy rights continue to be protected, as detailed in this policy. These steps include imposing contractual obligations on the recipient of your personal data and ensuring that recipients are subscribed to recognised ‘international frameworks’ that ensure the same protection.
If you use our services whilst you are outside the EEA, your personal data may be transferred outside the EEA, in order for us to provide you with the services.
7. HOW LONG WE KEEP YOUR PERSONAL INFORMATION FOR
The duration of time that we retain your collected personal data is determined by us, in a reasonable manner, based on a number of factors. These include the purpose for which we use the information and our obligations under other laws.
We only preserve personal data in an identifiable format for the period of time that is necessary.
Your personal information may be required to establish, bring or defend legal claims. In this case, we retain your personal data for 7 years after the last occasion on which we used the information in one of the ways that is specified in How we use your personal information in section 4.
The only exceptions to this are where:
- the law requires us to retain your personal data for a longer period, or to delete it sooner;
- you exercise your right to have the information deleted (where it applies) and we do not need to retain it in connection with any of the reasons permitted in this section 7;
- we may need to retain your personal data where this is necessary to comply with our legal or regulatory obligations, or to protect the vital interests of another natural person.
8. WHAT ARE YOUR ‘DATA SUBJECT’ RIGHTS
Subject to applicable law and certain exemptions, restrictions or circumstances, you may have the right:
- To access your personal data;
- To correct, modify and update your personal data;
- To erase your personal data or restrict its processing;
- To withdraw your consent;
- To object to our use of your personal data for automated decisions made about you;
- To ask us to transfer your personal data in a structured data file to you or to another service provider if it is technically possible (data portability);
- To lodge a complaint with the competent supervisory authority and seek a judicial remedy.
These rights may be exercised by written request sent to the contact details that will be provided to you at the time of data collection. A reply will be provided to you within a reasonable delay, in accordance with the applicable regulations.
If you wish to exercise any of your rights, we may ask you for information to confirm your identity.
8.1 ACCESSING YOUR PERSONAL INFORMATION
You have the right to request a copy of the personal information that we hold about you. To make a request, please email or write to us at the address at the end of this policy. You do not have to pay us a fee to access your personal information unless we believe your access request is unfounded, repetitive or excessive. In this case we may charge you a reasonable fee to access your personal information or we may decide not to comply with your request. We will notify you if this is the case.
8.2 CORRECTING AND UPDATING YOUR PERSONAL INFORMATION
The accuracy of your information is important to us and we are continually developing ways in which to make it easier for you to review and amend the personal information that we retain. In the meantime, if you change your name or address/email address, or you find that any of the information that we hold about you is incorrect or out of date, please let us know by contacting us via the means described at the end of this policy.
8.3 WITHDRAWING YOUR CONSENT
You may withdraw your consent as the legal basis for processing your personal information at any time. To do this, please contact us via the details below. If you withdraw your consent, our use of your personal data prior to your withdrawal remains lawful.
Data Protection Co-ordinator
European Dissemination Media Agency Limited
Staffordshire University Business Park
Staffordshire Technology Park
Telephone: +44 (0)1785 336398
8.4 OBJECTING TO OUR USE OF YOUR PERSONAL INFORMATION AND AUTOMATED DECISIONS MADE ABOUT YOU.
You may object to us using your personal data for these purposes by contacting us in writing by any of the means stated at the end of this policy. We will temporarily stop processing your personal information in line with your objection request until we have investigated the matter further, except for the purposes for which we are sure we can continue to process your personal information. If we agree that your objection is justified, in accordance with your rights under the data protection laws, we will permanently cease using your information for those purposes. If we do not agree, we will provide you with our justification as to why we are under obligation to continue using your data.
We will automatically comply with your request if you object to us using your personal data for direct marketing purposes. Please email us if you would like to do so.
To contest any decision that is made about you based on automated processing, please contact the data protection department using the details at the end of this policy.
8.5 ERASING YOUR PERSONAL INFORMATION OR RESTRICTING ITS PROCESSING
You have the right to ask for your personal information to be removed from our systems. You can do this by emailing or writing to us at the address stated at the end of this policy.
You may also ask us to stop or limit the processing your personal data in the following situations:
where you believe we are unlawfully using your personal data,
you have objected to our use of your personal data and have a pending investigation, or you require us to retain your data in connection with legal proceedings.
8.6 TRANSFERRING YOUR PERSONAL INFORMATION IN A USEABLE FORMAT
Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with your contract, you may request a copy of that information in a useable format. This means providing your personal information electronically in a structured, commonly used computer format, such as a Microsoft Excel File or XML.
You may request that your personal information is directly sent to another service provider. We will do so if it is technically feasible. If your personal information concerns other individuals, or we have another lawful reason to withhold that information, we may not provide you with a copy of your personal information in a useable format.
8.7 COMPLAINING TO THE UK DATA PROTECTION REGULATOR
You have the right to complain to the Information Commissioners Office (ICO) if you have any concerns about the manner in which we have processed your personal information. Please visit the ICO’s website for further details.
9. SECURITY / COOKIES / LINKS / SOCIAL PLUGINS
9.1 HOW WE ENSURE SECURITY AND CONFIDENTIALITY OF YOUR DATA
EDMA uses technical and organisational security measures to protect all personal information that is supplied by you and managed by us against manipulation, loss, destruction, and access by any third party. We are continually improving our security measures in line with advancements in technological developments.
The transmission of information via the internet is unfortunately not completely secure. Although we will do our best to safeguard and protect your personal data, we cannot guarantee the security of your information whilst it is in transit to our website, and all transmission is at your own risk.
Where you have chosen a password that enables you to access an account, you are solely responsible for keeping this password private and confidential. We request that you not to share your password with anyone.
9.2 HOW COOKIES WORK
“Cookies” are small pieces of information sent to your device and stored on its hard drive to allow our website to recognise you when you visit.
9.3 LINKS TO OTHER WEBSITES
Additionally, if you have linked to our website from a third party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party website. We recommend that you check the policy of the third party website.
9.4 SOCIAL PLUGINS
We may use the social plugins (buttons) of popular social networks like Facebook, Google+ and Twitter.
After activation, the server of the respective social network establishes a direct link. The contents of the social plugins button are then transmitted from the social network directly to your browser, and are then incorporated in our website. Following activation, the social network can retrieve data independently of whether you interact with the button or not. A social network cannot assign a visit to any websites that are operated by our other group companies unless, and until, you activate the respective button.
If you are a member of a social network and you do not wish it to combine the data that has been retrieved from your visit to our websites with your personal membership data of that social network, you must log out from the social network before activating the buttons. We have no influence over the range of data that is collected by the social networks via their buttons. The information on the purpose and extent of the collected data can be found in the data use policies of the relevant social networks.
In order to send you marketing information directly from us via email/SMS (where applicable), we will collect your marketing preferences
We will only send you marketing information and communications if you have consented to receive such information directly from us.
With your consent, We may contact you with targeted advertising delivered online through social media and platforms that are operated by other companies, by using your personal data. Unless you object, we may use your personal information to customise and improve the relevance of direct marketing to you.
Occasionally, we may request that you refresh your marketing preferences by asking you to confirm that you consent to continue receiving marketing information from us.
11. CONTACT US
If you have any questions, comments or requests about the processing of your personal information, or you wish to contact us to amend or update your marketing preferences, please contact the EDMA Data Protection Co-ordinator using the following details.
Data Protection Co-ordinator
European Dissemination Media Agency Limited
Staffordshire University Business Park
Staffordshire Technology Park
Telephone: +44 (0)1785 336398
12. ABOUT EUROPEAN DISSEMINATION MEDIA AGENCY LIMITED