Table of Contents
- Definitions used in this Policy
- Data protection principles we follow
- What rights you have regarding your Personal Data
- What Personal Data we gather about you
- How we use your Personal Data
- Who else has access to your Personal Data
- How we secure your data
- Information about cookies
- Social sharing and tracking
- Third-party links
- Contact information
Personal Data – any information relating to an identified or identifiable natural person.
Processing – any operation or set of operations which is performed on Personal Data or on sets of Personal Data.
Data subject – a natural person whose Personal Data is being processed.
Child – a natural person under 16 years of age.
We/us (either capitalised or not) – Nurture Media
Data Protection Principles
We promise to follow the following data protection principles:
- Processing is lawful, fair, transparent. Our processing activities have lawful grounds. We always consider your rights before processing Personal Data. We will provide you information regarding processing upon request.
- Processing is limited to the purpose. Our processing activities fit the purpose for which Personal Data was gathered.
- Processing is done with minimal data. We only gather and process the minimal amount of Personal Data required for any purpose.
- Processing is limited with a time period. We will not store your personal data for longer than needed.
- We will do our best to ensure the accuracy of data.
- We will do our best to ensure the integrity and confidentiality of data.
Data Subject’s rights
The Data Subject has the following rights:
- Right to information – meaning you have to right to know whether your Personal Data is being processed; what data is gathered, from where it is obtained and why and by whom it is processed.
- Right to access – meaning you have the right to access the data collected from/about you. This includes your right to request and obtain a copy of your Personal Data gathered.
- Right to rectification – meaning you have the right to request rectification or erasure of your Personal Data that is inaccurate or incomplete.
- Right to erasure – meaning in certain circumstances you can request for your Personal Data to be erased from our records.
- Right to restrict processing – meaning where certain conditions apply, you have the right to restrict the processing of your Personal Data.
- Right to object to processing – meaning in certain cases you have the right to object to processing of your Personal Data, for example in the case of direct marketing.
- Right to object to automated processing – meaning you have the right to object to automated processing, including profiling; and not to be subject to a decision based solely on automated processing. This right you can exercise whenever there is an outcome of the profiling that produces legal effects concerning or significantly affecting you.
- Right to data portability – you have the right to obtain your Personal Data in a machine-readable format or if it is feasible, as a direct transfer from one Processor to another.
- Right to lodge a complaint – in the event that we refuse your request under the Rights of Access, we will provide you with a reason as to why. If you are not satisfied with the way your request has been handled please contact us.
- Right for the help of supervisory authority – meaning you have the right for the help of a supervisory authority and the right for other legal remedies such as claiming damages.
- Right to withdraw consent – you have the right withdraw any given consent for processing of your Personal Data.
Data we gather
We do not collect any Special Category Data about you. Special Category Data is Data such as your race, ethnic origin, religion, health information and sexual orientation. We do not intend to collect or knowingly collect information from children. We do not target children with our services. We do not carry out automated decision making or any type of automated profiling. We may process your Personal Data without your knowledge or consent if we are legally obliged to do so. The types of Data we gather is as follows:
Communication Data includes any communications you send to us (i.e. through a contact form on our website, by email, text, social media or any other communication that you send to us). Data processed might include your e-mail address, name, postal address etc – mainly information that is necessary for communicating with you or to enhance your customer experience with us.
Customer Data includes Data relating to any purchases of products or services such as your name, email address, contact number, billing address, contact details and purchase history.
Technical Data includes Data about your use of our website such as your IP address, details about your browser, the type of device you use to access our website, your login history, length of visit to pages on our website, etc. We gather this Data from Google Analytics and from our security software. Technical Data also includes information that is automatically stored by cookies and other session tools. When you use our services or look at the contents of our website, your activities may be logged.
The IP address of visitors, user ID of logged in users, and username of login attempts are conditionally logged to check for malicious activity and to protect the site from specific kinds of attacks. Examples of conditions when logging occurs include login attempts, log out requests, requests for suspicious URLs, changes to site content, and password updates. This information is retained for 14 days.
User Data includes Data about how you use our website, together with any Data that you post for publication on our website in the form of a comment or review.
If you choose to login to our website with Facebook, with your consent we collect your public profile data. This data includes your first name, last name, email address, link to your social media profile, unique identifier and a link to your social profile avatar. This data is used to create your user profile at our website. You can revoke this consent at any time by emailing us.
Social Comment Data
If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.
Data from our partners
We gather information from our trusted partners with confirmation that they have legal grounds to share that information with us. This is either information you have provided them directly with or that they have gathered about you on other legal grounds.
Publicly available Data
We might gather information about you that is publicly available.
How we use your Personal Data
We use your Personal Data in order to:
- Provide our service to you. This includes for example registering your account; providing you with other products and services that you have requested; providing you with promotional items at your request and communicating with you in relation to those products and services; communicating and interacting with you; and notifying you of changes to any services.
- Enhance your customer experience.
- Fulfil an obligation under law or contract.
We use your Personal Data on legitimate lawful grounds and/or with your Consent. On the grounds of entering into a contract or fulfilling contractual obligations, we process your Personal Data for the following purposes:
- To identify you.
- To provide you a service or to send/offer you a product.
- To communicate either for sales or invoicing.
On the ground of legitimate interest, we process your Personal Data for the following purposes:
- To reply to communications sent to us.
- To send you personalised offers* (from us and/or our carefully selected partners).
- To administer and analyse our client base (purchasing behaviour and history) in order to improve the quality, variety, and availability of products/ services offered/provided.
- To enable us to properly administer our website and our business.
- To grow our business.
- To conduct questionnaires concerning client satisfaction.
- To keep records.
- To help us to decide our marketing strategy.
- To establish, pursue or defend legal claims.
As long as you have not informed us otherwise, we consider offering you products or services that are similar to or the same as your purchasing history/browsing behaviour to be our legitimate interest. With your consent we process your Personal Data for the following purposes:
- To send you newsletters and campaign offers (from us and/or our carefully selected partners).
- For other purposes we have asked your consent for.
- To enter you into competitions you have entered.
We process your Personal Data in order to fulfil obligation rising from law and/or use your Personal Data for options provided by law. We reserve the right to anonymise Personal Data gathered and to use any such data. We will use data outside the scope of this Policy only when it is anonymised. We won’t retain your Personal Data for longer than necessary to fulfil the purpose(s) we collected it for. We save your billing information and other information gathered about you for as long as needed for accounting purposes or other obligations deriving from law, but not longer than 7 years. We might process your Personal Data for additional purposes that are not mentioned here, but are compatible with the original purpose for which the data was gathered. To do this, we will ensure that:
- The link between purposes, context and nature of Personal Data is suitable for further processing;
- The further processing would not harm your interests; and
- There would be appropriate safeguard for processing.
We will inform you of any further processing and purposes. We will never share your Personal Data with any third party for their own marketing purposes. You can unsubscribe from our marketing communications at any time by following the opt-out links on any marketing message sent to you or by emailing us at firstname.lastname@example.org. If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc.
Who else can access your Personal Data
We do not share your Personal Data with strangers. Personal Data about you is in some cases provided to our trusted partners in order to either make providing the service to you possible or to enhance your customer experience. Some of our third party service providers are based outside of the EEA (in the US for example) so on some occasions, your Personal Data is transferred outside of the EEA in order to be processed. Whenever we transfer your Personal Data out of the EEA, we ensure at least one of the following safeguards is in place:
- We only transfer your Personal Data to countries that the European Commission have approved as providing an adequate level of protection for personal data; or
- We may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
- We use US-based providers that are part of EU-US Privacy Shield
Who we share your Data with
Our processing partners:
How we secure your data
We do our best to keep your Personal Data safe:
- We use safe protocols for communication and transferring data (such as HTTPS).
- We monitor our systems for possible vulnerabilities and attacks.
- We use a firewall.
- We use strong passwords for all accounts where Personal Data can be accessed.
- We use anonymising and pseudonymising where suitable.
- We use Dropbox to store backups of our website securely.
- Backup zip files are stored with hashed file names to prevent filename guessing and directory browsing is disabled.
Even though we try our best, we cannot guarantee the security of information. However, we promise to notify suitable authorities of data breaches. We will also notify you if there is a threat to your rights or interests. We will do everything we reasonably can to prevent security breaches and to assist authorities should any breaches occur. If you have an account with us, note that you have to keep your username and password secret.
Cookies and other technologies we use
- Necessary cookies – these cookies are required for you to be able to use some important features on our website, such as logging in. These cookies don’t collect any personal information.
- Functionality cookies – these cookies provide functionality that makes using our service more convenient and makes providing more personalised features possible. For example, they might remember your name and e-mail in comment forms so you don’t have to re-enter this information next time when commenting.
- Analytics cookies – these cookies are used to track the use and performance of our website and services
- Advertising cookies – these cookies are used to deliver advertisements that are relevant to you and to your interests. In addition, they are used to limit the number of times you see an advertisement. They are usually placed to the website by advertising networks with the website operator’s permission. These cookies remember that you have visited a website and this information is shared with other organisations such as advertisers. Often targeting or advertising cookies will be linked to site functionality provided by the other organisation.
Social sharing and tracking
Our contact details
Full name of legal entity: Nurture Media
Email address: email@example.com
Postal address: 36 Hylton Street, Birmingham, United Kingdom, B18 6HN
Our website address: www.nurturemedia.co.uk
Supervisory Authority ICO – ico.org