BACKGROUND:
Bloomin Good understands that your privacy is important to you and that you care about how your personal data is used. We OR I respect and value the privacy of everyone who visits this website, top1media.co.uk (“Our OR My Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our OR my obligations and your rights under the law.
Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is deemed to occur upon your first use of Our OR My Site AND/OR You will be required to read and accept this Privacy Policy when signing up for an Account. If you do not accept and agree with this Privacy Policy, you must stop using Our OR My Site immediately.
In this Policy the following terms shall have the following meanings:
“Account”
means an account required to access and/or use certain areas and features of Our OR My Site;
“Cookie”
means a small text file placed on your computer or device by Our OR My Site when you visit certain parts of Our OR My Site and/or when you use certain features of Our OR My Site. Details of the Cookies used by Our OR My Site are set out in Part 14, below; and
“Cookie Law”
means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
Our OR My Site is owned and operated by Top 1 Media, a Limited registered in England under company number 16117999 .
Registered address:128 City Road, LONDON, EC1V 2NX .
Main trading address: OR Address: 128 City Road, LONDON, EC1V 2NX .
Data Protection Officer: Tom Browne.
Email address: info@top1media.co.uk
This Privacy Policy applies only to your use of Our OR My Site. Our OR My Site may contain links to other websites. Please note that we OR I have no control over how your data is collected, stored, or used by other websites and we OR I advise you to check the privacy policies of any such websites before providing any data to them.
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
Under the GDPR, you have the following rights, which we OR I will always work to uphold:
For more information about our OR my use of your personal data or exercising your rights as outlined above, please contact us OR me using the details provided in Part 15.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our OR my use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
Depending upon your use of Our OR My Site, we OR I may collect some or all of the following personal and non-personal data (please also see Part 14 on our OR my use of Cookies and similar technologies and our OR my Cookie Policy <<insert link>> ):
Under the GDPR, we OR I must always have a lawful basis for using personal data. This may be because the data is necessary for our OR my performance of a contract with you, because you have consented to our OR my use of your personal data, or because it is in our OR my legitimate business interests to use it. Your personal data will OR may be used for one of the following purposes:
With your permission and/or where permitted by law, we OR I may also use your personal data for marketing purposes, which may include contacting you by email AND/OR telephone AND/OR text message AND/OR post with information, news, and offers on our OR my products AND/OR services. You will not be sent any unlawful marketing or spam. We OR I will always work to fully protect your rights and comply with our OR my obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
We OR I use the following automated systems for carrying out certain kinds of decision-making AND/OR profiling. If at any point you wish to query any action that we OR I take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the GDPR gives you the right to do so. Please contact us OR me to find out more using the details in Part 15.
We OR I will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
We OR I will only store or transfer your personal data in the UK. This means that it will be fully protected under the GDPR.
OR
We OR I will only store or transfer your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the GDPR or to equivalent standards by law.
We OR I may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we OR I will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR as follows.
We OR I share your data within the group of companies of which we are OR I am a part. Where this involves the transfer of personal data outside the EEA, our OR my group ensures that personal data is protected by requiring all companies within the group to follow the same rules with respect to personal data usage. These are known as “binding corporate rules”. More information on binding corporate rules is available from the European Commission.
We OR I share your data with external third parties, as detailed below in Part 10, that are based outside of the EEA. The following safeguards is OR are applied to such transfers:
We OR I will only transfer your personal data to countries that the European Commission has deemed to provide an adequate level of personal data protection. More information is available from the European Commission.
We OR I use specific contracts with external third parties that are approved by the European Commission for the transfer of personal data to third countries. These contracts ensure the same levels of personal data protection that would apply under the GDPR. More information is available from the European Commission.
AND/OR
Where we OR I transfer your data to a third party based in the US, this may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar to those in Europe. More information is available from the European Commission.
Please contact us OR me using the details below in Part 15 for further information about the particular data protection mechanism used by us OR me when transferring your personal data to a third country.
The security of your personal data is essential to us OR me, and to protect your data, we OR I take a number of important measures, including the following:
We OR I will not share any of your personal data with any third parties for any purposes, subject to one important exception.
In some limited circumstances, we OR I may be legally required to share certain personal data, which might include yours, if we are OR I am involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
If any of your personal data is required by a third party, as described above, we OR I will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our OR my obligations, and the third party’s obligations under the law, as described above in Part 9.
If any personal data is transferred outside of the EEA, we OR I will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 9.
You may access certain areas of Our OR My Site without providing any personal data at all. However, to use all features and functions available on Our OR My Site you may be required to submit or allow for the collection of certain data.
You may restrict our OR my use of Cookies. For more information, see Part 14 and our OR my Cookie Policy top1media.co.uk/cookies.
If you want to know what personal data we OR I have about you, you can ask us OR me for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us OR me everything we OR I need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our OR my administrative costs in responding.
We OR I will respond to your subject access request within 5 days and, in any case, not more than one month of receiving it. Normally, we OR I aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we OR I receive your request. You will be kept fully informed of our OR my progress.
Our OR My Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us OR me and are used only by us OR me. We OR I use Cookies to facilitate and improve your experience of Our OR My Site and to provide and improve our OR my products AND/OR services. We OR I have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.
All Cookies used by and on Our OR My Site are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a pop up cookie banner requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us OR me to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our OR My Site may not function fully or as intended. You will be given the opportunity to allow only first-party Cookies and block third-party Cookies.
Certain features of Our OR My Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that Our OR My Site may not work properly if you do so. We OR I have taken great care to ensure that your privacy is not at risk by allowing them.
Our OR My Site uses analytics services provided by Google Analytics Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us OR me to better understand how Our OR My Site is used. This, in turn, enables us OR me to improve Our OR My Site and the products AND/OR services offered through it.
The analytics service(s) used by Our OR My Site use(s) Cookies to gather the required information. You do not have to allow us OR me to use these Cookies, however whilst our OR my use of them does not pose any risk to your privacy or your safe use of Our OR My Site, it does enable us OR me to continually improve Our OR My Site, making it a better and more useful experience for you.
In addition to the controls that we OR I provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
To contact us OR me about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Tom Browne):
Email address: info@top1media.co.uk.
We OR I may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we OR I change our OR my business in a way that affects personal data protection.
Any changes will be immediately posted on Our OR My Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our OR My Site following the alterations. We OR I recommend that you check this page regularly to keep up-to-date.
