ATEX MEDIA LIMITED

Updated and Effective as of 25 May 2018.

This website (and any mobile site or mobile application that link to this Privacy Policy) (collectively, the “Sites”) is owned and operated by Atex Media Limited (a private limited company with its registered address at Unit A Underwood Business Park, Wookey Hole Road, Wells, Somerset, England, BA5 1AF) ("Atex ", “ we”, “our”, and “us”).

At Atex, we are committed to respecting your privacy. This Privacy Policy explains how we collect, use and disclose personal information that we receive when you visit the Sites, use our services, or communicate with us both on the Sites and offline as a business customer, prospective customer or general contact. This Privacy Policy applies to Atex and covers our processing activities as a data controller.

We also process personal information as a data processor on behalf of our customers (please see “Atex as Data Processor” below).

The Sites are not intended for or directed at children under the age of 16 years and we do not knowingly collect information relating to children under this age.

We are not required to appoint a formal data protection officer under data protection laws. However, we have appointed a Data Protection Contact who you can reach out to about any queries you may have in relation to this Privacy Policy. If you are located in the EEA, you can contact our representative(s) in the EEA about any data protection queries, using the contact details below.

Contacting Us

If you have any questions about our Privacy Policy or your information, or to exercise any of your rights as described in this Privacy Policy or under data protection laws, you can contact us as follows:

By post:
Privacy Officer, Atex Media Limited, Unit A Underwood Business Park, Wookey Hole Road, Wells, Somerset, England, BA5 1AF

With contact form
www.atex.com/contact

By email
dataprotection@atex.com

Topics

Data Protection Principles

Atex adheres to the following principles when processing your personal information as data controller:

1. Lawfulness, fairness and transparency – data must be processed lawfully, fairly and in a transparent manner.

2. Purpose limitation - data must be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.

3. Data minimisation - data must be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

4. Accuracy - data must be accurate and, where necessary, kept up to date.

5. Storage limitation - data must be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal information are processed.

6. Integrity and confidentiality - data must be processed in a manner that ensures appropriate security of the personal information, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage by using appropriate technical or organisational measures.


PERSONAL INFORMATION WE COLLECT

Information you give us

You may provide us with information through the Sites, by email, over the phone or otherwise communicate or be in contact with us as a business customer or business contact, when you:

· request additional information about our services or ask us to contact you;

· use our services;

· register with us on the Sites; and

· make any comment or contribution on our Sites.

The categories of personal information you provide may include:

· first and last name;

· job title and company name;

· email address;

· phone number

· mailing address;

· password to register with us;

· your personal or professional interests;

· any other identifier that permits Atex to make contact with you.

We do not generally seek to collect sensitive personal information through our Sites. Sensitive personal information is information relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership; health or sex life, sexual orientation; genetic or biometric information. If we do collect sensitive personal information, we will ask for your explicit consent to our proposed use of that information at the time of collection.

Information we collect from you

Atex collects, stores and uses information about your visits to the Sites and about your computer, tablet, mobile or other device through which you access the Sites. This includes the following information:

Technical information, including the Internet protocol (IP) address, browser type, internet service provider, device identifier, time zone setting, browser plug-in types and versions, operating system and platform, and geographical location;

information about your visit and use of the Site, including the full Uniform Resource Locators (URL), clickstream to, through and from our Site, pages you viewed and searched for, page response times, length of visits to certain pages, referral source/exit pages, page interaction information (such as scrolling, clicks and mouse-overs), and website navigation.


ATEX AS DATA PROCESSOR

We collect and process personal information on behalf of our customers in the provision of our services. In these circumstances, Atex is acting as a data processor and our customers remain the data controller in respect of personal information they provide to us. To the extent that we are acting as data processor, we will process such personal information in accordance with our customer’s instructions and any agreement in place with our customers. Atex will only use such personal information for the purposes of providing the services for which our customers have engaged us.

Our customers are responsible for ensuring that these individuals’ privacy is respected, including communicating to the individuals in their own privacy policies who their personal information is being shared with and processed by.

As a data processor, Atex may share personal information where instructed by our customer (the data controller). Where authorized by the customer, we may also share personal information with third party service providers who work for Atex and who are subject to security and confidentiality obligations.

Where Atex is acting as a data processor, we will refer any request from an individual for access to personal information which we hold about them to our customer. Atex will not respond directly to the request.

Atex will retain personal information which we process on behalf of our customers for as long as needed to provide services to our customers and in accordance with any agreement in place with our customers.


WHAT WE DO WITH YOUR PERSONAL DATA

As a data controller, Atex will only use your personal information if we have a legal basis for doing so. The purpose for which we use and process your information and the legal basis on which we carry out each type of processing is explained in the table below.

Purposes for which we will process the information

Legal Basis for the processing

To carry out our obligations arising from any contracts entered into with you and to provide services to you.

It is necessary for us to process your personal information in this way in order to enter into a contract with you and to fulfil our contractual obligations to you.

To provide you with information and materials that you request from us.

It is in our legitimate interests to respond to your queries and provide any information and materials requested in order to generate and develop business. To ensure we offer an efficient service, we consider this use to be proportionate and will not be prejudicial or detrimental to you.

To personalise our services and the Sites to you.

It is in our legitimate interests to enhance your experience on our Sites and to better our services. We consider this use to be proportionate and will not be prejudicial or detrimental to you.

If you do not wish to receive tailored or personalised information from us based on personal information you have provided us, please contact us as provided in “Contacting Us” above.

To enforce the terms and conditions and any contracts entered into with you.

It is in our legitimate interests to enforce our terms and conditions of service. We consider this use to be necessary for our legitimate interests and proportionate.

To update you on services and benefits we offer.

It is in our legitimate interests to market our services. We consider this use to be proportionate and will not be prejudicial or detrimental to you.

If you would prefer not to receive any direct marketing communications from us, you can opt-out at any time by contacting us as providing in “Contacting Us” above.

For direct marketing sent by email to new contacts (i.e. individuals who we have not previously engaged with), we need your consent to send you unsolicited direct marketing.

To send you information regarding changes to our policies, other terms and conditions and other administrative information.

It is in our legitimate interests to ensure that any changes to our policies and other terms are communicated to you. We consider this use to be necessary for our legitimate interests and will not be prejudicial or detrimental to you.

· To administer our Sites including troubleshooting, data analysis, testing, research, statistical and survey purposes;

· To improve our Sites to ensure that consent is presented in the most effective manner for you and your computer, mobile device or other item of hardware through which you access the Sites; and

· To keep our Sites safe and secure.

For all these categories, it is in our legitimate interests to continually monitor and improve our services and your experience of the Sites and to ensure network security. We consider this use to be necessary for our legitimate interests and will not be prejudicial or detrimental to you.

To measure or understand the effectiveness of any marketing we provide to you and others, and to deliver relevant marketing to you.

It is in our legitimate interests to continually improve our offering and to develop our business. We consider this use to be necessary in order to effectively generate business and will not be prejudicial or detrimental to you.

Where you provide consent, you can withdraw your consent at any time and free of charge, but without affecting the lawfulness of processing based on consent before its withdrawal. You can update your details or change your privacy preferences by contacting us as provided in “Contacting us” above.

Atex will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you in a timely manner and we will explain the legal basis which allows us to do so.


DISCLOSURE OF YOUR PERSONAL DATA TO THIRD PARTIES

Atex will not sell, rent, lease or otherwise share your personal information other than as outlined in this Privacy Policy or without obtaining your consent beforehand.

We will share your personal information with our group companies, affiliates and advisers as necessary to carry out the purposes for which the information was supplied or collected (i.e. to provide the services you have requested).

Personal information will also be shared with our third party service providers and business partners who assist with the running of the Sites and our services including hosting providers and crm providers. Our third party service providers and business partners are subject to security and confidentiality obligations and are only permitted to process your personal information for specified purposes and in accordance with our instructions.

In addition, Atex may disclose information about you:

· in the event that we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets;

· if all or substantially all of Atex’s assets are acquired by a third party, in which case personal information held by it about its customers will be one of the transferred assets;

· if we are under a duty to disclose or share your personal information in order to comply with any legal or regulatory obligation;

· if necessary to protect the vital interests of a person; and

· to enforce or apply our terms and conditions or to establish, exercise or defend the rights of Atex, our staff, customers or others.


INTERNATIONAL TRANSFERS

To deliver services to you, it is necessary for us to transfer your personal information outside of the European Economic Area (“ EEA”) to our group companies and our service providers and business partners located outside the EEA. This includes the United States, Australia, Singapore and Pakistan.

Where personal information is transferred to and stored in a country not determined by the European Commission as providing adequate levels of protection for personal information, we take steps to provide appropriate safeguards to protect your personal information, including:

· entering into standard contractual clauses approved by the European Commission, obliging recipients to protect your personal information;

· under the EU-U.S. Privacy Shield Framework which enables U.S. business to self-certify as a means of complying with EU data protection laws (see below).

If you want further information on the specific mechanism used by us when transferring your personal information out of the EEA, please contact us using the details set out above.


SECURITY OF YOUR PERSONAL DATA

Atex use appropriate technical and organizational security measures to protect personal information both online and offline from unauthorized use, loss, alteration or destruction. We use industry standards physical and procedural security measures to protect information from the point of collection to the point of destruction. This includes encryption of communications, access controls to our systems, policies and other procedures to protect information from unauthorized access.

Only authorized personnel and third party service providers are permitted access to personal information, and that access is limited by need. Where data processing is carried out on our behalf by a third party, we take steps to ensure that appropriate security measures are in place to prevent unauthorized disclosure of personal information.

Despite these precautions, however, Atex cannot guarantee the security of information transmitted over the Internet or that unauthorized persons will not obtain access to personal information. In the event of a data breach, Atex have put in place procedures to deal with any suspected breach and will notify you and any applicable regulator of a breach where required to do so.

If you have any questions about security on our Sites, you can contact us as provided in “Contacting us” above.


HOW LONG WE KEEP YOUR PERSONAL DATA

Your personal information will not be kept for longer than is necessary for the purposes for which it was collected and processed. We will retain your personal information for as long as your account is active or as needed to provide you with services or products you have requested.

The criteria we use for retaining different types of personal information, includes the following:


YOUR RIGHTS

ACCESS TO AND UPDATING YOUR PERSONAL DATA

You have the right to access information which we hold about you (“ data subject access request”).

You may also have the right to receive personal information which you have provided to us in a structured and commonly used format so that it can be transferred to another data controller (“data portability ”). The right to data portability only applies where your personal data is processed by us with your consent or for the performance of a contract and when processing is carried out by automated means.

We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate. Please keep us informed if your personal information changes during your relationship with us.


RIGHT TO OBJECT

Direct marketing

You have the right to object at any time to our processing of your personal information for direct marketing purposes.

Where we process your information based on our legitimate interests

You also have the right to object, on grounds relating to your particular situation, at any time to processing of your personal information which is based on our legitimate interests. Where you object on this ground, we shall no longer process your personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.


YOUR OTHER RIGHTS

You also have the following rights under data protection laws to request that we rectify your personal information which is inaccurate or incomplete.

In certain circumstances, you have the right to:

· request the erasure of your personal information erasure (“ right to be forgotten”);

· restrict the processing of your personal information to processing in certain circumstances.

Please note that the above rights are not absolute and we may be entitled to refuse requests, wholly or partly, where exceptions under the applicable law apply.

For example, we may refuse a request for erasure of personal information where the processing is necessary to comply with a legal obligation or necessary for the establishment, exercise or defence of legal claims. We may refuse to comply with a request for restriction if the request is manifestly unfounded or excessive.


EXERCISING YOUR RIGHTS

You can exercise any of your rights as described in this Privacy Policy and under data protection laws by contacting us as provided in “Contacting us” above.

Save as described in this Privacy Policy or provided under data protection laws, there is no charge for the exercise of your legal rights. However, if your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may either: (a) charge a reasonable fee taking into account the administrative costs of providing the information or taking the action requested; or (b) refuse to act on the request.

Where we have reasonable doubts concerning the identity of the person making the request, we may request additional information necessary to confirm your identity.


COOKIES

In order to improve the Sites, we may use small files commonly known as “cookies”. A cookie is a small amount of data which often includes a unique identifier that is sent to your computer or mobile phone (your “ device”) from the Sites and is stored on your device’s browser or hard drive. The cookies we use on the Sites won't collect personally identifiable information about you and we won't disclose information stored in cookies that we place on your device to third parties.

By continuing to browse the Sites, you are agreeing to our use of cookies.

If you don't want us to use cookies when you use the Sites, you can set your internet browser not to accept cookies. However, if you block cookies some of the features on the Sites may not function as a result.

You can find more information about how to do manage cookies for all the commonly used internet browsers by visiting www.allaboutcookies.org. This website will also explain how you can delete cookies which are already stored on your device.

We currently do not set cookies, except for third parties listed below.

Cookies from third parties

We only use "Google Analytics" on the Sites. This cookie provides us with a visitor count and an understanding of how visitors move around and use the Sites. We can then use this information to improve navigability and the Sites generally. The cookies we use on the Sites won’t collect personally identifiable information about you and we won’t disclose information stored in cookies that we place on your device to third parties.

The Sites use Google Analytics, a web analytics service provided by Google Inc. ("Google"). Google Analytics uses "cookies", which are text files placed on your computer, to help the Sites analyse how users use the Sites. The information generated by the cookie about your use of the Sites (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Sites, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of the Sites. By using the Sites, you consent to the processing of data about you by Google in the manner and for the purposes set out above.


LINKS

The Sites may, from time to time, contain links to and from the websites of our business partners, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and Atex does not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.


COMPLAINTS

If you have any questions or complaints regarding our Privacy Policy or practices, please contact us as provided in “Contacting Us” above.

If you are in located in the EEA, you also have the right to complain to the relevant supervisory authority in the EEA. In the UK, this is the Information Commissioner’s Office ( https://ico.org.uk/).


CHANGES TO OUR PRIVACY POLICY

Atex reserves the right to change this Privacy Policy from time to time. Any changes will be posted on this page with an updated revision date. If we make any material changes to this Privacy Policy, we will notify you by email or by means of a prominent notice on the Sites prior to the change becoming effective.

Updated and Effective as of 25 May 2018