Last Updated: December 21, 2016.
NEWBAY MEDIA EUROPE LIMITED (“we”, “our” or “us”) is a company registered in England and Wales with company number 03641099 and having its registered office at 16 Old Bailey, London, EC4M 7EG.
- websites owned or controlled by us. You can see a list of these here http://www.newbaymedia.com/euro-brands/ (the “Websites”);
- any services accessible via the Websites for example the booking of events; or
- any mobile application software downloadable via our Website(the “App”);
The purpose of this Policy is to set out the basis on which any personal data we collect from you, or which has been provided by you or third parties will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
Sections 1 – 10 of the Policy shall apply to any use of our Websites, App, events, other related services and products.
If you use our NewBay Connect website which can be found here http://newbayconnect.com (“NewBay Connect Site”), please ensure you also read section 11 of this Policy.
If you are applying for a vacancy via the job boards on our Websites, please ensure you also read section 12 of this Policy.
1. What information do we collect and how is it collected?
We may collect personal data about you in the way as set out below.
Information you give to us – this relates to any personal information which you have specifically input into the Websites or App or provided to us via a third party.
- Registration details and associated details, such as your name, email address, role and company when subscribing to our Websites, App, our services, our products, our events, our newsletters or registering your interest in receiving whitepapers.
- Your responses, to our surveys, entering our competitions or promotions, posting material or requesting further services.
- Any preferences you have selected, including any consents for receipt of newsletters, vacancies or communications of services, products or events which we think may be of interest to you.
- Any queries that you raise with us, for instance you may submit a question by email to us about our Websites, App, events, services or products or when you report a problem to us.
- Any content you have sent to us, including any case studies, opinions, or whitepapers you have submitted to us for posting on certain of our Websites (the “Content”). In this instance, we will store the Content, any other information you have submitted, any responses and correspondence in relation to such Content.
- Any interactions that you have with us on any of our chosen social media platforms, for instance, you may choose to like our Facebook page or send us a tweet on Twitter.
- Card information, where you pay for our subscription services, job advertisements, events, other services or products using a bank card, we may receive certain card details including the last four digits of your card number and the card type from our third party payment provider.
- Please note, we do not store credit card details nor do we share customer details with any third parties where you have provided such details via the PayPal (Europe) S.à r.l. et Cie, S.C.A. payment platform.
- All other information that you choose to provide us.
You may choose whether or not to give some information to us. However, not providing certain information may mean you cannot enjoy all or parts of our services.
Information that is collected automatically – this relates to information which is automatically collected from your visit of our Websites, use of our App, services or products.
Details of your visits, including but not limited to, your IP address, operating systems, browser type and traffic data. For detailed information on how we collect this data, please see our Cookies Policy at http://www.newbaymedia.com/euro-cookies-policy/ .
- Details of your interaction with information we send to you, including but not limited to whether you have read or opened our emails or particular subscriptions via our email communications.
- Details of your mobile device, including device type and mobile operating system if you have used the mobile device to access the Websites, App services or products.
- Location information transmitted from your mobile device, where you have used the mobile device to access the Websites, App, services or products but only where you have set our device settings to allow this.
- Information from third parties, including information passed to us via competitions or events which we sponsor. We may combine information we receive from third parties with information we collect directly or indirectly from you.
2. We may use the data that we collect about you for the following purposes:
- to allow you to participate in interactive features of our service, when you choose to do so;
- to carry out our obligations to you, including providing you with your subscription services, booking and running events and providing you with access to certain contents on our Websites or our App;
- to manage your account, including customising the types of communication such as newsletters and job vacancy notifications we send to you according to your preferences;
- to respond to your queries that you submit through our Websites, App or via any other communication such as email or letter;
- to verify your user credentials;
- to contact you with important service announcements;
- to contact you with details of any prizes you may win;
- to provide you with technical assistance in the event that you contact us about a technical issue you are experiencing with the Websites or App;
- if you agree, to contact you and/or to allow third parties to contact you about other services we provide which we think may be of interest to you. If you do not want us to use your data in this way, or pass your details on to third parties for marketing purposes, please tick the relevant box situated on the registration form or please email us [EMAIL ADDRESS] with your request. If you have registered for our subscription services, you can also change your preferences on your account settings;
- to help us improve our Websites, App, services or other products including its content, layout and navigation;
- to optimise and present the Websites, App, services or products in the most effective manner; and
- for analysis, research and statistical purposes to help us understand who is using the Websites, App, services, events or products; when and how the Websites, App, services, events, or products are being used (your data is anonymised when we do this so that you cannot be identified).
We may also use any of this information to meet our legal and regulatory obligations and protect our legitimate interests.
3. Where do we store your personal data?
The data that we collect from you is stored in secure servers and data centres. These will normally be located on servers or data centres located in the EU. The suppliers and advisers we engage to help us run and deliver our business, may have servers or data centres located outside the EU for example in the US or in cloud-based solutions. We may need to transfer your personal data to these countries so that we can continue providing the Websites, App, events, other services or products to you.
Naturally, we expect our suppliers to take information security as seriously as we do so we will put appropriate measures in place to ensure our suppliers implement EU standards of protection for your personal information.
Even so, any transfer of information to other countries in this way could result in that information being available to the government, the courts and other authorities in those countries under their laws.
4. Who do we share your data with?
We may disclose some or all of the data we collect from you when you use the Websites, App our services or products to the following third parties:
- companies within our group, which means our subsidiaries, our ultimate holding company, as defined in section 1159 of the Companies Act 2006;
- third party partners, for example where we collaborate to provide competitions or where events are run by third party partners but are displayed on our “Events” information. In these instances we will only share information in relation to and in so far as is necessary for us to perform the services to you;
- third party service providers, such as our payment providers or subscription providers and also including our lawyers and accountants (and those of any prospective purchasers of our business – see below) who provide us with professional advice – we will impose appropriate obligations to protect the security and privacy of your information;
- where we re-organise, re-structure, sell or transfer our business, we will transfer your personal information to the new incumbent of the business for them to continue to use it in the same ways as we have prior to the transfer.
We may also share your information with our advertisers. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day).
5. Your security and links to external websites
We have implemented measures to ensure that the personal information you provide to us or is collected about you is kept safe, secure and private. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Our Websites or App may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies or websites. Please check these policies before you submit any personal data to these websites.
In particular, please be aware that where you register for events hosted by third parties via our “Events” information page, newsletters, App or email notifications, you may be re-directed to a third party events provider. In such instances, we only provide information of such events and do not accept any responsibilities for the event itself of the operation of third parties including their websites. Please ensure you read the privacy policies of these third parties carefully
6. Your rights
We would like to send you information about our services, events, newsletters, whitepapers which may be of interest to you. If you would prefer us not to process your personal data for marketing purposes, you have the right to unsubscribe from the relevant mailing list. You can remove yourself from our mailing list by:
- selecting the relevant options on your account settings (only available if you are registered for our subscription services);
- selecting the relevant option at the bottom of the email; or
- contacting us and stating your preferences at NewBay Media Europe Limited, The Emerson Studios, 4-8 Emerson Street, SE1 9DU or by email to UKPrivacy@nbmedia.com.
7. Access to your personal information
You have the right to access information held about you. If you would like to see or change your personal information, please go to your “Manage account” settings if you are registered for our subscription services, otherwise please email us with your request at: UKPrivacy@nbmedia.com.
The UK Data Protection Act 1998 also gives you the right to ask if we hold your personal information and subject to certain exceptions, to be provided with a copy of it. This is called a subject access request. We will require a statutory fee of £10 to meet our costs in providing you with details of the information we hold about you. If you would like to make such a request, please contact us at: UKPrivacy@nbmedia.com and ensure that you include “Subject Access Request” in the title of the email.
8. Updates to this Policy
Any changes we may make to this Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.
9. Further information
We are registered under the Data Protection Act 1998 with the Information Commissioner’s Office (the UK data protection regulator). Our registration number is Z8552403 and can be viewed online at www.ico.org.uk. You can also view useful access guidance and information about your data protection rights on this website.
For the purpose of the Data Protection Act 1998 (the Act), we are the data controller. This term is a legal phrase used to describe a person or entity that controls the way data is used or processed. We are committed to protecting and respecting your privacy.
You can make a complaint to the ICO at any time about the way we use your information. However, we hope that you would first raising with us any issue or complaint you have about how we handle your personal information.
11. NewBay Connect Site
In addition to the terms as set out in sections 1 – 10, our NewBay Connect Site allow you to register and provide certain personal information in order to specifically download third party whitepapers, case studies and other content (“Materials”). If you do download these Materials, the following terms will also apply to you.
Materials from the NewBay Connect Site may belong to third parties based outside the European Economic Area (non-EEA). In return for free access to these Materials we may transfer personal data you have submitted on the registration page following the download option to that specific third party in the country where they are based. We will only do this where you have provided us with your consent on the registration page.
In addition to the terms as set out in sections 1 – 10, where you have used our job boards on our Websites to apply for a vacancy (a “Vacancy”) the below terms will also apply to you in relation to your personal information.
Unless you are applying for a role with us, we do not have access to or store any of the information you have submitted on the application form (your “Application Information”). Such information is provided directly to the recruiter, agent or employer who is advertising the vacancy on our Websites.
You may choose to submit sensitive personal information such as your medical history, ethnic or racial background, political views, religious beliefs, trade union membership, sexual life or any alleged or actual offence as part of your Application Information. By submitting these details, you consent to the disclosing of the same to the relevant employer or recruiter.
Where you have applied for a Vacancy posted by an employer or a recruiter located in a non-EEA country, we will have to transfer your Application Information to that country. We will always display which country the Vacancy, employer and/or the recruiter is located. By applying for such Vacancy, you agree that we will need to transfer your Application Information to such country so that your application can be submitted for the Vacancy and you consent to such transfer.
Please note, we never have access to or store any copies of your Application Information (save where you are applying for a job with us). We are not data controllers in respect of this information.