PRIVACY POLICY
Introduction.
Welcome to the CTM (“Click Tap Media”) privacy notice. Click Tap Media is a division of Media Agency Group that is a company registered in England and Wales under company number 7022358 and with our registered office at Digital World Centre, 4th Floor, 1 Lowry Plaza, Salford Quays, Manchester, M50 3UB.
Media Agency Group respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit or access it from) and tell you about your privacy rights and how the law protects you. This policy is implementing the requirements of the General Data Protection Regulation (the law which protects and controls the use of personal data).
Media Agency Group has developed systems and processes to ensure that the standards are met or exceeded. This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. GLOSSARY
1. Important information and who we are
Purpose of this privacy notice.
This privacy notice aims to give you information on how Media Agency Group collects and processes your personal data including through your use of our website including any data you may provide through our websites when make an enquiry or request or submit any other information from us. Our websites at the date of inception of this policy are:
Websites
www.transportmedia.co.uk
www.oohinternational.co.uk
www.clicktapmedia.com
www.radioairtimemedia.co.uk
www.tvadvertisingmedia.com
www.pressmagmedia.com
www.traveltourismmedia.com
www.airportadvertisingmedia.net
Our website are not intended for children (being an individual under the age of 16 years old) alone and do not permit children to open accounts.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Controller
The Media Agency Group is made up of eleven different legal entities, Media Agency Group Ltd, Transport Media Ltd, OOHInternational Ltd, Click Tap Media Ltd, Radio Airtime Media Ltd, TV Advertising Media Ltd, Press Mag Media Ltd, Travel Tourism Media Ltd, Airport Advertising Media Ltd, London Bus Advertising Ltd, Advan Ltd. This privacy notice is issued on behalf of the Group so when we mention Media Agency Group, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Media Agency Group Group responsible for processing your data. Media Agency Group Ltd and its relevant entities are joint controllers with respect to your data. This is because all companies jointly determine the means and use of your data; for example, all enquiries are shared in our CRM (SalesForce) software from which all entities work together to ensure appropriate encryption is in place, it is securely stored, and onward transmission of data is limited to within the group. We have explained what steps have been taken in relation to the joint controller relationship, our arrangement, and what this means to you, below. We never just ‘hand over’ your data with appropriately jointly determined safeguards. By accepting our terms and privacy policy, you are giving consent to the sharing and management of data as set out in this policy.
Media Agency Group Ltd will share your personal data with the above entities. It is important that this happens so that we can ensure your enquiry is properly processed and fulfilled in order to deliver the best possible service.
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.
Contact Details
Our full details are:
Full name of legal entity: Media Agency Group
Email address: info@mediaagencygroup.com
Postal address: Media Agency Group 34 South Molton Street Mayfair London W1K 5RG
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-Party Links
Our website and applications may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website or service you visit.
1. The data we collect about you.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
NON-SPECIAL CATEGORY OF PERSONAL DATA
• Identity Data includes first name, last name and email.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of services you have purchased or requested from us.
• Technical Data includes internet protocol (IP) address of your device, your login data, browser type and version, temporary or persistence unique device identifiers, mobile operating system type, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website and/or application.
• Usage Data includes information about how you use our website and services including number of visits, length of visit, interaction with website pages (i.e. clicking page links).
•Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website or web page feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with a detailed campaign plan). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
2. How is your personal data collected?
We use different methods to collect data from and about you including through:
• Direct interactions. You may give us your Identity & Contact, by filling in forms on our website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• Make an advertising enquiry
• Signing up to our news letter
• request marketing to be sent to you;
• apply for a position at Media Agency Group;
• enter a competition, promotion or survey; or
• give us some feedback.
• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see the information regarding cookies in this policy.
• Third parties. We may receive personal data about you from various third parties as set out below:
• Technical Data from the following parties from analytics providers such as Google based outside the EU and from our third party providers for emails and communications.
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Sagepay and Lexis Nexus, based inside the EU.
• Identity and Contact Data from the electoral roll, company house and similar sources.
• Contact, Identity and Data from third party providers, employers, and other third parties from whom we may put a call for data from. This is to streamline your account creation and make it a more enjoyable process for you.
• Identity and Contact Data from third parties with whom you may be in contact with in reference to applying for a job or position at Media Agency Group.
3. How we use your personal data.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
In addition to the data protection laws which we adhere to, we also respect the common law right of confidentiality. We will never share your records to any third party not involved in the provision of services between us unless you expressly consent to us doing so.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity
To register you as a new contact including sending emails relating to your initial enquiry, account set up, status and account credentials.
External Third Parties will be used for the hosting of such data.
Where you expressly authorise us, we may draw information into your account from authorised third parties.
Type of data
(a) Identity
(b) Contact
Lawful basis
Performance of a contract with you (i.e. a user subscribing to our service via our website or application).
Purpose/Activity
To deliver services to you in the manner of organisation, co-ordination and facilitation of campaign planners, executives & administrators for managing payments, fees and charges relating to the same.
We may disclose data to Media Owners (see Glossary) for the purpose of providing you with a detailed campaign proposal
External Third Parties may be used for facilitation of payments and hosting.
Type of data
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
Lawful basis
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
Purpose/Activity
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
(c) Contacting you by email or phone regarding your account (welcoming you to our service), reminding you of appointments and dates, re-engaging with you, maintenance of your account and updating of details.
We may use External Third Parties for the processing of data to assist in sending emails and other correspondence.
Type of data
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
Lawful basis
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
Purpose/Activity
To enable you complete a survey or provide feedback.
We may use External Third Parties for the processing of data to assist in sending emails and other correspondence.
Type of data
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
Lawful basis
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
Purpose/Activity
To administer and protect our business, website and applications (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
We may use External Third Parties for the hosting of data, applications, website and technical support of the same.
Type of data
(a) Identity
(b) Contact
(c) Technical
Lawful basis
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
Purpose/Activity
To deliver relevant website and application content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
We may use External Third Parties for the processing of data to assist in sending emails and other correspondence.
Type of data
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Lawful basis
Necessary for our legitimate interests (to study how customers use our products/services/applications, to develop them, to grow our business and to inform our marketing strategy)
Purpose/Activity
To use data analytics to improve our website and applications, products/services, marketing, customer relationships and experiences and to ensure our website and applications display and operate properly on your devices.
Type of data
(a) Technical
(b) Usage
Lawful basis
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website and applications updated and relevant, to develop our business and to inform our marketing strategy)
Purpose/Activity
To make suggestions and recommendations to you about services that may be of interest to you
Type of data
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
Lawful basis
Necessary for our legitimate interests (to develop our products/services and grow our business)
Purpose/Activity
If you apply for a job either direct to Media Agency Group or, in some instances, where you apply via a third party.
Where you apply via a third party we will obtain information from that third party.
Type of data
(a) Identity
(b) Contact
Lawful basis
Necessary for our legitimate interests (to assess suitability of candidates)
Marketing.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
• Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or received services from us or if you provided us with your details when signed up or registered in the application or website and, in each case, you have not opted out of receiving that marketing.
• Third-party marketing
We will get your express opt-in consent before we share your personal data with any company outside the Media Agency Group of companies for marketing purposes.
• Opting out
You can ask us or third parties to stop sending you marketing messages at any time by amending your preferences in your user account (via the website or application) and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of using the services, requesting services, ordering prescriptions, or providing feedback or surveys.
Cookies.
Media Agency Group uses a technology called ‘Cookies’ across all of its websites and applications in order to deliver the best possible user experience. Cookies are files that are stored on your device each time you visit a website or use an application and enables understanding of your preferences and habits.
Cookies do not contain person-identifiable information such as Identity, Contact Data or Financial Data.
Media Agency Group websites are set to ‘allow cookies’ and if you browse the sites and use our applications you consent to this. If you would prefer to deactivate cookies, you can do so by updating your browser settings. Please note that disabling cookies will limit the service that Media Agency Group can provide. For more information on how to update your settings, visit https://ico.org.uk/for-the-public/online/cookies/
Media Agency Group uses three types of cookie:
• Session cookies: These enable the tracking of your movement across the websites and applications and save information to make life easier. For instance, a session cookie might save an item to your shopping basket, without which you would be forced to order each item separately.
• Persistent cookies: These enable your preferences and settings to be saved each time you visit our websites and use our applications. This makes using the site faster and reduces the need to re-enter data.
• Third party cookies: These enable tracking of user activity outside the websites and applications and optimise campaigns and analytics better.
CHANGE OF PURPOSE AND OTHER LAWFUL DISCLOSURES
We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, where this is required or permitted by law. For example, we may be required to disclose your data in the interests of public health, national security, or serious threats to health and/or safety (including child abuse or neglect). Media Agency Group shall always identify a valid basis for disclosure of data including the following examples:
• Where data is required to be disclosed, for example, as compelled by the Children’s Acts 1989 and 2004 for the protection of a child such disclosure shall be on the basis of:
o For the performance of a task carried out in the public interest or in the exercise of official authority’ and:
o It is necessary for the purposes of carrying out the obligations and exercising the specific rights of the controller or of the data subject in the field of social protection law in so far as it is authorised by Union or Member State law.
• Where data is required to be disclosed, for example, in the interest of national security such disclosure shall be on the basis of:
o For the performance of a task carried out in the public interest or in the exercise of official authority’ and:
o It is necessary for reasons of substantial public interest, on the basis of Union or Member State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject.
4. Disclosures of your personal data.
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We do not allow the integration and/or transfer of information to any other mobile applications in your device.
5. International transfers.
Some of our External Third Parties are based in the US outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it. As our providers are based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us using the DPO contact detail in section 1 if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
6. Data security.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Media Agency Group uses SSL encryption to transfer information between your device, our servers and the Media Agency Group entities. All data is encrypted ‘at rest’. This means the data stored on our systems has been encrypted. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
7. Data retention.
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
Where we have anonymised your personal data (with consent where appropriate) or collected aggregated data for research or statistical purposes, we may continue to use that data indefinitely without further notice to you.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
8. Your legal rights.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
9. Glossary.
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. With regards to Media Agency Group, this is the terms you agree to upon making an enquiry, following which you can request consultations and other services.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
For compliance with a legal obligation means the processing of data is required by us to comply with our legal obligations.
THIRD PARTIES
Internal Third Parties
Means ‘all entities stated above. as part of the Media Agency Group, acting as joint controllers and who are based in England and Wales and provide services as specially set out herein.
External Third Parties
• Service providers acting as processors who provide IT and system administration services.
• Marketing service providers (including email list providers) who act as processors for our engagement correspondence and marketing with users.
• Online survey providers (including Lexis Nexus, MailChimp & Smart Survey) who convey information supplied by customers to Media Agency Group.
• Media Owners such as exterion Media, clear channel who inform us of options available when planning 7 booking an advertising campaign
• Payment providers, as processors of payment information, including Sagepay.
• Postal and delivery service providers acting as processors.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS.
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. Please note that we may object to amending records that may held by Media Agency Group in in the interests of maintaining the integrity of this data and benefitting your enquiry. Should you wish to update your details please contact us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.