Effective Date: 19-4-2018

1. Who are we?

1.1 We are Media Leads Ltd. You can contact us at dataprotection@medialeads.co.uk. Other contact details are on our website.

2. What’s the point of this policy?

2.1 It tells you what to expect when we collect your personal information. Please only use our service if you are completely happy with this policy.

2.2 Generally, the policy covers only information provided to us. If you give personal information to other people, such as payment providers or other websites, please check their privacy policies.

3. Might the policy change?

3.1 Please check whenever you visit our website. We will assume you agree to the new version of the policy if you use the site after its effective date.

4. What do we collect?

4.1 Information which you upload to our service or otherwise give us such as your name and contact details.

4.2 Automated information such as the internet protocol (IP) address used to connect your device to the internet, connection information such as browser type and version, information about your device including device-type and device identifier, operating system and platform, mobile network data, a unique reference number linked to the data you enter on our system, login details, the site from which you arrived at our service, details of your activity with date / time stamps including pages you visited and your searches / transactions.

5. What’s our reason / legal basis for collecting the information?

5.1 Because it’s necessary to provide you with our services under our contract with you. In the case of automated information collected when you browse our site, we use this to manage and improve our service in accordance with our “legitimate interests”.

6. What about cookies?

6.1 We and/or third parties use cookies and other tracking technologies on our website. A cookie is an identifier (a small file of letters and numbers) that is sent to your computer. Our website’s functionality will be limited if you configure your browser to reject cookies.

6.2 Cookies are widely used to make websites work, or work more efficiently, as well as to provide information to the website owner or others. Session cookies are temporary cookies that remain in the cookie file of your browser only until your browser is closed. They allow websites to link your actions during a browser session. Persistent cookies stay in the cookie file of your browser for longer (how long will depend on the lifetime of the specific cookie). For further information on cookies, including how to use your browser to block them and how to delete cookies already stored on your device, visit: allaboutcookies.org.

6.3 The following kinds of cookies may be used on this website:

a. Session cookies: These enable us to keep track of your movement from page to page and store your selections so you do not get asked repeatedly for the same information. They allow you to proceed through many pages of the site quickly and easily without having to authenticate or reprocess each new area you visit. For example, a session cookie remembers your shopping cart selection so you will have the items you selected when you are ready to check out.

b. Google cookies: Persistent cookies (up to four years we believe) are set in connection with the following Google services on our site and these cookies may involve certain information (such as your IP address and web address of the page you’re visiting) being sent to Google:

1. Google Analytics (“GA”): We use cookies to recognise and count the number of website visitors as well as providing other information about the visit such as duration, route through the website and what sites the visitor came from. This information helps us to improve the way our website works, for example by making sure users find what they need easily. You can specifically opt out of GA here. See below for other opt out routes.

More information and opt out: Click here for Google’s privacy policy and here for more information about the kinds of cookies placed by Google. Click here for information about how Google uses data from its partners’ sites or apps as well as different ways to opt out of Google cookies.

c. Cookie-warning cookie: This cookie takes note of whether you are happy to accept cookies on this website based on your response to the message which appeared when you first visited the website. This persistent cookie will remember your preference for up to 30 days.

6.4 By continuing to use our website, having seen our cookie notice, we assume that you consent to use of the cookies outlined above.

7. What do we do with personal information?

7.1 Provide our service, e.g. send service messages, process payments, fulfil orders.

7.2 Use it to recognise you when you visit or return to our service to track anonymised traffic and usage patterns, prevent or detect fraud or abuses and help us improve our service.

8. How long do we keep it?

8.1 We may keep your personal information for up to six years after your transaction – for tax reasons and/or to help deal with any disputes. That timeframe may vary if we are legally required to keep information for a particular period.

9. To whom do we send or make available your personal information?

9.1 To the relevant staff dealing with your enquiry.

9.2 To other people who supply us with a service, e.g. e-commerce platform providers, website hosts and businesses which help us send communications or monitor our website.

9.3 To the police or other relevant authorities or to complainants, if we think the personal information breaches our terms and conditions, or it is necessary to protect us or others, or that a criminal offence may have been committed, or where required by law or where requested by the police or other appropriate authorities.

9.4 To potential buyers so far as reasonably necessary, in the case of an actual or proposed (including negotiations for a) sale or merger or business combination involving all or the relevant part of our business.

10. What happens to your payment details?

10.1 These go direct to our payment partners. We do not receive such information except as stated above. To ensure your details are not being used without consent, our payment partners may send your personal information to relevant third parties including credit reference and fraud prevention agencies, who may keep a record of that information.

11. Do we send your information outside the European Union?

11.1 Your personal information which we collect is stored within the EU and is not transferred to any third countries except for the following.

11.2 Your personal information may be transferred to the US by our webhost GoDaddy, which is certified under the EU-US Privacy Shield Framework. This provides certain safeguards in relation to the handling of your personal data. See here for more information.

12. What rights do you have?

12.1 If the legal requirements are met: To ask us for access to your personal information, to rectify it if there are mistakes, to delete or restrict or object to its use in certain circumstances or to “data portability”.

12.2 If you have a complaint about how we are dealing with your personal information, please contact us via the email address above. If you are not happy with our response or think we are not handling your personal information in accordance with the law, you can complain to the Information Commissioner’s Office (ICO).

12.3 For more information about your rights, visit the ICO’s website: ico.org.uk.

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