Privacy Policy

Privacy and cookies policy

1. Introduction

1.1 We are committed to safeguarding the privacy of visitors to our
website, including those webpages of our partners and clients (whose
webpages we manage and power).

1.2 This policy applies where we are acting as a data controller with
respect to the personal data of our website visitors and service users;
in other words, where we determine the purposes and means of the
processing of that personal data.

"Personal data" is defined in Article 4(1) of the GDPR:

"'personal data' means any information relating to an identified or
identifiable natural person ('data subject'); an identifiable
natural person is one who can be identified, directly or indirectly,
in particular by reference to an identifier such as a name, an
identification number, location data, an online identifier or to one
or more factors specific to the physical, physiological, genetic,
mental, economic, cultural or social identity of that natural
person".

1.3 We use cookies on our website. Insofar as those cookies are not
strictly necessary for the provision of our website and services, we
will ask you to consent to our use of cookies when you first visit our
website.

1.4 Our website incorporates privacy controls which affect how we will
process your personal data.

1.5 In this policy, "we", "us" and "our" refer to Seed Media
Limited. For more information about us, see Section 15.

2. How we use your personal data

2.1 In this Section 2 we have set out:

(a) the general categories of personal data that we may process;

(b) in the case of personal data that we did not obtain directly from
you, the source and specific categories of that data;

(c) the purposes for which we may process personal data; and

(d) the legal bases of the processing.

Article 6(1)(f) of the GDPR provides that:

"Processing shall be lawful only if processing is necessary for the
purposes of the legitimate interests pursued by the controller or by a
third party, except where such interests are overridden by the
interests or fundamental rights and freedoms of the data subject which
require protection of personal data, in particular where the data
subject is a child."

2.2 We may process data about your use of our website and services
("usage data"). The usage data may include your IP address,
geographical location, browser type and version, operating system,
referral source, length of visit, page views and website navigation
paths, as well as information about the timing, frequency and pattern of
your service use. The source of the usage data is our analytics tracking
system. This usage data may be processed for the purposes of analysing
the use of the website and services. The legal basis for this processing
is our legitimate interests, namely monitoring and improving our website
and services and the supply of services that you consent that we may
supply to you.

2.3 We may process your account data ("account data"). The account
data may include your name and email address. The source of the account
data is you. The account data may be processed for the purposes of
operating our website, providing our services, ensuring the security of
our website and services, maintaining back-ups of our databases and
communicating with you. The legal basis for this processing is our
legitimate interests, namely the proper administration of our website
and the supply of services that you consent that we may supply to you.

2.4 We may process your information included in your personal profile on
our website ("profile data"). The profile data may include your
name, address, telephone number, email address, profile pictures,
gender, date of birth, relationship status, interests and hobbies,
buying preferences, educational details and employment details. The
profile data may be processed for the purposes of enabling and
monitoring your use of our website and services. The legal basis for
this processing is our legitimate interests, namely the proper
administration of our website and the supply of services that you
consent that we may supply to you.

2.5 We may process your personal data that are provided in the course of
the use of our services ("service data"). The service data may
include name, address, telephone number, email address, and information,
such as, reward/voucher that you are applying to be provided with by us.
The source of the service data is you. The service data may be processed
for the purposes of operating our website, providing our services,
ensuring the security of our website and services, maintaining back-ups
of our databases and communicating with you. The legal basis for this
processing is our legitimate interests, namely the proper administration
of our website and the supply of services that you consent that we may
supply to you.

2.6 We may process information relating to transactions, including
purchases of goods and services, that you enter into with us and/or
through our website ("transaction data"). The transaction data may
include your contact details, and the transaction details. The
transaction data may be processed for the purpose of supplying the goods
and services and keeping proper records of those transactions. The legal
basis for this processing is the proper administration of our website
and the supply of services that you consent that we may supply to you.

2.7 We may process information that you provide to us for the purpose of
subscribing to our email notifications and/or newsletters
("notification data"). The notification data may be processed for
the purposes of sending you the relevant notifications and/or
newsletters. The legal basis for this processing is the proper
administration of our website and the supply of services that you
consent that we may supply to you.

2.8 We may process information contained in or relating to any
communication that you send to us ("correspondence data"). The
correspondence data may include the communication content and metadata
associated with the communication. Our website will generate the
metadata associated with communications made using the website contact
forms. The correspondence data may be processed for the purposes of
communicating with you and record-keeping. The legal basis for this
processing is our legitimate interests, namely the proper administration
of our website and the supply of services that you consent that we may
supply to you.

2.9 In addition to the specific purposes for which we may process your
personal data set out in this Section 2, we may also process any of your
personal data where such processing is necessary for compliance with a
legal obligation to which we are subject, or in order to protect your
vital interests or the vital interests of another natural person.

2.10 Please do not supply any other person's personal data to us,
unless we prompt you to do so.

3. Providing your personal data to others

3.1 We may disclose your personal data to any member of our group of
companies (this means our subsidiaries, our ultimate holding company and
all its subsidiaries) insofar as reasonably necessary for the purposes,
and on the legal bases, set out in this policy.

3.2 We may disclose personal data to our suppliers insofar as reasonably
necessary for us to deliver those goods and services that you have
consented to receive on our website.

3.3 Financial transactions relating to our website and services may be
handled by our payment services providers. We will share transaction
data with our payment services providers only to the extent necessary
for the purposes of processing your payments, refunding such payments
and dealing with complaints and queries relating to such payments and
refunds.

3.4 In addition to the specific disclosures of personal data set out in
this Section 3, we may disclose your personal data where such disclosure
is necessary for compliance with a legal obligation to which we are
subject, or in order to protect your vital interests or the vital
interests of another natural person. We may also disclose your personal
data where such disclosure is necessary for the establishment, exercise
or defence of legal claims, whether in court proceedings or in an
administrative or out-of-court procedure.

4. Retaining and deleting personal data

4.1 This Section 4 sets out our data retention policies and procedure,
which are designed to help ensure that we comply with our legal
obligations in relation to the retention and deletion of personal data.

Article 5(1)(e) of the GDPR sets out the storage limitation, one of
the fundamental rules of the regime:

"Personal data shall be kept in a form which permits identification
of data subjects for no longer than is necessary for the purposes for
which the personal data are processed; personal data may be stored for
longer periods insofar as the personal data will be processed solely
for archiving purposes in the public interest, scientific or
historical research purposes or statistical purposes in accordance
with Article 89(1) subject to implementation of the appropriate
technical and organisational measures required by this Regulation in
order to safeguard the rights and freedoms of the data subject".

4.2 Personal data that we process for any purpose or purposes shall not
be kept for longer than is necessary for that purpose or those purposes.

4.3 We will retain your personal data in order for us to provide our
services (and those of our partners) to you, such as, those offers that
you opt-in to receive via the website and, following deletion of your
account on our website, for a maximum period of 6 months.

4.4 Notwithstanding the other provisions of this Section 4, we may
retain your personal data where such retention is necessary for
compliance with a legal obligation to which we are subject, or in order
to protect your vital interests or the vital interests of another
natural person.

5. Security of personal data

5.1 We will take appropriate technical and organisational precautions to
secure your personal data and to prevent the loss, misuse or alteration
of your personal data.

5.2 We will store all your personal data on secure servers, and in
secure manual record-keeping systems.

5.3 You should ensure that your password is not susceptible to being
guessed, whether by a person or a computer program. You are responsible
for keeping the password you use for accessing our website confidential
and we will not ask you for your password (except when you log in to our
website).

6. Amendments

6.1 We may update this policy from time to time by publishing a new
version on our website.

6.2 You should check this page occasionally to ensure you are happy with
any changes to this policy.

6.3 We will notify you of significant changes to this policy by email or
through the private messaging system on our website.

7. Your rights

7.1 In this Section 7, we have summarised the rights that you have under
data protection law. Some of the rights are complex, and not all of the
details have been included in our summaries. Accordingly, you should
read the relevant laws and guidance from the regulatory authorities for
a full explanation of these rights.

7.2 Your principal rights under data protection law are:

(a) the right to access;

(b) the right to rectification;

(c) the right to erasure;

(d) the right to restrict processing;

(e) the right to object to processing;

(f) the right to data portability;

(g) the right to complain to a supervisory authority; and

(h) the right to withdraw consent.

7.3 You have the right to confirmation as to whether or not we process
your personal data and, where we do, access to the personal data,
together with certain additional information. That additional
information includes details of the purposes of the processing, the
categories of personal data concerned and the recipients of the personal
data. Providing the rights and freedoms of others are not affected, we
will supply to you a copy of your personal data. The first copy will be
provided free of charge, but additional copies may be subject to a
reasonable fee.

7.4 You have the right to have any inaccurate personal data about you
rectified and, taking into account the purposes of the processing, to
have any incomplete personal data about you completed.

7.5 In some circumstances you have the right to the erasure of your
personal data without undue delay. Those circumstances include: the
personal data are no longer necessary in relation to the purposes for
which they were collected or otherwise processed; you withdraw consent
to consent-based processing; you object to the processing under certain
rules of applicable data protection law; the processing is for direct
marketing purposes; and the personal data have been unlawfully
processed. However, there are exclusions of the right to erasure. The
general exclusions include where processing is necessary: for exercising
the right of freedom of expression and information; for compliance with
a legal obligation; or for the establishment, exercise or defence of
legal claims.

7.6 In some circumstances you have the right to restrict the processing
of your personal data. Those circumstances are: you contest the accuracy
of the personal data; processing is unlawful but you oppose erasure; we
no longer need the personal data for the purposes of our processing, but
you require personal data for the establishment, exercise or defence of
legal claims; and you have objected to processing, pending the
verification of that objection. Where processing has been restricted on
this basis, we may continue to store your personal data. However, we
will only otherwise process it: with your consent; for the
establishment, exercise or defence of legal claims; for the protection
of the rights of another natural or legal person; or for reasons of
important public interest.

7.7 You have the right to object to our processing of your personal data
on grounds relating to your particular situation, but only to the extent
that the legal basis for the processing is that the processing is
necessary for: the performance of a task carried out in the public
interest or in the exercise of any official authority vested in us; or
the purposes of the legitimate interests pursued by us or by a third
party. If you make such an objection, we will cease to process the
personal information unless we can demonstrate compelling legitimate
grounds for the processing which override your interests, rights and
freedoms, or the processing is for the establishment, exercise or
defence of legal claims.

7.8 You have the right to object to our processing of your personal data
for direct marketing purposes (including profiling for direct marketing
purposes). If you make such an objection, we will cease to process your
personal data for this purpose.

7.9 To the extent that the legal basis for our processing of your
personal data is:

(a) consent; or

(b) that the processing is necessary for the performance of a contract
to which you are party or in order to take steps at your request prior
to entering into a contract,

and such processing is carried out by automated means, you have the
right to receive your personal data from us in a structured, commonly
used and machine-readable format. However, this right does not apply
where it would adversely affect the rights and freedoms of others.

7.10 If you consider that our processing of your personal information
infringes data protection laws, you have a legal right to lodge a
complaint with a supervisory authority responsible for data protection.
You may do so in the EU member state of your habitual residence, your
place of work or the place of the alleged infringement.

7.11 To the extent that the legal basis for our processing of your
personal information is consent, you have the right to withdraw that
consent at any time. Withdrawal will not affect the lawfulness of
processing before the withdrawal.

7.12 You may exercise any of your rights in relation to your personal
data by written notice to us.

8. Third party websites

8.1 Our website includes hyperlinks to, and details of, third party
websites.

8.2 We have no control over, and are not responsible for, the privacy
policies and practices of third parties.

9. Personal data of children

9.1 Our website and services are targeted at persons over the age of 18.

9.2 If we have reason to believe that we hold personal data of a person
under that age in our databases, we will delete that personal data.

10. Acting as a data processor

10.1 In respect that we do not act as a data controller, instead we act
as a data processor.

10.2 Insofar as we act as a data processor rather than a data
controller, this policy shall not apply. Our legal obligations as a data
processor are instead set out in the contract between us and the
relevant data controller.

11. About cookies

11.1 A cookie is a file containing an identifier (a string of letters
and numbers) that is sent by a web server to a web browser and is stored
by the browser. The identifier is then sent back to the server each time
the browser requests a page from the server.

11.2 Cookies may be either "persistent" cookies or "session"
cookies: a persistent cookie will be stored by a web browser and will
remain valid until its set expiry date, unless deleted by the user
before the expiry date; a session cookie, on the other hand, will expire
at the end of the user session, when the web browser is closed.

11.3 Cookies do not typically contain any information that personally
identifies a user, but personal information that we store about you may
be linked to the information stored in and obtained from cookies.

12. Cookies that we use

12.1 The types of cookies that we use are both session and persistent
cookies

12.2 We use cookies for the following purposes:

(a) authentication - we use cookies to identify you when you visit our
website and as you navigate our website;

(b) status - we use cookies to help us to determine if you are logged
into our website;

(c) orders of goods/services - we use cookies to maintain the state of
your orders as you navigate our website;

(d) personalisation - we use cookies to store information about your
preferences and to personalise our website for you;

(e) security - we use cookies as an element of the security measures
used to protect user accounts, including preventing fraudulent use of
login credentials, and to protect our website and services generally;

(f) advertising - we use cookies to help us to display advertisements
that will be relevant to you;

(g) analysis - we use cookies to help us to analyse the use and
performance of our website and services; and

(h) cookie consent - we use cookies to store your preferences in
relation to the use of cookies more generally.

13. Cookies used by our service providers

13.1 Our service providers use cookies and those cookies may be stored
on your computer when you visit our website.

13.2 We use Google Analytics to analyse the use of our website. Google
Analytics gathers information about website use by means of cookies. The
information gathered relating to our website is used to create reports
about the use of our website. Google's privacy policy is available at:
https://www.google.com/policies/privacy/

14. Managing cookies

14.1 Most browsers allow you to refuse to accept cookies and to delete
cookies. The methods for doing so vary from browser to browser, and from
version to version. You can however obtain up-to-date information about
blocking and deleting cookies via these links:

(a)
https://support.google.com/chrome/answer/95647?hl=en

(b)
https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

(c)
http://www.opera.com/help/tutorials/security/cookies/

(d)
https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies

(e)
https://support.apple.com/kb/PH21411

and

(f)
https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy

14.2 Blocking all cookies will have a negative impact upon the usability
of many websites.

14.3 If you block cookies, you will not be able to use all the features
on our website.

15. Our details

15.1 This website is owned and/or controlled by Seed Media Limited.

15.2 We are registered in England and Wales under registration number
06487246, and our registered office is at 35 Westgate, Huddersfield, HD1
1PA.

15.3 You can contact us:

(a) using our website contact form;

(b) by email, using the email address published on our website from time
to time.

16. Data protection registration

16.1 We are registered as a data controller with the UK Information
Commissioner's Office.

16.2 Our data protection registration number is ZA114793.