Privacy And Data Security Policy

Business Privacy Policy

Waverley Media Ltd, and its wholly owned subsidiary Markiteer Ltd respects your privacy and is committed to protecting your personal data, This privacy policy sets out how we use and protect any information that you give us when you interact with us by visiting our web sites, opening our emails, making a purchase, or other form of direct communication.

Our Cookies Policy is also set out at the end of this Privacy Policy.

 

Who we are and other Important Information

Waverley Media Ltd is committed to ensuring that your privacy is protected. Should we ask you to provide information by which you can be identified when using this web site, then you can be assured that it will only be used in accordance with this privacy statement.

This web site is not intended for children (those under the age of 18), and we do not knowingly collect data relating to children.

If you are under the age of 18 you must leave this site immediately. Fraudulent use of this web site may make you subject to civil or criminal sanctions.

We do not collect sensitive data such as ethnic origin, religious beliefs, and medical issues.

Waverley Media Ltd may change this policy from time to time by updating this page and will inform you when updates have occurred using a ‘pop up’ banner on the Web Site. You should check this page from time to time to ensure that you are happy with any changes. This policy was last updated on 23rd May 2018.

The Data Controller

Waverley Media Ltd is the controller and is responsible for your personal data (referred to as “we”, “us”, or “our” in this Privacy Policy).

We have appointed a person who is responsible for overseeing questions you may have in relation to this Privacy Policy. If you have any questions, or Data requests, please contact us by emailing timlowe@markiteer.com, and state that your query is for the attention of the Data Protection Lead.

Contact Details

Our details are:

Waverley Media Ltd, registered in the UK company number 03683874.

Our registered office is: 99 Weyhill, Haslemere, Surrey, GU27 1HT

Our Postal Address is: Waverley Farm, Waverley Lane, Farnham, Surrey, GU9 8EP

You can contact us by email at timlowe@markiteer.com

We always appreciate the chance to deal with any concerns you may have relating to your data before you approach the Information Commissioner’s Office (ICO. Please contact us in the first instance and we will be happy to help you. However, you have the right to make a complaint at any time to the ICO. Please read https://ico.org.uk/your-data-matters/ for further details.

Your Duty to Us

It is important that the personal data we hold about you is accurate and up to date. Please ensure that you give us accurate data, and keep us informed if your personal data changes during your relationship with us.

Third Party Links

This web site may include links to third-party web sites, 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 third-party web sites and are not responsible for their privacy statements. If you leave our web site, please refer to and read the Privacy Policy of every web site you visit.

How we collect your Personal Data

We collect your Personal Data via direct interaction with you when you:

• Visit our web sites and enter using a password we have provided to you;
• Purchase a product or service from us;
• Opt in to a free subscription service from us;
• Request to be kept aware of our services;
• Give us feedback;
• Interact with our web sites;
• Open marketing emails we have sent you.

We may also collect anonymous data when you visit our websites without using a password or login. Such data is not classed as personal data because you cannot be identified from it.

 

What We Collect

Personal Data means any information about an individual from which that person can be identified.

We may collect, use, store, and transfer the following information about you (we have grouped the data we collect as follows, to enable ease of understanding):

1. Identity Data: Your first and last name, including any title
2. Contact information: Including your billing address, delivery address, email address and telephone number
3. Financial Data: We do not store or process your card details ourselves. They are processed and stored via a contracted third party service provider, who encrypt your payment card details. We are unable to see your full credit card details.
4. Transaction Data: Details about transactions you have made including payments to us along with other details of product and services you have purchased from us. As well as storing this information ourselves, it is also stored by a contracted third party service provider who is GDPR compliant.
5. Profile Data: Your username and password, your login data, purchases or orders made by you, your interests, preferences, feedback and survey responses.
6. Technical Data: Details about the device(s) you use to access our web site including your IP address, browser type and version, location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this web site. Some of this data may be collected anonymously and so in some instances may not constitute Personal Data. If you have accessed our web site using a password sent on a postal mailing, we may also track your name and mailing code/description of the mailing you have contacted us from, in which case the data again constitutes Personal Data. We may also track whether you have received and opened emails from us, and whether you have clicked through to our web site from any links in those emails.
7. Usage Data: Information about how you use our web site, products and services such as browsing patterns and information such as how long you might spend on one of our web pages and what you look at on our web site, how often you have logged into or visited our web sites, where you visit our web site from, page response times, and page interaction information such as scrolling, clicks, and mouseovers. Some of this data may be collected anonymously and so in some instances may not constitute Personal Data.
8. Marketing and Communications Data: This includes your preferences in receiving marketing from us and your communication preferences.

 

What we do with the information we gather

We require the information we gather to understand your needs and provide you with a better service, and in particular for the following reasons:

• 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.
• Internal record keeping.
• We may use the information to improve our products and services.
• We may periodically send promotional emails and postal mailings about new products, special offers or other information which we think you may find interesting using the email and postal addresses which you have provided. This may include information about products available from other 3^rd parties.
• We may contact you if we have a financial query relating to any purchases you have made from us
• We may contact you if we have a customer service-related issue to discuss with you.
• From time to time, we may also use your information to contact you for market research purposes. We may contact you by email or post. We may use the information to customise the web site according to your interests. We do not store your credit card details. They are processed and stored via a contracted third party service provider, who encrypt your payment card details. We are unable to see your full credit card details.

 

Generally, we do not rely on consent as a legal basis for processing your personal data, unless you have not purchased a product from us but have specifically requested that we send you information or marketing material.

Where we rely on legitimate interest as the lawful basis for processing your personal data, we will consider and balance any potential impact on you before we process such data for our legitimate interests. In such cases where our interests would be outweighed by the impact on you, we do not process your personal data, unless there is another lawful basis for us to do so, such as consent, or to comply with a legal or regulatory obligation.

Please see the following table to see what type of personal data we use for what purpose, and on what lawful basis we process this data.

 

Purpose/Activity	Type of data	Lawful basis for processing
To register you as a new customer	Identity Data Contact Information Profile Data Marketing and Communications Data	Contractual necessity
To update your customer records	Identity Data Contact Information Profile Data Financial Data Marketing and Communications Data	Contractual necessity – we need to be able to contact you and process any payments you owe us. We also have a legitimate Interest in staying in contact with you, as we may also wish to let you know about additional products or services that may be of interest to you (you can opt-out of hearing about these if you wish)
To process and deliver a product or service you have purchased from us: Managing payments, fees and charges; and Managing your queries through our Admin or Customer service team, or letting you know about relevant issues	Identity Data Contact Information Financial Data Profile Data Marketing and Communications Data	Contractual necessity: We need this information in order to perform our contract with you, so that we can take payments from you. We also need to be able to contact you in order to reply to queries you might have raised with us, or to let you know about new developments that may affect you.
To collect or recover money you owe us	Identity Data Contact Information Financial Data Transaction Data Profile Data	Necessary for our legitimate interests so that we can recover any money you may owe us.
To carry out fraud assessments	Identity Data Contact Information Financial Data Transaction Data Technical Data	Necessary for legitimate interest to ensure that payments are not fraudulent.
To notify you in relation to our legal obligations and documents, including but not limited to changes to our terms or Privacy Policies	Identity Data Contact Data Profile Data	Necessary for our legitimate interest to ensure that customers are notified of changes and updates for our policies
To administer and protect our business and web sites	Identity Data Contact Data Profile Data Technical Data	Necessary for our legitimate interest to ensure that we run our business fairly, profitably, and within the law and that we are able to restructure it as necessary, to provide adequate IT and administration services, for network security, to prevent fraud.
To deliver relevant web site content and marketing material to you, and to measure or understand the effectiveness of the material to you	Identity Data Contact Data Profile Data Technical Data Usage Data Marketing & Communications Data	Necessary for our legitimate interests, to understand how customers use our products and services, to develop and update products and services, to inform our marketing strategies and to improve the way we interact with you. Where cookies are used, please see our Cookies Policy at the end of this document.
To use data analytics to improve our web site, products and services, and customer relationships	Technical Data Usage Data	Necessary for our legitimate interests, so that we know who uses and wants to use our products and services, so that we can update our web sites and ensure they remain relevant and useful to customers, to help us decide what kind of products our customers are interested in, to aid us in developing new products, and to inform our marketing strategies. Where cookies are used, please see our Cookies Policy at the end of this document
To send you marketing communications, to suggest or recommend goods or services that we or third parties provide that may be of interest to you	Identity Data Contact Data Technical Data Usage Data Profile Data Marketing & Communications Data	Necessary for our legitimate interests, so that we can develop our products and services, grow our business, and improve our offerings to you. If you have not previously purchased from us, but specifically ask us to keep you informed or to send you marketing and other communications, your Consent will form the basis of our use of your data.

 

 

We do not conduct online behavioural tracking of our customers.

We will only use your personal data for the purpose for which we collected it, unless we need to use it for another reason which is compatible with the original purpose.

If we need to use your personal data for a purpose which is unrelated to the reason it was collected, we will notify you and explain the legal basis on which we are allowed to use it.

In some rare cases, we may process your personal data without your knowledge or consent. This would only be done as required or permitted by law, such as if we are instructed to process your data by Court Order, as part of a criminal investigation, or similar.

Marketing

We may use your Identity, Contact, Technical, Usage, and Profile Data to help us work out what type of products or services you may be interested in and what may be relevant to you. We do not track what other web sites other than our own you might visit, but use only the data you provide to us directly, and general market data. However we may register which site referred you to our site (for example, a search engine, a blog, or an advertisement on a particular site).

We will usually only send you marketing, which may be in the form of a letter through the post, or by email, if you have previously purchased a product or service from us or as the result of a historical joint promotion with another Company in which case we consider there is a legitimate interest for us to process your data and send you information.

If you have not previously purchased from us, but have specifically requested to receive information from us, then you have consented to us sending such information and we rely on your express consent in order to process your data.

In cases where we consider there is a legitimate interest for us to send you such information, we continually review the basis for this interest. Should we discover that you have not opened any emails from us for a long time, or if a postal mailing is returned with person unknown at the address for example, then we will stop processing your personal information and will remove your details from our database unless there is a legitimate basis for us to keep it.

In the case where we send you a marketing communication, it may be necessary for us to pass your personal details to a third party in order to send such communication. For example, we may need to pass your Identity Data, and your Contact Data, to our printers in order to have letters and envelopes printed with your name and address. Where it is necessary for us to do this, we will do our best to ensure your personal data is processed securely. We only use suppliers who are GDPR compliant.

Opting Out of Marketing

You can opt out of receiving marketing communications from us at any time. To opt out of our email communications, simply ‘unsubscribe’ using the link provided on one of our emails. To opt out of postal mail marketing communications, please telephone us, write to us at our address, or email us at timlowe@markiteer.com.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. Please note that disabling or refusing cookies may affect the usability of a web site. For further information please see the Cookies Policy at the end of this document.

Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

In the case of a data breach or suspected data breach, we have put procedures in place to deal with such a situation swiftly, and will notify you and any applicable regulatory organisation where we are legally required to do so.

Please be aware that the internet can never be a completely secure medium for communication. We cannot guarantee the security of information you send to us, or which we send to you, via the internet. We are not responsible for any damage which you, or others, may suffer as a result of the loss of confidentiality of such information, save in such cases as we have used your data illegally or failed in our duty to keep it secure to the best of our ability.

Length of Retention of Personal Data

We will only retain your data for as long as necessary to fulfil the purposes we collected it for, or to satisfy any legal, accounting, or reporting requirements.

In some circumstances you may be able to ask us to delete your data. In some cases where deletion is not legally possible, we may still be able to anonymise your data

Your Legal Rights

You have the right to:

Request access to your personal data. You will receive a copy of the personal data we hold about you and you can check that we are processing it on a lawful basis.

Correct or update the personal data we hold about you in order to ensure accuracy.

Request that we erase your personal data, unless there is a legal reason which overrides your request. In cases where we are unable to erase your personal data because there is a legal obligation for us to process it, you can request that we restrict our processing of your data to only those functions lawfully required. This may be that some, but not all, of the personal data we hold can be erased.

Object to our processing of your personal data if we are relying on the basis of legitimate interest and you feel that your fundamental rights and freedoms override our legitimate interest.

Withdraw your consent for us to process your personal data, in the case where we are relying on consent as the lawful basis for us to process your data. This will not affect the lawfulness of any processing carried out before you withdraw your consent.

If you wish to exercise any of these rights, please contact us in writing at our address,or by emailing us at timlowe@markiteer.com.

You will not normally have to pay a fee to access your personal data, unless your request is clearly unfounded, repetitive, or excessive. In such cases we may either charge a fee, or refuse your request.

Data access requests will normally be responded to within one month, unless your request is extremely complex or if you make a number of separate and updated requests. We will remain in contact with you to update you of any ongoing delays and the reasons for these.

 

How We Use Cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. If you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes, by remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our web site in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better web site, by enabling us to monitor which pages you find useful and which you do not. A cookie does not give us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. Please be aware that this may prevent you from taking full advantage of the web site.

Your Personal Information

We will not sell, lease or distribute your personal data to third parties unless we are required by law to do so. We may use your personal information to send you promotional information about third parties which we think you may find interesting unless you tell us that you do not wish for this to happen.

You may request details of personal information which we hold about you under the Data General Data Protection Regulation (GDPR) (EU) 2016/679. If you would like a copy of the information held on you, or have any other related query, please send an email to timlowe@markiteer.com

If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.

Questions, Comments, or Report of Incidents

You may direct questions, comments or reports to: timlowe@markiteer.com

 

Cookie Policy

Cookies are small text files placed on your computer by websites that you visit. They are used to collect standard internet log information and visitor behaviour information.

Sometimes a string of random characters known as an anonymous identifier may be used in place of a cookie.

When you visit the website that generated a particular cookie, your internet browser accesses the cookie file. This means that your experience can be made easier by such things as: automatically logging you into a site; and remembering particular preferences.

Some cookies are only stored whilst you browse a web site and are automatically deleted once your close your browser.

Others are stored in your computer memory and retain your preferences so that they are remembered the next time you visit the web site that generated them.

You can use your internet browser to enable, disable, and manage some or all cookies. Please check the ‘Help’ menu of your particular browser to learn how to change your cookie preferences. To help you we have provided links to information on how to remove and/or delete cookies with some of the most widely used web browsers. Please be aware that if you block cookies from websites, some or all of the website's functions may not operate as intended.

Firefox

Internet Explorer

Google Chrome

Safari

 

 

Last amended 15^th October 2018