Privacy Policy

Last Updated – 25 May 2018

Hurst Media Company Limited (including its affiliate and subsidiary companies see below) (”We”, “us”) are committed to protecting and respecting your privacy.

This policy (together with our terms of use https://www.hurstmediacompany.co.uk/terms-of-website-use/ and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, or 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. By visiting the following www.hurstmediacompany.co.uk and/or www.celebritysecrets.com you are accepting and consenting to the practices described in this policy.

For the purpose of the General Data Protection Regulations EU 2016/679 (the Regulations), the data controller is Hurst Media  Company Limited (No. 8375910) of United House, North Road, Islington, London, N7 9DP 

INFORMATION WE COLLECT FROM YOU  

We will collect and process the following data about you:

  • Information you give us. This is information about you that you give us by filling in forms on our site www.hurstmediacompany.co.uk and/or www.celebritysecrets.com (our sites) or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, subscribe to our service, search for a product, place an order on our site, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, and when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information, personal description and photograph.
  • Information we collect about you. With regard to each of your visits to our site we will automatically collect the following information:
  • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
  • information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for’ page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.
  • Information we receive from other sources. This is information we receive about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data if we intend to share those data internally and combine it with data collected on this site. We will also have told you for what purpose we will share and combine your data. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.

EMPLOYEE INFORMATION

Personal information (or personal data as defined by the Regulations) for purposes of this Privacy Notice, means any information that (i) directly and clearly identifies an individual, or (ii) can be used in combination with other information to identify an individual.

The following is a non exhaustive list of Personal Information We may collect from our employees:

• Names and contact details of relatives for in case of emergency purposes.

• Home address.

• Home phone number.

• Email address.

• An individual’s name

• Date of birth.

• Network ID, IP Address, network activities and communications.

We will process employee data for the essential performance of rights and obligations under a contract of employment, for example payroll and pension benefits or to comply with laws and regulations such health and safety or tax.

We also process employee data for legitimate business purposes including but not limited to:

• Employee communications, including development and training programs;

• Human resource functions including management of employee performance, beneficiary information, compensation and benefits;

• Background checks, emergency contact list, reference checks and terminations.

• Managing the security of our network infrastructure to protect company, employees and customers’ data through the use of monitoring technologies such as data loss prevention tools, next generation firewall, and security incident and event management tools.

Sensitive employee data such as salary and performance evaluations may be accessible by other Hurst Media Company Limited employees (or our Human Resource advisers) only if required for legitimate purpose related to human resource functions or associated employee issues.

Hurst Media Company Limited will obtain an employees consent before using their personal data for any purpose not described in this Privacy Policy

COOKIES  

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie policy https://www.hurstmediacompany.co.uk/cookie-policy/.

USES MADE OF THE INFORMATION  

We use information held about you in the following ways:

  • Information you give to us. We will use this information:
  • to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
  • to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
  • to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data (the order form OR registration form);
  • to notify you about changes to our service;
  • to ensure that content from our site is presented in the most effective manner for you and for your computer.
  • Information we collect about you. We will use this information:
  • to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
  • to allow you to participate in interactive features of our service, when you choose to do so;
  • as part of our efforts to keep our site safe and secure;
  • to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
  • to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
  • Information we receive from other sources. We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

DISCLOSURE OF YOUR INFORMATION  

You agree that we have the right to share your personal information with:

  • Any member of our group, which means our subsidiaries (including those listed below), our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
  • Selected third parties including:
  • business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
  • advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers without express written informed consent, but we will 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). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience;
  • analytics and search engine providers that assist us in the improvement and optimisation of our site;
  • credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.

We will disclose your personal information to third parties:

  • In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
  • If Hurst Media Company Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use https://www.hurstmediacompany.co.uk/terms-of-website-use/ or terms and conditions of supply https://www.hurstmediacompany.co.uk/hurst-media-advertising-terms/and other agreements; or to protect the rights, property, or safety of Hurst Media Company Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

INFORMATION PROCESSOR ACTIVITIES

Hurst Media Company Limited (and its affiliates and subsidiaries) operate as a data processor for our business customers located in the EU and other locations worldwide. Our business customers remain the data controllers with respect to any customer data that they provide to us for our provision of services. We therefore act in accordance with the instructions of such customers regarding the collection, processing, storage, deletion, access, rectification, portability and transfer of customer data.

WHERE WE STORE YOUR PERSONAL DATA  

The data that we collect from you maybe transferred to, and stored at, a destination outside the European Economic Area (”EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will to ensure that your data is treated securely and in accordance with this privacy policy.  Unless notified otherwise, any transfer of data to a processor or sub processor outside the EEA will be done subject to Hurst Media Company Limited entering into Data Transfer Agreement under the EU Model Clauses with the processor or sub processor  – so as to ensure appropriate technical and organisational in relation to how that data is stored and processed and to ensure it is processed only in accordance with the Regulations.

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which 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.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

YOUR RIGHTS  

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at DataPrivacy@hurstmediacompany.co.uk .

We will make reasonable efforts to adhere to any requests made either (i) under this section or (ii) the section marked “Access to Information” – unless the requests are prohibited as a matter of law or there is a legitimate purpose for retaining the data pursuant to the Regulations.

Our site 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. Please check these policies before you submit any personal data to these websites.

ACCESS TO INFORMATION  

Your right of access can be exercised in accordance with the Regulations. Any access request will be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.  We reserve the right to verify your identity before we comply with any request.  If you would like to request a copy of the personal information we hold on you please contact us at:

DataPrivacy@hurstmediacompany.co.uk

Hurst Media Company – Privacy

United House, North Road, Islington, London, N7 9DP

MONITORING AND ENFORCEMENT 

Hurst Media Company Limited regularly reviews our compliance with our privacy policy. We also adhere to several self-regulatory frameworks in addition to complying with applicable laws. If we receive formal written complaints, we will follow up with the person making the complaint. We will work with the appropriate regulatory authorities to resolve any complaints that cannot be resolved directly.

If personal information of EU individuals is received directly from our clients, we will provide reasonable assistance to our clients:

• in informing the impacted data subjects about (a) that we may disclose such individuals’ information to third parties and (b) the data subjects’ right to opt out of such disclosures (except for disclosures to third parties performing tasks directly on our behalf and pursuant to our instructions); and

• reasonably ensure that the information is processed for the purposes for which it was originally collected or consented by the data subjects. After we have notified our clients, they will then inform us if any individuals have opted out of such disclosures.

CHANGES TO OUR PRIVACY POLICY  

Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

CONTACT  

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to DataPrivacy@hurstmediacompany.co.uk .

HURST MEDIA COMPANY LIMITED – AFFILIATES AND SUBSIDIARIES

Hurst Media Agency Limited

Hurst Media Company (Assets) Limited.

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Necessary

Advertising

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