Purpose of this privacy notice

This privacy notice aims to give you information on how For Media Group Limited collects and processes your personal data, including any data you may provide through our website.

Controller

For Media Group Limited (company number 13063455) is the controller and responsible for your personal data (referred to as "we", "us" or "our" in this privacy notice).

We have appointed a data protection officer ("DPO") who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact Details

Whilst 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 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

We may amend this privacy notice from time to time and you are advised to ensure that you are familiar with the latest version.

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.

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:

• Identity Data includes but is not limited to first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender
• Contact Data includes but is not limited to 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 products and services you have purchased from us
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, 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 our website
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses
• Usage Data includes information about how you use our website, products, and services
• 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 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.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). If, however this information becomes necessary in order for us to fulfil our obligations to you then we will specifically request this information from you.

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 goods or services). 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.

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• buy our products or services;
• provide information via our website;
• request marketing to be sent to you;
• 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 and other similar technologies. Please see our cookie policy for further details.
  
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources including:
• Technical Data from analytics providers such as Google based outside the EU;
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services;
• Identity and Contact Data from data brokers or aggregators;
• Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
• Data we buy from a third party

We occasionally purchase data from third party suppliers. The data we purchase is primarily business data. Business data may include but not be limited to a business email address, business job title and business postal address. Such a purchase may result in you receiving communications from For Media Group Limited regarding your business sector or business interests without you having directly supplied your information to us. We keep clear records of the data suppliers and provide an unsubscribe option at every contact. If you have any queries concerning the use of business data, we hold about you please email Sara Smith (sara@formediagroup.co.uk).

• Data we collect through your use of our websites

We may collect information about how you use our websites or other content online, and the device(s) you use to access the services. This includes collecting unique online identifiers such as IP addresses, which are numbers that can uniquely identify a specific computer or other network device on the internet. Anonymous data will be recorded for the purpose of reporting web traffic statistics, advertisement ‘click-throughs’, and/or other activities on our sites. We may receive information about you from any third parties we may partner with through the use of cookie technologies to personalise advertisements for goods and services (please see Online Advertising below for further information) To opt out of receiving advertisements tailored to your interests by our partners, visit the European Interactive Digital Advertising Alliance at http://youronlinechoices.eu/. For detailed information on Cookies please visit our Cookie Policy.

• Online Advertising

For Media Group Limited website shows advertising to users when a specific level of subscription is chosen. A certain amount of this advertising is tailored to the individual user, a practice known as “Online Behavioural Advertising” which uses cookies to discover general information about the pages you visit. This keeps our websites and services you use free of charge in certain instances. Our advertising delivery systems and partners uses the limited information available to it to serve adverts to you, which it believes are relevant. It does not collect personal information such as your name, email address postal address or telephone number.

From time to time, For Media Group Limited may share this aggregated data with our advertising partners. This could mean that when you are on other websites you are served advertising based on your behaviour across For Media Group Limited or you may be served advertising based on your behaviour on other sites.

Behavioural retargeting is another form of Online Behavioural Advertising that enables us and some of our advertising partners to show you adverts based on browsing patterns and interactions with the site away from our sites. For example, if you have visited the website of a car dealership you may start seeing adverts from that same dealership site displaying special offers or showing you the products that you were browsing. This allows companies to advertise to website visitors who leave their website without making a purchase.

If you want to opt out of receiving Online Behavioural Advertising this does not mean that you will no longer receive advertising when you are using our sites. It just means that the advertising you see will not be customised for you. If you would like more information about online behavioural targeting and how to opt out of it, please visit www.youronlinechoices.com or you can also visit http://www.networkadvertising.org.

Our websites uses JavaScript to detect the use of ad blocking extensions for web browsers, we do not store any information on users’ devices and do not process any personal data.

• 
  Links to third party websites

When you click on advertisements or links on any of our sites, you will leave that site and go to a third-party site, which is outside of our control. When we place an advertisement on one of our sites, it does not signify that we are endorsing that advertiser’s product or service. We do not accept responsibility for content, have no control over and our Privacy Policy does not apply to these companies, sites, or content and if such third-party sites collect personal data, we cannot control how this data is processed, stored, or used. We advise that you read their data collection statements, which accompany any registration and their Privacy Policies before you submit your personal information

• Social Media Features

Our Websites include Social Media Features, such as the Facebook Like button and Widgets, such as the Share Button or interactive mini-programs that run on our sites. These features may collect your IP address, which page you are visiting on our sites, and may set a cookie to enable the feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Websites. This Privacy Policy does not apply to these features. Your interactions with these features are governed by the privacy policy and other policies of the companies providing them.

• When You Visit our Websites

You are free to explore the Websites without providing any Personal Information about yourself. When you register for a Subscription Service, we request that you provide Personal Information about yourself, and we collect Navigational Information depending on the level of subscription service selected.

• When purchasing a free or paid subscription

We may collect certain personal data if you sign up for a free account, a trial or purchase any of our Paid Subscriptions or make other purchases with For Media Group Limited. The exact personal data collected will vary depending on the payment method (e.g., direct via your mobile phone carrier or by invoice) but will include information such as:

• Name / Job Title / Company Details / Credit or debit card type, expiration date, and certain digits of your card number;

• Address / Postal code / Mobile phone number / Details of your purchase and payment history / Areas of interest;

Please note that when signing up to a subscription, certain personal data will be shared with our carefully selected 3^rd party advertisers, partners, and sponsors. To opt-out, please email Sara Smith sara@formediagroup.co.uk.

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.

Please note that the levels of personal data use will vary depending on the level of subscription entered into. For example, by signing up to a free subscription, certain personal data will be shared with our carefully selected 3^rd party advertisers, partners, and sponsors.

• 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.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out in the schedule to this privacy notice 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. We have also identified what our legitimate interests are where appropriate.

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.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. For example:

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 purchased services from us or if you provided us with your details when you entered a competition or registered for a promotion 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 other than For Media Group Limited for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time 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 services you may have purchased.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

Change of purpose

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 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, in compliance with the above rules, where this is required or permitted by law.

We may have to share your personal data with the parties set out below for the purposes set out in the schedule referred to in paragraph 4 above:

• 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.

Please note that when signing up to a free subscription, certain personal data will be shared with our carefully selected 3rd party advertisers, partners, and sponsors.

We do not transfer your personal data outside the European Economic Area (EEA).

If, however it is necessary for us to transfer your personal data out of the EEA, we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries;
  
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries;
  
• Where we use providers 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 if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

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. 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.

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, and the applicable legal requirements.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see the Glossary 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.

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.

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.

THIRD PARTIES

External Third Parties

• Service providers acting as processors who provide IT and system administration services.
• Professional advisers acting as processors or joint controllers including other lawyers, bankers, auditors, and insurers who provide consultancy, banking, insurance, and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
• When signing up for a subscription certain personal data will be shared with For Media Group Limited's carefully selected 3^rd party advertisers, partners, and sponsors.

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.

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.

SCHEDULE

Lawful Bases