Privacy & Cookie Policy

Introduction

Brave Bison Limited, Brave Bison Group plc and each of their subsidiaries (collectively referred to as Brave Bison, “we”, “us” or “our” in this privacy notice) are committed to protecting and respecting your privacy.

This privacy notice will inform you as to how we use any of your personal data we might collect: (i) when we provide you with products or services; (ii) when you visit our websites or applications (regardless of where you visit it from); or (iii) in the course of conducting our day to day business.

  1. Information we may collect from you

    Purpose of this privacy notice

    This privacy notice aims to give you information on how Brave Bison collects and processes your personal data when providing services to you, through your visiting of our websites or applications, or otherwise in the course of conducting its day to day business.

    Our websites, applications and services are not intended for children and we do not knowingly collect data relating to children.

    It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

    Controller

    Brave Bison is the controller and responsible for your personal data.

    Brave Bison is made up of different legal entities. This privacy notice is issued on behalf of the Brave Bison Group so when we mention “Brave Bison”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Brave Bison Group responsible for processing your data. Brave Bison Limited is the controller and responsible for this website and other websites and applications incorporating this Privacy and Cookie Policy.

    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

    Our full details are:

    Full name of legal entity: Brave Bison Limited

    Name and Title of DPO: Phillippa Norridge, CFO

    Email address: [email protected]

    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, however, 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

    This version was last updated on 1 October 2019.

    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.

    Third-party links

    Brave Bison’s websites and applications may include links to third-party websites, 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 these third-party websites and are not responsible for their privacy statements. When you leave our websites or applications, we encourage you to read the privacy notice of every website you visit.

  2. The data we collect about you

    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 first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
    • Contact Data includes 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 websites or applications.
    • 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 websites, applications, 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). Nor do we collect any information about criminal convictions and offences.

    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.

  3. How is your personal data collected?

    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:
    • request our products or services;
    • enter into discussions or correspondence with us in relation to our services;
    • enter into a contract with us;
    • create accounts on our websites or applications;
    • subscribe to our services or publications;
    • 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 websites or applications, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We would collect this personal data by using cookies and other similar technologies. Please see our cookie policy at section under section 10 below for further details.
    • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
    • Technical Data from analytics providers such as Google based outside the EU; and
    • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
  4. How we use your personal data

    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.
    • 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.

    Please see the Glossary under section 11 for descriptions of the types of lawful basis that we will rely on to process your personal data.

    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 below, in a table format, 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. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

    Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
    To register you as a new client (a) Identity
    (b) Contact
    Performance of a contract with you
    To process and deliver services to you including (without limit):
    (a) Managing payments, fees and charges
    (b) Administering your account with us
    (a) Identity
    (b) Contact
    (c) Financial
    (d) Transaction
    (e) Marketing and Communications
    (a) Performance of a contract with you
    (b) Necessary for our legitimate interests (to recover debts due to us)
    To manage our relationship with you (a) Identity
    (b) Contact
    (c) Profile
    (d) Marketing and Communications
    (a) Performance of a contract with you
    (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
    To enable you to partake in a prize draw, competition or complete a survey (a) Identity
    (b) Contact
    (c) Profile
    (d) Usage
    (e) Marketing and Communications
    (a) Performance of a contract with you
    (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
    To administer and protect our business, websites and applications (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
    (b) Contact
    (c) Technical
    (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
    (b) Necessary to comply with a legal obligation
    To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity
    (b) Contact
    (c) Profile
    (d) Usage
    (e) Marketing and Communications
    (f) Technical
    Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
    To use data analytics to improve our websites, applications, products/services, marketing, customer relationships and experiences (a) Technical
    (b) Usage
    Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
    To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity
    (b) Contact
    (c) Technical
    (d) Usage
    (e) Profile
    Necessary for our legitimate interests (to develop our products/services and grow our business)

    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 used our services 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 outside the Brave Bison group of companies for marketing purposes.

    Opting out

    You can ask us or third parties to stop sending you marketing messages at any time 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 our provision of services.

    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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

    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.

  5. Disclosures of your personal data

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

    • Internal Third Parties as set out in the Glossary under section 11.
    • External Third Parties as set out in the Glossary under section 11.
    • 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.

  6. International transfers

    We may share your personal data within the Brave Bison Group. This will involve transferring your data outside the European Economic Area (EEA).

    Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

    Whenever we transfer your personal data out of the EEA, we 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.

  7. Data security

    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.

  8. Data retention

    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.

    Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

    In some circumstances you can ask us to delete your data: see section 9 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.

  9. 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.

    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.

  10. Cookies

    Our websites and applications use cookies to distinguish you from other users. This helps us to provide you with a good experience when you browse our websites or applications and also allows us to improve our services. By continuing to browse, you are agreeing to our use of cookies.

    A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is downloaded to your computer’s hard drive.

    We use strictly necessary cookies. These are cookies that are required for the operation of our websites and applications. They include, for example, cookies that enable you to log into secure areas of our websites or applications or use or make use of e-billing services.

    Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

    You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our websites or applications.

    We may revise and update this Cookies Policy at any time. Please periodically review the Cookies Policy, as your continued use of our sites indicates your agreement with any changes that we make.

  11. Glossary

    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

    Internal Third Parties

    Other companies in the Brave Bison Group who are based in UK and Singapore.

    External Third Parties

    • Service providers acting as processors based in UK, Republic of Ireland, Singapore and USA who provide IT and system administration services and online media services.
    • Professional advisers including lawyers, bankers, auditors and insurers based in UK, Singapore and USA who provide consultancy, banking, legal, insurance and accounting services.
    • HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.

1 October 2019

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how we collect and process your personal data through your use of our Sites and Services, including any data you may provide through this Site.

The Sites are not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

CONTROLLER

The Hook Group Limited is the 'controller' of your personal data and responsible for your personal data.

CONTACT DETAILS

Our full contact details are here:

Full name of legal entity: The Hook Group Limited

Email address: [email protected]

Postal address: 20 Farringdon Street, EC4A 4EN

If you have any questions about this privacy notice or our practices and procedures in relation to your personal data, or if you want to exercise your legal rights, please contact us using the details set out above. We would appreciate the chance to deal with any concerns you might have but 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).

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on 10th January 2020.

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.

THIRD-PARTY LINKS

The Sites may include links to third-party websites, 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 these third-party websites and are not responsible for their privacy notices or statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

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 (i.e. anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, last name, username, social media handle or similar identifier or title.
  • Contact Data includes billing address (if applicable), email address and telephone numbers. This may include a photo of you.
  • 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 the Sites.
  • Profile Data includes any ID you provide to us, your username and password, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our Sites, 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 page or 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.

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 products 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.

3. HOW IS YOUR PERSONAL DATA COLLECTED

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

  • Direct interactions. You may give us your Identity and Contact Data through our website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • enquire about our services;
    • create a log in on our website;
    • subscribe to our service or publications or join our daily roundup of news;
    • request marketing to be sent to you;
    • enter a survey; or
    • give us some feedback.
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your device, browsing actions and patterns. We may collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. 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 including marketing services providers and partner organisations and public sources.

4. HOW WE USE YOUR PERSONAL DATA

We use your personal data for the following purposes:

  • Journalism (click here)
  • We collect and maintain personal data for journalistic purposes. For example, we may collect and publish personal data on individuals who form the subject matter of any news articles that appear on our entertainment channels.
    The personal data may include your name and any other information relevant to the article. Please be aware that where we process personal data for the purposes of journalism, this may be subject to a series of exemptions from requirements under data protection (e.g. you may not have the same legal rights where we are processing your personal data for journalistic purposes).
  • Use of our Sites (click here)
  • We collect and maintain personal data that you submit to us during your use of our Sites in the following ways:

    • Registering and accessing your login account
      Our Sites and Services provided through our Sites may enable or require you to register an account with us in order to comment on articles, primarily to ensure that you are a 'real' person and not a robot. We will ask all registrants to complete the registration form, providing a username, email address and password or to log in using your Facebook, Google or Twitter account.
      We will use your personal data in order to process your application for an account. Once you are registered, we will process your username and password to identify you when you login to your account and the secure areas of our Sites. We will also process your login information so that we can administer your account.
      Our legal basis for processing
      It is necessary for us to use your personal data in our legitimate interest to ensure that the comments at the bottom of our articles are genuine.
    • Your contributions to our Site and content that you post
      If you write an article or blog for us or contribute in any other way to publications we send to our members and/or publish on our Site, we may use your personal data (such as your name and the name of your organisation) to credit you for your contribution. If you provide photographs or other images in support of your article or blog, we may publish one or more of those images alongside your article or blog.
      Our legal basis for processing
      Where we use your content in connection with Services that we provide via our Sites, it is in our legitimate interest to use any personal data that you provide to us to ensure that we provide the relevant Service in an effective way.
    • Linking to social media sites and interacting with our social media pages (click here)
      If you click on one of the social media links on our Sites or otherwise interact with our social media pages such as on Facebook or Instagram (including interacting with any 'like' or similar embedded features on our Sites or social media accounts) we and the relevant social media platform may receive information relating to such interaction and may share your personal data in connection with this purpose. For more information about how we use this personal data, please see the Insight and Analysis section below.
      Please note that we are a joint controller with the relevant social media platform in respect of the personal data we use which is collected via your use of our social media pages. Your personal data may be used by the relevant social media platform for additional purposes. For details of how the relevant social media platform uses your personal data, please see the privacy policy of the relevant social media platform.
      Our legal basis for processing
      It is in our legitimate interest or a third party's legitimate interest to use personal data in such a way to ensure that we provide the Site and our Services in an effective way and to promote our Site and our Services via social media.
  • Customer service and general enquiries (click here)
  • Our Sites feature a "Contact" page which invites you to submit general enquiries about our Sites and our Services by email, telephone or via a message box.
    You may also be able to submit specific enquiries on other pages of our Sites in relation to particular Services offered via those pages.
    When you make an enquiry, we will collect and process your name, contact information (including email address and/or telephone number) and any other personal data that is relevant to your enquiry. We use this information to manage and respond to your enquiry.
    Our legal basis for processing
    It is in our legitimate interest to use your personal data in the ways described above to ensure that we are able to help you with your enquiry and provide a good standard of service to you.

  • Hosting and managing events (click here)
  • From time to time, we may organise and host events for the purpose of raising the profile of The Hook. We may process your name and contact information (including email address, postal address and telephone number) to communicate with you about such events where you have specifically requested information about such events or where we have another lawful basis for sending that information to you.
    If you attend one of our events, we may use your personal data to record your attendance at the event and for related record-keeping purposes and, if relevant, we may collect and process any dietary requirements you may have. You may also feature in photographs taken at our events and such photographs may appear in publications that we make available.
    Our legal basis for processing
    It is necessary for us to use your personal data in this way to perform our obligations in accordance with any contract that we may have with you where you have signed up to attend an event, or it is in our legitimate interest or a third party's legitimate interest to use personal data in such a way to ensure that the event is operated in an effective way.
    We may specifically ask your permission to use your photographs, quotes, testimonials, or other content that you make available or publish at the event. Where this is the case, our processing of such personal data will be based on consent.

  • Surveys and feedback (click here)
  • From time to time, we will invite you to provide feedback about us, our Sites or our Services in the form of online surveys. We will collect and process your name and contact details (including email address, postal address and telephone number, as applicable) and any other personal data you choose to volunteer in your survey response or other feedback.
    We use this information to help us to monitor and improve our Sites and our Services and to train our personnel.
    Our legal basis for processing
    It is in our legitimate interest to use the personal data provided by you so that we can improve our Services and provide them in an effective way.

  • Insight and analysis (click here)
  • We analyse your contact details with other personal data that we observe about you from your interactions with our Sites and/or with our Services.
    Where you have given your consent (where lawfully required), we use cookies, log files and other technologies to collect personal data from the computer hardware and software you use to access the Sites, or from your mobile device. This includes the following:

    • an IP address to monitor Site traffic and volume;
    • a session ID to track usage statistics on our Sites; and
    • information regarding your personal or professional interests, demographics, experiences with our Services and contact preferences.

     
    Our Sites contain cookies, web beacons, pixel tags and other similar technologies ("Tags"). Tags allow us to count users who have visited a web page and collect other types of aggregated information.
    Please see our Cookie Policy for further information.
    This information is used to create insights about our visitors' browsing habits on our Sites. Where we have your consent to do so, we will also use your location data for insight and analysis purposes.
    By using this information, we are able to measure the effectiveness of our content and how visitors use our Sites and Services. This allows us to learn what pages of our Sites are most attractive to our visitors, which parts of our Sites are the most interesting and what kind of features and functionalities our visitors like to see.
    We also use this information to help us with the selection of future product and service lines, website design and to remember your preferences.
    We also use this information for marketing purposes (see the "Marketing activities" section below for further details).
    Our legal basis for processing
    Where your data that we process is anonymised, we do not require a legal basis to use it as the information does not constitute personal data. However, our collection and use of such anonymised personal data may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.
    Where your personal data is not in an anonymous form, it is in our legitimate interest to use your personal data in such a way to ensure that our Sites and our Services are provided in an effective way.
    Where we use Tags to obtain your personal data, we shall rely on your consent.
    We will only use your location data for insight and analysis purposes where we have your consent to do so.

  • Marketing activities (click here)
  • We carry out the following marketing activities using your personal data:

    • Email and SMS/MMS marketing
      We use your name and email address to send you (or the organisation you represent) marketing communications by email. We use your mobile telephone number to send you marketing communications by SMS/MMS or send you push notifications. Our email and SMS/MMS marketing communications will include daily news, as well as general information about our organisation, our Sites, and the Services we provide.
      Our legal basis for processing
      We will only send you marketing communications by email where you have consented to receive such communications, or where we have another lawful right to send such communications to you.
    • Social media remarketing
      We use information that we observe about you from your interactions with our Sites and/or with our Services to provide you with personalised advertising on social media channels, including those operated by Facebook (including Instagram), Twitter and/or Google.
      We do this by securely providing your personal data to the relevant social media platform so that they can identify whether you are registered with their service and, if so, provide the personalised advertising to you.
      Such activity is also subject to the privacy choices you have elected to make on such services.
      Please see the "Insight and Analysis" section above for more details about the personal data collected and how it is collected.
      Our legal basis for processing
      Where data that we process is anonymised, we do not require a legal basis to use it as the information does not constitute personal data. However, our collection and use of such anonymised personal data may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.
      Where your personal data is not in an anonymous form, we will only engage in social media remarketing where you have consented to us using your email address and sharing your email address in an encrypted format with Facebook (including Instagram), Snapchat and/or Google respectively for marketing purposes.
  • Recruitment (click here)
  • We use your personal data for recruitment purposes, in particular, to assess your suitability for any of our positions that you apply for, whether such application has been received by us online, by email or by hard copy and whether submitted directly by you or by a third party recruitment agency on your behalf. We also use your personal data to communicate with you about the recruitment process, to keep records about our recruitment process and to comply with our legal and regulatory obligations in relation to recruitment.
    We will process any personal data about you that you volunteer, including during any interview, when you apply for a position with us. We may also process your personal data obtained from any third parties we work with in relation to our recruitment activities, including without limitation, recruitment agencies, background check providers, credit reference agencies and your referees.
    The personal data we process may include your name and contact information (including your email address, postal address and telephone number), details of your education, qualifications and employment history, any other personal data which appears in your curriculum vitae or application, any personal data that you volunteer during an interview or your interactions with us, or any personal data which is contained in any reference about you that we receive. Such information may also include special categories of personal data (such as information about your health, any medical conditions and your health and sickness records) and information relating to criminal convictions and offences if that information is relevant to the role you are applying for.
    We also use your personal data for the purposes of reviewing our equal opportunity profile in accordance with applicable legislation. We do not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability or any other basis covered by local legislation. All employment-related decisions are made entirely on merit.
    Our legal basis for processing
    Where we use your personal data in connection with recruitment, it will be in connection with us taking steps at your request to enter into a contract we may have with you or it is in our legitimate interest to use personal data in such a way to ensure that we can make the best recruitment decisions.
    We will not process any special (or sensitive) categories of personal data or personal data relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.

  • Fulfilment of our social marketing services (click here)
  • If you have engaged us to provide you with social marketing services, we may collect and process your personal data whether you are interacting with us on your own behalf or on behalf of any organisation you represent.
    The personal data we process may include your name, job title and contact information (such as email address, postal address and telephone number) and your payment information (where applicable). We process this information so that we can fulfil the supply of social marketing services and maintain our user databases.
    Our legal basis for processing
    It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you, or it is in our legitimate interest or a third party's legitimate interest to use personal data in such a way to ensure that we provide the our services in an effective, safe and efficient way.

  • Receipt of services from suppliers (click here)
  • If we have engaged you or the organisation you represent to provide us with products or services (for example, if you or the organisation you represent provide us with services such as IT support or financial advice), we will collect and process your personal data in order to manage our relationship with you or the organisation you represent, to receive products and services from you or the organisation you represent and, where relevant, to provide our Services to others.
    The personal data we collect from you may include your name, job title, contact information (including email address, telephone number and postal address), bank account or other payment details and any other personal data you volunteer which is relevant to our relationship with you or the organisation you represent.
    Our legal basis for processing
    It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you or it is in our legitimate interest to use personal data in such a way to ensure that we have an effective working relationship with you or the organisation you represent and are able to receive the services that you or your organisation provides, and provide our Services to others, in an effective way.

  • Business administration and legal compliance (click here)
  • We use your personal data for the following business administration and legal compliance purposes:

    • to comply with our legal obligations;
    • to enforce our legal rights;
    • to protect the rights of third parties; and
    • in connection with a business transition such as a merger, reorganisation, acquisition by another company, or sale of all or a portion of our assets.

     
    Our legal basis for processing
    Where we use your personal data in connection with a business transition, to enforce our legal rights or to protect the rights of third parties, it is in our legitimate interest to do so. For all other purposes described in this section, we have a legal obligation to use your personal data to comply with any legal obligations imposed upon us such as a court order.
    We will not process any special (or sensitive) categories of personal data or personal data relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.

  • Any other purposes for which we wish to use your personal data that are not listed above, or any other changes we propose to make to the existing purposes, will be notified to you using the contact details we hold for you.
  • 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 you would like an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.

    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.

5. DISCLOSURES OF YOUR PERSONAL DATA

We will only share personal data with others when we are legally permitted to do so. When we share personal data with others, we put contractual arrangements and security mechanisms in place to protect the personal data shared and to comply with our data protection, confidentiality and security standards and obligations.

When processing your personal data, we may need to share it with third parties as follows:

Third-party organisations that provide applications/functionality, data processing or IT services: We share personal data with third parties who support us in providing our Services and help provide, run and manage our internal IT systems. Such third parties may include, for example, providers of information technology, cloud-based software as a service providers, identity management, website hosting and management, data analysis, data back-up, security and storage services. We use third party plug-ins, such as Spot.IM on our Sites, when you register to post a comment. The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal data may be stored in any one of them. We also share your personal data with third-party service providers to assist us with insight analytics. These providers are described in our Cookie Policy.

Payment providers and banks: We share personal data with third parties who assist us with the processing of payments.

Event partners and suppliers: When we run events, we will share your personal data with third-party services providers that are assisting us with the operation and administration of that event. If we are running an event in partnership with other organisations, we will share your personal data with such organisations for use in relation to the event.

Recruitment agencies and related organisations: We share personal data with external recruiters, third-party providers that undertake background checks on our behalf and other entities within our group of companies.

Auditors, lawyers, accountants and other professional advisers: We share personal data with professional services firms who advise and assist us in relation to the lawful and effective management of our organisation and in relation to any disputes we may become involved in.

Law enforcement or other government and regulatory agencies and bodies: We share personal data with law enforcement or other government and regulatory agencies or other third parties as required by, and in accordance with, applicable law or regulation.

Sharing with other third parties: Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, or to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.
This list is non-exhaustive and there may be circumstances where we need to share personal data with other third parties in order to operate our Sites and to provide our Services.

6. INTERNATIONAL TRANSFERS

To provide our goods and services to you we may need to transfer your data outside European Economic Area (EEA).

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

Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. DATA SECURITY

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.

8. DATA RETENTION

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 the section below on your rights for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you and so it is no longer 'personal data' within the meaning of applicable data protection legislation) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

You have the following rights in relation to the personal data we hold about you. Please note that these rights are subject to certain exemptions which may be applicable to any request you make.

Your right of access (click here)
If you ask us, we'll confirm whether we're processing your personal information and, subject to any applicable exemptions, provide you with a copy of that personal information (along with certain other details) within the timescales or extended timescales provided for by the GDPR for complex requests, or where applicable, provide you with an explanation as to why we will not be complying with your request. If you require additional copies, we may need to charge a reasonable fee.
Your right to rectification (click here)
If the personal information we hold about you is inaccurate or incomplete, you're entitled to have it rectified. If you are entitled to rectification and if we've shared your personal information with others, we'll let them know about the rectification where possible and where this would not involve disproportionate effort. If you ask us, where possible and lawful to do so, we'll also tell you who we've shared your personal information with so that you can contact them directly.
Your right to erasure (click here)
You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable because that was the legal basis on which we were processing your personal information). If you are entitled to erasure and if we've shared your personal information with others, we'll take reasonable steps to inform those others where possible and where this would not involve disproportionate effort. If you ask us, where it is possible and lawful for us to do so, we'll also tell you who we've shared your personal information with so that you can contact them directly.
Your right to restrict processing (click here)
You can ask us to 'block' or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or you object to us. If you are entitled to restriction and if we've shared your personal information with others, we'll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we'll also tell you who we've shared your personal information with so that you can contact them directly.
Your right to data portability (click here)
You have the right, in certain circumstances, to obtain personal information you've provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.
Your right to object (click here)
You can ask us to stop processing your personal information, and we will do so, if we are:

  • relying on our own or someone else's legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or
  • processing your personal information for direct marketing.
Your rights in relation to automated decision-making and profiling (click here)
You have the right not to be subject to a decision when it's based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us.
Your right to withdraw consent (click here)
If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.
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 or any other circumstances where lawfully entitled to do so.

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.