privacy
Privacy Policy
Introduction
This is the Privacy Policy outlines for Western Providence Media Group Ltd ("we", "our" or "the Company") practices with respect to information collected from users who access our website www.westernprovidence.com ("Site") or otherwise share personal information with us (collectively: "Users"). The Privacy Policy describes who we are, how we obtain and use your personal data and your rights. Please read it carefully.
About Us
We are Western Providence Media Group Ltd, a private limited company incorporated in (and subject to the laws of) England and Wales with registration number 10803503. Our registered office is 71-75 Shelton street. Covent Garden, London, England, WC2H 9JQ.
We take your privacy seriously and use your personal data as further explained in this Privacy Policy. We are the “controller” of the personal data you provide to us.
What information do we collect?
We collect two types of data and information from Users.
The first type of information is unidentified and non-identifiable information pertaining to a User(s), which may be made available or gathered via your use of the Site (“Non-personal Information”). We are not aware of the identity of a User from which the Non-personal Information was collected. Non-personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time, etc.) in order to enhance the functionality of our Site. We may also collect information on your activity on the Site (e.g. pages viewed, online browsing, clicks, actions, etc.).
The second type of information Personal Information, which is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual. Such information includes:
• Device Information: We collect Personal Information from your device. Such information includes geolocation data, IP address, unique identifiers (e.g. MAC address and UUID) and other information which relates to your activity through the Site.
• Registration information: When you register with our Site you may be asked to provide us certain details such as: full name; email or physical address, and other information.
• Identity and Contact Data: includes first name, last name, email address, username or similar identifier we collect when you create an account with us, give feedback or leave a review.
• Marketing and Communications Data: includes your preferences in receiving marketing from us and any third parties and your communication preferences. Where you have given consent, we use your personal data to contact you about how we can help you find products and services.
• Technical Data: may include internet protocol (IP) address, your login data and any technology on the devices you use to access the website and/or app.
• Profile Data: may include username and password, feedback responses.
• Usage Data: may include information about how you use our website, products and services.
• Correspondence: We collect any additional personal data that you may provide to us from time to time if you contact us by email, letter or telephone, through our website, or by any other means. If you contact us by telephone, we may make notes in relation to your call for training and service improvement purposes, to comply with our legal obligations and to be able to deal with any dispute or defence of a claim which may arise in the course of us providing our products and services to you. We will store the data in line with our retention policy.
User Rights
You may request to:
1. Right to be informed - Receive confirmation as to whether or not personal information concerning you is being processed and access your stored personal information, together with supplementary information.
2. Right of access Receive a copy of personal information you directly volunteer to us in a structured, commonly used and machine-readable format.
3. Right to rectification Request rectification of your personal information that is in our control. You are entitled to have your personal data corrected if it is inaccurate or incomplete.
4. Right to erasure Request erasure of your personal information. This is not a general right to erasure; there are exceptions.
5. Right to object to processing Object to the processing of personal information by us. You have the right to object to us processing your personal data for our legitimate business interests or for direct marketing purposes (including in each case any related profiling).
6. Right to data portability Request to restrict processing of your personal information by us.
7. Lodge a complaint with the supervisory authority, the ICO.
However, please note that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements.
If you wish to exercise any of the above rights or receive more information, please contact us through email -
info@westernprovidence.com
Retention
We will retain your personal information for as long as necessary to provide our services, and as necessary to comply with our legal obligations, resolve disputes and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable opportunity. Under applicable regulations, we will keep records containing client personal data, account opening documents, communications and anything else as required by applicable laws and regulations.
We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion. We securely erase your personal data from our systems when it is no longer needed.
How do we receive information about you?
We receive your Personal Information from various sources:
• When you voluntarily provide us with your personal details in order to register on our Site;
• When you use or access our Site in connection with your use of our services;
• From third-party providers, services and public registers (for example, traffic analytics vendors).
How is the information used? With whom do we share the information?
We do not rent, sell or share Users’ information with third parties, except as described in this Privacy Policy.
We may use the information for the following:
• To contact you in response to a request for information
• For Direct Marketing (including by third parties) where you have provided your consent or we otherwise have the right to do so, we may use your contact details to sent you direct marketing and keep you informed of products, services and offers by email, post, telephone or SMS. You can unsubscribe from direct marketing at any time by clicking the “Unsubscribe” link in our emails or by contacting us (see below).
• We may work with trusted business partners who would also like to use your name, email address, postal address and telephone number to inform you of similar products, services and promotional offers. We will only share your personal data with our partners where you have provided us with your consent to do so. You can unsubscribe at any time by clicking the “Unsubscribe” link in any of their emails.
• To conduct automated decision-making and profiling We may use technology to track your use of our website, products and services to help us build a profile of your preferences. What this means for you is that you are more likely to receive direct marketing and promotional offers that are tailored to your specific preferences, based on your previous activity. If you don’t agree with an automated decision that our technology has made in relation to you, you can contact us.
• To maintain our records and improve data accuracy we may process personal data in the course of maintaining and administering our internal records. This includes processing your personal data to ensure that the information we hold about you is kept up to date and accurate.
• To respond to enquiries, complaints and disputes we may use the personal data we hold about you to help us respond to enquiries you have made, or deal with any dispute which may arise in the course of us providing our products and services to you, in the most effective manner.
• Communicating with you – sending you notices regarding our services, providing you with technical information and responding to any customer service issue you may have; To communicate with you and to keep you informed about our latest updates and services;
• To serve you advertisements when you use our Site (see more under "Advertisements");
• To market our websites and products (see more under "Marketing");
• For statistical and analytical purposes, intended to improve the Site.
In addition to the purposes listed in this Privacy Policy, we may share Personal Information with our trusted third-party providers, who may be located in different jurisdictions across the world, for any of the following purposes:
We may also disclose information if we have good reason to believe that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies (including our Agreement), including investigations of potential violations thereof; (iii) investigate, detect, prevent or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our users, yourself or any third party; or (vi) for the purpose of collaborating with law enforcement agencies and/or in case we find it necessary in order to enforce intellectual property or other legal rights; (vii) We also have a duty under section 330 of the Proceeds of Crime Act 2002 to report to the Serious Organised Crime Agency (SOCA) if we know, or have reasonable cause to suspect, that you or anyone connected with your business are or have been involved in money laundering. Failure on our part to make a report where we have knowledge, or reasonable grounds for suspicion, would constitute a criminal offence
Grounds for data collection
Processing of your personal information is necessary for the performance of our contractual obligations towards you and providing you with our services, to protect our legitimate interests and for compliance with legal and financial regulatory obligations to which we are subject.
When you use the Site, you consent to the collection, storage, use, disclosure and other uses of your Personal Information as described in this Privacy Policy.
We encourage our Users to carefully read the Privacy Policy and use it to make informed decisions.
Legal Reasons for Processing
Data protection law requires us to only process your personal data if we satisfy one or more legal reasons. We rely on a number of different reasons for the processing we undertake. These include:
Consent
In certain circumstances, we process your personal data after obtaining your consent to do so for the purposes of:
• sending marketing communications to you about our products and services;
• sharing your name, email address, postal address and telephone number with our trusted business partners so that they may market to you about their own similar products and services;
Necessary for the performance of a contract to comply with our legal obligations
It maybe necessary for us to process your contact details in order to set up your account and for the performance of any contract between us which may include when we communicate with you about major changes to the terms of this Privacy Policy or to any related or similar information.
Necessary for the purposes of our legitimate business interests
It is sometimes necessary to collect and use your personal data for the purposes of our legitimate interests as a business, in order to:
• respond to any enquiries or complaints you have made, or deal with any dispute which may arise in the course of us providing our products and services to you; and
• Carry out marketing activities when we have carefully considered the law and the impact the collection and use of personal data could potentially have on individuals’ rights.
• train our staff so that we provide a better service;
• better understand our customer base so we can improve products and services and marketing activities (which could also benefit you);
• develop and improve our website to enhance the experience;
Where we wish to rely on Legitimate Interests for processing, we are required by data protection law to consider whether our legitimate interests are overridden by your interests or your fundamental rights and freedoms. We may continue to process your personal data on the basis of our legitimate interests only if we determine that your interests, rights and freedoms are not overridden by our legitimate interests. We have considered these matters and on balance, we consider that the benefits described above are not outweighed by your interests or your fundamental rights and freedoms.
Where we think there is a risk that one of your interests or fundamental rights and freedoms may be affected we will not process your personal data unless there is another legal ground for us to do so (either that we have obtained your consent to the processing or it is necessary for us to perform our contract with you or to comply with our legal obligations).
Who we share your data with
We may share your personal data to our suppliers who perform certain business services for us and act as processors of your personal data on your behalf.
Cookies
We and our trusted partners use cookies and other technologies in our related services, including when you visit our Site or access our services.
A "cookie" is a small piece of information that a website assigns to your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier. Cookies are also used to help make sure that the advertisements you see are relevant to you and your interests and to compile statistical data on your use of our Services.
The Site uses the following types of cookies:
a. 'session cookies' , which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed;
b. 'persistent cookies', which are read only by the Site, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next sign-in;
c. 'third-party cookies' , which are set by other online services who run content on the page you are viewing, for example by third-party analytics companies who monitor and analyse our web access.
Cookies do not contain any information that personally identifies you, but Personal Information that we store about you may be linked, by us, to the information stored in and obtained from cookies. You may remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our Site may not operate properly and your online experience may be limited.
We use a tool which is based on the Snowplow Analytics technology to collect information about your use of the Site. The tool collects information such as how often users access the Site, which pages they visit when they do so, etc. The tool does not collect any Personal Information and is only used by our Site hosting and operating service provider to improve the Site and services.
Use of script libraries (Google Web Fonts)
In order to present our contents correctly and make them graphically appealing across all browsers, we use script libraries and font libraries such as Google Web Fonts (https://www.google.com/webfonts) on this website. Google Web Fonts are transferred to your browser's cache to avoid multiple loading. If your browser does not support Google Web Fonts or does not allow access, content will be displayed in a default font.
• Calling script libraries or font libraries automatically triggers a connection to the library operator. In theory, it is possible – but currently also unclear whether and, if so, for what purposes – that operators of corresponding libraries collect data.
The privacy policy of the library operator Google can be found here: https://www.google.com/policies/privacy.
Third-party collection of information
Our policy only addresses the use and disclosure of information we collect from you. To the extent you disclose your information to other parties or sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them. Accordingly, we encourage you to read the terms and conditions and privacy policy of each third party that you choose to disclose information to.
This Privacy Policy does not apply to the practices of companies that we do not own or control, nor to individuals whom we do not employ or manage, including any of the third parties which we may disclose information to as set out in this Privacy Policy.
How do we safeguard your information?
We take great care in implementing and maintaining the security of the Site and your information. We employ industry standard procedures and policies to ensure the safety of the information we collect and retain, and prevent unauthorised use of any such information, and we require any third party to comply with similar security requirements, in accordance with this Privacy Policy. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorised access or abuse our Site, and we make no warranty, express, implied or otherwise, that we will prevent such access.
Transfer of data outside the EEA
Please note that some data recipients may be located outside the EEA. In such cases we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection.
Advertisements
We may use a third-party advertising technology to serve advertisements when you access the Site. This technology uses your information with regards to your use of the Services to serve advertisements to you (e.g., by placing third-party cookies on your web browser).
You may opt out of many third-party ad networks, including those operated by members of the Network Advertising Initiative ("NAI") and the Digital Advertising Alliance ("DAA"). For more information about this practice by NAI and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: http://optout.networkadvertising.org/#!/ and http://optout.aboutads.info/#!/.
Marketing
We may use your Personal Information such as your name, email address, telephone number, etc., ourselves or by using our third-party subcontractors, for the purpose of providing you with promotional materials concerning our services which we believe may interest you.
To respect your right to privacy, within such marketing materials we provide you with the means to opt out of receiving further marketing offers from us. If you unsubscribe, we will remove your email address or telephone number from our marketing distribution lists.
Please note that even if you have unsubscribed from receiving marketing emails from us, we may send you other types of important email communications without offering you the opportunity to opt out of receiving them. These may include customer service announcements or administrative notices.
Corporate transaction
We may share information in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, the transferee or acquiring company will assume the rights and obligations as described in this Privacy Policy.
Minors
We understand the importance of protecting children’s privacy, especially in an online environment. The Site is not designed for or directed at children. Under no circumstances shall we allow the use of our services by minors without prior consent or authorisation by a parent or legal guardian. We do not knowingly collect Personal Information from minors. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at info@westernprovidence.com.
Links to other websites
This privacy policy only applies to this website and doesn’t cover external & other websites, transactions or services that we are linked to; if you follow a link and go to another website from our website, please read the privacy policy on that website to find out what it does with your information. If you come to Western Providence Media Group from external websites, we may receive personal information about you from these external websites. You should read the privacy policies of these websites you came from to find out more about it.
Social Networking Links
On our website we use links to social networking sites - Facebook, Twitter, Youtube and LinkedIn. When you click on these links these sites are likely to be collecting information about your internet behaviour and website visiting patterns by setting off one or more of their own cookies. In some cases these external sites will be registering the fact that you are visiting the pages of Western Providence Media Group, even if you don't click on their links, you still find yourself logged into their services such as Google and Facebook. Western Providence Media Group is not responsible for the data generated by or processed by such third parties. Therefore, you should check the respective policies of each of these sites to see how exactly they use your information and to find out how to opt-out or request deletion of your information.
Updates or amendments to this Privacy Policy
We reserve the right to periodically amend or revise the Privacy Policy; material changes will be effective immediately upon the display of the revised Privacy policy. The last revision will be reflected in the "Last modified" section. Your continued use of the Platform, following the notification of such amendments on our website, constitutes your acknowledgment and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.
How to contact us
If you have any general questions about the Site or the information we collect about you and how we use it, you can contact us at info@westernprovidence.com
Western Providence Media Group Ltd
Building 3, 566 Chiswick high road
London
W4 5YA
Last Modified 01/05/2023