- ABOUT US
- THIS POLICY
- WHAT WE DO?
- YOUR INFORMATION
- SHARING YOUR INFORMATION
- STORING YOUR INFORMATION
- YOUR PRIVACY RIGHTS
- CONTACT US
This Policy applies to the personal data we process as part of our business. Whilst our group of companies will deal with your data in accordance with this Policy, it doesn’t apply to any other companies or organisations that we work with and you are therefore encouraged to check other privacy policies as they may apply to you. This Policy was last updated on 23rd of May 2018.
Other privacy policies apply to certain services we provide (e.g. Fundamental Monitor). Please read these when you register or subscribe for these services.
We may need to make changes to this Policy from time to time, where we do so we will highlight these changes here. This Policy was last updated on 23rd of May 2018.
Our clients work across the asset management, securities services, investment & corporate banking, reinsurance and private banking sectors within the finance industry and separately within high-profile education institutions promoting undergraduate, postgraduate and professional qualifications. The nature of the products and services we provide to our clients drives the nature of the personal data we process.
We provide our clients with media planning and buying services and media intelligence, this includes undertaking market research, event analysis, campaign data analytics and the procurement and placement of advertising on publisher and other websites and via various media platforms.
Our clients may also wish to register for other of our services, which may involve clients and their employees providing us with limited personal information so that we may grant a licence and access to use the same and monitor usage in accordance with any applicable fair usage policy (e.g. Fundamental Monitor).
We also use personal information in the day to day operation of our business, in order to maintain contact with our clients and potential clients as well as for administration, recruitment and employment purposes.
We collect and use information about you when you enquire about Fundamental Media and/or our services and request information from us, to provide you with the services you have registered for and, with your consent, to contact you about other of our products and services which may be of interest to you. We also collect and use the information you provide where you participate in our market research, respond to our surveys or otherwise provide feedback to us.
This information may include data like your name, postal address, telephone number, email address and, in relation to our surveys or market research, your views and opinions. We may also ask you to provide other data relevant to your query or service to be provided, such as your location, industry and preferred method of being contacted.
Separately we use information collected from websites you visit belonging to our clients and/or particular publishers or media owners via cookie or similar technology. This enables us, as a media agency, to advise our clients on the advertising of their products and service, including the placing and tracking of online advertising. This data is generated and used by us in an aggregated and anonymized form. We also collect or use information from other organisations who provide aggregated information. We do not pass or share this information with any third parties (other than our data management platform providers), and only pass anonymized aggregated data back to our clients for the above purposes. If you do not wish not to share information about your browsing activity, you can choose not to accept a cookie or other cookie-like technology on your device (see our section on Advertising Planning and Buying below for more information).
Please see below for more detail on how we use your personal data in each of the above areas, as well as in the day to day to day operation of our business, in maintaining contact with our clients and suppliers, as well as for administration, recruitment and employment purposes.
We are only able to process your personal data where we have a legal ground for doing so. Please also see below for more information about the legal grounds we have to process your data.
We generally process your data based on one of four legal grounds set out below. We explain which legal ground we rely on, which describes how we use personal data.
- It being necessary in order to perform or take steps to perform a contract with you or your employer;
- It being processed with your consent;
- It being processed to comply with our legal obligations or
- It being processed where we have a legitimate interest in doing so.
“Legitimate Interests” means the interests of our business in conducting and managing our business. However, we only rely on this legal ground to process your personal data where your fundamental rights and freedoms are not overridden as a result. Therefore, where we rely on this ground we make sure to consider and balance any potential impact on you and your rights. In particular, but amongst other factors, we have in each case considered the purpose of the processing, the extent to which it is necessary against the likely impact upon you (including any safeguards we’ve been able to put in place). We describe in this Policy (at section 4) where we rely on this legal ground to process your personal data.
Please contact us if you wish to understand more about the assessment we have undertaken in a particular case. If you have any concerns about the processing below, you have the right to object to processing that is based on our legitimate interests. For more information on your rights, please see “Your Rights” section below.
We conduct specific media consulting projects for our clients from time to time which cause us to act as a data processor of your personal data. Where we do so, we only process your personal information in accordance with our client’s lawful written instructions and where our clients confirm that they have an appropriate legal basis to undertake the project in question.
In the event that you work for one of our clients, or suppliers, we may also process your employee business contact details (name, business email, job title, business telephone number) so that we may provide our services, undertake day to day management and administration of our clients’ and suppliers’ accounts with regard to the work undertaken, in each case as is necessary to perform our contractual obligations. We process this in the form of emails, client files, invoicing and account records which are securely hosted in the EEA (UK). In addition, we retain the same business contact details so as to maintain our business relationship with you, our clients and suppliers and potential clients and suppliers. This data is securely held in our CRM database in the EEA (UK). In each case we have a legitimate interest in processing your personal data for these purposes.
As part of our work for our clients under or in connection with our agreement and/or services we provide, we approach, negotiate and instruct media owners, publishers, creative agencies or other suppliers as part of the planning, negotiation and appointment process. During this process it may be necessary for us to share your business contact data (where you work for one of our clients) with such providers which, depending on the account in question, may be located outside of the EEA.
We may share your personal information with:
- our suppliers, as described above, under contract where it is necessary for their provision of services to us and/or to provide our services to you;
- prospective partners or professional advisors in the event of any business reorganization, merger, sale, joint venture or similar, under strict confidentiality obligations;
- third parties where it is (or we reasonably believe, it is) necessary for legal or regulatory purposes, or we are under a duty to disclose your personal information to comply with a legal obligation or process or to enforce or apply our terms and conditions, other agreement or protect the rights or safety of clients, employees, or others. This includes exchanging information with other companies, governmental departments and organisations for fraud protection and credit risk reduction; and
- our clients or media partners (but only in an aggregated non-personally identifiable form) where we provide research, data analytics, or advertising placement.
We only transfer personal data to countries outside the European Economic Area (EEA) where appropriate legal safeguards are in place or where we have consent to do so.
Your personal data is protected by strict security measures and we require that any suppliers who process your personal data on pour behalf do the same. We only keep your personal data for certain amounts of time depending on individual circumstances.
Storing, Securing and Retaining your personal data
We employ appropriate security measures to protect your personal information from unauthorised access, accidental loss, disclosure and destruction. We require that our suppliers and service providers also use appropriate security measures when processing your personal information on our behalf and that they only do so in ways and for the purposes we’ve agreed; not for their own uses. We reserve the right to check their security measures and processing activities.
We may need to transfer your personal information to other companies within the Fundamental Group, suppliers or service provides based outside of the UK and outside of the EEA. We will only do this where we need to do this, for example where our servers or service providers are based outside of this area and where appropriate safeguards are in place to protect your data or we have your consent to do so. A transfer outside of the EEA will also occur if you access any of our online applications, such as Fundamental Monitor, from outside of the EEA. Personal Data is shared within the Fundamental Group of companies under the EC Model Clauses.
Unless we explain otherwise to you, we’ll hold your personal information based on the following criteria:
- for as long as we provide our services to you and then for as long as someone could bring a claim against us related to those services; and/or
- for as long as we have reasonable business needs to do so, such as providing our services to our clients, maintaining our relationships with our clients and potential clients, for as long as our research projects remain live and their results relevant, and a period thereafter in which we may need to validate the findings and for managing our business operations; and/or
- in line with legal and regulatory requirements or guidance.