- 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 section describes what we do as a business and the context in which personal data is processed.
Our clients work across the asset management, securities services, investment and 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. We also offer our clients other online proprietary services. In order to provide these, we require limited personal information to grant access and monitor usage in accordance with fair usage policies (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.
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. The capacity in which we act in processing this data depends, on the solution we provide. 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 for the provision of the services). 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 via our client’s or via publisher cookie consent tools on their digital properties (see section 4.5 Advertising Planning and Buying 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 or our client (for whom we act as data processor) have a legal ground for doing so. We explain which legal ground we rely on in each case below, but in all cases, we rely on one of the four legal grounds below:
- 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. Please see below to find out more about legitimate Interests.
What are Legitimate Interests?
“Legitimate Interests” is a term used in the GDPR and is a legal ground upon which a business may process personal data, where that processing is necessary to pursue interests pursued by the business (data controller or by a third party) provided always that the fundamental rights and freedoms of the data subject in question 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. If you have any concerns about any processing, we carry out based on our “legitimate interests”, you have the right to object to that processing. For more information on your rights, please see “Your Rights” section below.
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 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 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 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 plan and buy media space using media intelligence so that relevant advertising can be delivered appropriately on behalf of our clients within the financial industry and education sectors in which they operate. The advertising we place therefore tends to be across online and offline publications as well as out of home and experiential media. We may use targeted advertising as an advertising tool and track visits to our clients’ and suppliers’ websites and particular online campaigns to measure the effectiveness of the advertising placed. The exact nature of the targeting and tracking of advertising will vary depending on the requirements of our clients’ campaigns but an overview is below.
- identifying and advertising on websites with audiences our clients’ wish to reach and dealing directly with publishers to establish a campaign;
- matching that cookie ID to a pool or segment which our client is trying to reach and serving advertising in real time to websites with corresponding advertising space for sale
- identifying a cookie ID that has previously visited a client site to serve relevant advertising based on their earlier activity on the client site.What is targeted advertising?
We are able to deliver relevant advertising on behalf of our clients by using cookies (or similar technology). Cookies are tiny text files that are stored on your browser (where you agree) when you visit our clients’ websites or websites of publishers or media owners relevant to our clients’ activities. The cookies we use do not collect your name or any similar information, but instead comprise a unique identifier called a cookie ID: a string of characters that websites and servers associate with the browser on which the cookie is stored.By associating the cookie ID with the browsing activity undertaken we are able to build a profile and place that information into a “pool” or “segment” within the data management platforms we use, enabling us to show you (or rather the browser associated with the cookie ID) advertisements of interest. Find out more about “profiling” below.
We can do this in a variety of ways, depending on our clients’ advertising strategy, but may include:
We use Google DoubleClick and Oracle BlueKai cookies and their data management platforms to deliver targeted advertising on behalf of our clients. Where we assemble cookie IDs as part of one of our solutions we act as a data controller. Where we collect cookie IDs to service a specific client’s instructions we do so as a data processor on behalf of our client, the data controller.
Just to reiterate that as part of this process, we do not obtain your name, contact details or any similar information. However, we are able to make inferences from your browsing activity and help our clients to plan their advertising based on this information. For example, if you browse on one of our clients’ websites, you may see an advert from them on another website. We do not profile or pool or segment any information based on or linked to “special category information” being data identifying racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic and or biometric data for the purpose of uniquely identifying an individual and data concerning an individual’s health, sex life or sexual orientation.
- What is “Profiling”?
Generally, profiling is an activity which automates some or all of the processing of personal data to evaluate certain features relating to an individual, such as behavior. Profiling, like other processing, can only be carried out where there is a legal ground to do so. We undertake profiling based on the cookie data we receive with consent to place targeted advertising on behalf of our clients as described in this policy.
We also advise on and conduct social media campaigns (e.g. LinkedIn, Facebook, Twitter) on behalf of our clients. This may involve us specifying the type of user we want to see our client’s advertising which the social media platform then matches with its database and permissions or using cookies within that platform. Although we are provided with information regarding the success of such a campaign, this is only provided to us in an aggregated format, and no individual can be identified. We may also seek to make contact through social media on behalf of our clients (e.g. by Inmail via LinkedIn.) However, we shall only do so where our client has an appropriate legal ground to do so. We do not seek to obtain any personal data from you as part of our use of social media for our advertising activities undertaken on behalf of our clients.
- Why do we do this?
Our clients (and we as their agency working on their behalf) are seeking to understand what products and campaigns interest you, and to measure the effectiveness of various marketing strategies. By understanding your interests, we can work with our clients to promote relevant products (and avoid advertising products that may not be suited to you). From your browsing activity we may be able to avoid promoting products which, by their regulated nature, may not be available to you and therefore helps our clients serve advertising compliantly. As set out above, please alter your browser settings or do not accept advertising cookies if you would prefer for your data to not be used in this way.
We conduct primary research and proprietary research analysis in the financial and business education sectors amongst, for example, financial services professionals, (investors and advisors) together with educational specialists, prospective students, students and alumni, allowing us to support and advise our clients effectively with their media planning and buying needs. The personal data we use to undertake our research is sourced directly or via third parties from publicly available sources, including business directories and websites and comprises: name, business name, business address, email, business telephone number, job title, age and languages spoken. We also make contact via business-led platforms such as LinkedIn. We have a legitimate interest in undertaking primary research as part of our work as a media agency, providing media insights and intelligence to our clients and in processing this data for these purposes.
We undertake our research through surveys and polls. Once an individual has participated in our research, we hold their responses (including any comments or opinions on relevant market information), together with additional details where relevant (such as the type of assets under management, business size/number of clients and whether any incentive has been received to participate). All responses are held only with the consent of the respondent, and used in an anonymous, aggregated format. From time to time as part of our service offering, we may pass our research findings to our clients, but we only ever do so in a fully anonymised and aggregate way where ensuring that no personal data is disclosed.
When we seek to recruit participants, we provide the opportunity to decline participation and/or to be contacted again for these purposes (where we hold minimal details for suppression purposes). You also have the right to object to our processing of your data for these purposes. We do not ask for any special category (sensitive) personal data (e.g. data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic and or biometric data for the purpose of uniquely identifying an individual and data concerning an individual’s health, sex life or sexual orientation) to be submitted as part of any response; nonetheless we ask for explicit consent to enable us to retain responses for our market research purposes.
We hold the personal data we use for these purposes securely. We work with third parties, such as Qualtrics LLC, who assist us with contacting respondents and storing the resulting data. Qualtrics is required to hold this data securely in their data center in the EEA. We also work with panel providers who distribute our surveys to their panelists based on their data and permissions (which is not shared with us). We ask all panel providers to confirm that the personal data they use for these purposes is compliant with all applicable data protection and privacy legislation. We may pass your contact information on to an incentive provider (as set out in our email to you), but only where you agree to take part in the research in question and only for the purpose of providing the incentive in question.
Where we undertake market research specifically for a client using client data, we act as a data processor and process that data in compliance with the requirements of the client data controller.
- 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, or 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.
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 Media Group, suppliers or service providers 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.
If you are a Californian resident, you may request that we disclose or delete the personal data we hold about you (where we do so in our capacity as a “Business” as that term is described in the CCPA). In particular, you may request that we
- disclose to you the following information covering the 12 months preceding your request:
- the categories and specific pieces of personal information we collected about you and the categories of personal information we sold (if any);
- the categories of sources from which we collected such personal information
- the categories of third parties to whom we sold or otherwise disclosed personal information.
- delete personal information we collected from you; or
- opt-out of any future sale of personal information about you. NB. We do not sell your personal data.
If you're not satisfied with the way any complaint you make in relation to your personal information is handled by us, then you may be able to refer your complaint to the relevant data protection regulator. In the UK, this is the Information Commissioner's Office, see www.ico.org.uk.
By Email: [email protected]
The Privacy Manager
Fundamental Media Limited
31-41 Worship Street