• ABOUT US
  • THIS POLICY
  • WHAT WE DO?
  • YOUR INFORMATION
  • SHARING YOUR INFORMATION
  • STORING YOUR INFORMATION
  • YOUR PRIVACY RIGHTS
  • CONTACT US
Fundamental Media Limited is a company registered in England and Wales and is the parent company within the Fundamental Group (“Fundamental Media”, “us” “we” or “our”). We operate as a specialist media agency providing our clients with media planning and buying expertise, together with media intelligence. Further detail about what we do is set out below. Our contact details are located in the “Contacting Us” section.

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.

We understand that the privacy and security of your personal information is extremely important. Therefore, this Privacy Policy (“the Policy”) explains how we use any personal data we collect about you, including via our website www.fundamentalmedia.com (and any other websites operated by our group of companies) (the “Website”) and in the course of the services we provide to our clients together with what we do to keep it secure. All personal data collected about you will be processed by us in accordance with this Policy and the applicable data protection legislation as is in force from time to time. “Personal data” (or “personal information” as the terms may be used interchangeably in this Policy) means information that identifies you as an individual or is capable of doing so.

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.

WHAT INFORMATION DO WE COLLECT

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.

We also collect and use information about your use of our Website using cookies and other similar technologies. We collect information about you for our internal business purposes, such as data analysis (e.g. to evaluate your recent visits to and interaction with our Website so that we can make it more intuitive, to understand your interests and ensure our services and communications are relevant to you). Our cookie policy explains how cookies work and the information we collect via our Website in more detail.

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 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.

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. We and our clients have a legitimate interest in advertising to you in this way. As set our above, please reject cookies or alter your browser settings if you would rather avoid seeing advertising which is based on your previous browsing history.
We advise our clients on data analytics and may implement recommended strategies so that our clients may learn more about the effectiveness of their campaigns. Analytics tools (e.g. Google Analytics) using cookie technology are able to identify the number of users, their location, number of previous visits and so on, but do not identify individuals. We use various tools, including Google Data Studio which pulls together data from social media, analytics tools (e.g. Google Analytics), Doubleclick and other sources such as MOAT (a tool which verifies advert visibility) to reflect and visualise that data. No personal data is used as part of this process. We have a legitimate interest in generating insights as part of our work as media agency providing media intelligence to our client and assisting with their compliance obligations where possible.
We conduct primary research and proprietary research analysis in the financial sector amongst, for example, financial services professional (including investors and advisors) as well as in the further education sector (including educations 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 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.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 with your consent, as the respondent, and used in an anonymous, aggregated format. When we recruit participants, we give you the opportunity to decline participation and/or ask not to be contacted for these purposes again. 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 your explicit consent to us retaining your responses for our market research purposes.We hold the personal data we use for these purposes securely. We do not share any personal data used in our research with any clients. We work with third parties, such as Qualtrics LLC, who assist us with contacting respondents and storing the resulting data. Qualtrics holds this data securely in their data centre located within 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.
We use the personal data you submit as part of your application for our recruitment purposes, specifically to review your application or CV. We may also collect additional personal data from you as the recruitment process progresses, including personal data which may be derived from an interview, test or presentation, for example. We may also process personal data about you where we undertake pre-employment screening and/or collect references or gather information from publicly available sources. In summary, our recruitment process may require that we process some or all of the following: Personal details such as name, address, date and place of birth; Work history/job data; previous employers, positions, dates, etc.; Compensation; basic salary, benefits, bonuses, etc.; Education and work history including professional qualifications and skills; Employer feedback / references to include regulated references where necessary; Nationality / visa / right to work permit information; (e.g. passport, driving licence, National Insurance numbers); Photographs and images from recorded assessments or from onsite CCTV; Results of Pre-employment screening checks (e.g. credit history, criminal records check where permitted under local law); Assessment results e.g. Psychometric assessment results, results from gamification and video or telephone assessment. We may collect this information in a variety of ways. As referred to above, your personal data is likely to be contained within application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment, including online tests. Please note that you are under no statutory or contractual obligation to provide data to us during the recruitment process. However, if you do not provide the information, we may be unable to process your application properly or at all. We may collect and share your personal data from and with third parties, such as referees, employment background check providers and information from criminal records checks (where applicable). We will seek information from such third parties only once a job offer to you has been made and we will inform you that we are doing so. Your personal data will be stored in our systems on servers in the UK, including on your application record, as part of HR systems and on other IT systems (including email). We only process your information as is necessary for the purposes of progressing your application or as required by law or regulatory requirements and where we have a legal ground to do so, including: Taking steps to administer your application at your request prior to a potential offer of employment. Processing your personal data to ensure we are complying with our legal obligations. For example, checking your eligibility to work in the UK before employment starts. We may also collect some sensitive personal data (e.g. disability information) in order to make reasonable adjustments to enable our candidates to apply for jobs and to ensure that we comply with regulatory obligations placed on us with regard to our hiring. Processing where we have legitimate interest in doing so, specifically in allowing us to manage and administer the recruitment process, assess and confirm your suitability for employment and decide to whom to offer a job. We may also need to process personal data from job applicants to respond to and defend against legal claims. Processing, where applicable, other special categories of data, such as information about ethnic origin, sexual orientation, health or religion or belief, for equal opportunities monitoring purposes. Processing, where applicable, information about criminal convictions and offences where relevant to the position in question. We do not make any recruitment processes or decisions based solely on any automated decision-making. As referred to above we may share your personal data with suppliers who undertake pre-employment screening (including credit checking agencies and criminal record checking bureaus), academic institutions in validating relevant academic qualifications and suppliers who provide candidate interview and/or assessment services to us (where applicable). Where a supplier processes your personal data on our behalf we contractually require that they process that data in full compliance with the law and solely in accordance with our instructions. If your application for employment is unsuccessful, we will hold your data on file for 6 months after the end of the relevant recruitment process. If your application for employment is successful, Personal Data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The periods for which your personal data will be held will be provided to you in an Employee Privacy Notice.
We process the personal data of our employees in connection with their employment with us. A full description of the types of personal data we hold, how it is used and who it is shared with is set out in our Employee Privacy Notice available to all employees as part of our Employee Handbook and as shared with all employees on induction and afterwards on a periodic basis.
SHARING YOUR INFORMATION We may share your personal data within the Fundamental Group or with third party suppliers or other third parties where we have reason for doing so as described in this Policy. Where third parties are appointed to process any of your data on our behalf they are appointed in writing under contract and required to process only in accordance with our written instructions, and not for their own purposes. We only transfer personal data outside of the EEA where appropriate legal safeguards are in place or we have consent to do so.
We may share your personal data within the Fundamental Group to provide our services to you, maintain our business relationship with our clients and/ potential clients and where you agree, so that our group companies may offer you their products and services. Our Group Data Protection Policy sets out the standards to which we as a business work and to which our employees are expected to adhere. It applies to companies and employees across the Fundamental Group so as to ensure consistency in our approach and it emphasises the legal requirement that, where we process Personal Data (for our own purposes or on behalf of clients), we do so lawfully, fairly and transparently.

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.
YOUR PRIVACY RIGHTS We may share your personal data within the Fundamental Group or with third party suppliers or other third parties where we have reason for doing so as described in this Policy. Where third parties are appointed to process any of your data on our behalf they are appointed in writing under contract and required to process only in accordance with our written instructions, and not for their own purposes. We only transfer personal data outside of the EEA where appropriate legal safeguards are in place or we have consent to do so.
You have the right to be provided with transparent and clear information about the personal data we hold about you and how we use it. You also have the right to request access to that information, request changes to be made where it is incorrect or incomplete, request for it to be deleted or blocked (if you believe we shouldn’t be processing that information, or are processing it incorrectly) and, in some circumstances, the right to request that we move, copy or transfer your personal information (where we process it based on your consent). You are also legally entitled to withdraw your consent for processing at any time. In each case we will promptly review your request in accordance with applicable law. In addition, you have the right to object to any of our processing where we do so based on our legitimate interests. If our processing relates to any direct marketing or profiling, we will stop processing at your request (providing that in relation to profiling we are able to identify you from the data we hold). If you object to targeted advertising, we encourage you to revisit your browsing choices and decline cookies or change your browser settings (please refer to section 4 above). In all other cases, where processing is based on our legitimate interests, if you raise an objection we will stop processing your personal data unless very exceptional circumstances apply (in which case we will inform you of this).
Please do let us know if any of your information relevant to your application changes for any reason so that we may maintain accurate application records. To make enquiries, exercise any of your rights set out in this Privacy Policy and/or make a complaint please contact us, our contact details our set out below. 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] By post: The Privacy Manager Fundamental Media Limited 31-41 Worship Street London EC2A 2DY