We at Hoops Media Limited, 28 Keston Avenue, New Haw, Surrey, KT15 3EF, Company number 7120604 ("we" or "our" or "us"), want to make sure that all the personal information we have collected about you, is safe and secure whether we collect it through our website at Retrolink.co.uk ("Site") or from other sources.
This Policy set outs our commitments to you, in compliance with and beyond the General Data Protection Regulation (commonly known as the GDPR) and explains how we collect, store and use your personal information.
We have not appointed a Data Protection Officer to oversee our compliance with data protection laws as we not required to do so, but our Data Protection Compliance Manager has overall responsibility for data protection compliance in our organisation. If you have any questions about this Policy or what we do with your personal information, their contact details are set out in the "Contact" section below.
2. The difference between Data Controllers and Data Processors
A data controller is a person who controls how personal information is processed and used. A data processor is a person who processes and uses personal information in accordance with the instructions of a third party, i.e. the data controller.
This distinction is important. You have certain rights in relation to your personal information, for example the right to be provided with the personal information held about you and details of its use and the right to have certain of your personal information either erased or anonymised, commonly referred to as the right to be forgotten (see below to see what rights you have). These rights can generally only be exercised against a data controller of your information.
In most cases we will not be a data controller of your personal information. In any case where we are not a data controller this means that you cannot exercise these rights against us directly (i.e. where we only act as a data processor), but you can do so against the data controller (i.e. the person who controls how we process the personal information). In these cases we will endeavour to inform you who is the data controller of your personal information so that you can direct any such requests to them.
Also it is only a data controller that will provide you with a privacy notice about your personal information, so where we process your personal information as a data controller we will provide you with a privacy notice. Where we process your personal information as a data processor for a third party, that third party should provide you with a privacy notice which will set out details regarding the processing of your personal information, which should also include the processing to be carried out by us on their behalf.
3. Explaining The Legal basis which we rely on
Consent - In specific situations, we can collect and process your data with your consent. For example, when you tick a box and sign-up to receive our email newsletters. When collecting your personal data, we'll always explain what data is necessary in connection with a particular service.
Legitimate interest - In specific situations, we will require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially affect your rights, freedom or interests.
Legal compliance - If required by law, we may need to collect and process your data. For example, we can pass on details of people involved in fraud or other criminal activity to law enforcement officials.
4. What information do we collect?
We may collect, store and use personal information that includes, but is not limited to, anonymised IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views, website navigation and details. This may include:
(a) information about your computer and about your visits to and use of this website; (b) information relating to any transactions carried out between you and us on or in relation to this website, including information relating to any purchases you make of our goods or services; (c) information that you provide to us for the purpose of registering with us; (d) information that you provide to us for the purpose of subscribing to our website services, email notifications and/or newsletters; (e) any other information that you choose to send to us; and (f) other information.
A cookie consists of a piece of text sent by a web server to a web browser, and stored by the browser.
6. Using your personal information
We may use your personal information to:
(a) administer the website; (b) improve your browsing experience by personalising the website; (c) enable your use of the services available on the website; (d) send you email notifications which you have specifically requested; (e) send to you our newsletter where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications); (f) provide third parties with statistical information about our users (this information will not be used to identify any individual user); (g) and deal with enquiries and complaints made by or about you relating to the website.
Where you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the licence you grant to us.
We will not without your express consent provide your personal information to any third parties for the purpose of direct marketing.
7. Who do we share your personal information with?
Generally it is only where we need to do so in order to run our organisation (e.g. where other people process information for us). In such circumstances, we will put in place arrangements to protect your personal information. Outside of that we do not disclose your personal information unless we are required to do so by law.
If we transfer personal information about you outside the European Economic Area (EEA), we will let you know and ensure that all reasonable security measures are taken and that any third party processers will be required to process the information in accordance with information protection laws and we will notify you in your privacy notice if we are the information controller.
We do not sell, trade or rent your personal information to others.
8. How long do we hold onto your personal information?
We will only hold your information for as long as is necessary or, where you ask us to delete records, we may delete it earlier.
The duration for which we retain your personal information will differ depending on the type of information and the reason why it was collected. However, in some cases personal information may be retained on a long term basis: for example, personal information that we need to retain for legal purposes will normally be retained for at least six years in accordance with usual commercial practice and regulatory requirements.
If you have unsubscribed from our newsletter we may still store your email address for around 3 months after you unsubscribed, after which point it will be permanently deleted. If you wish, you can ask that we delete your email address before this time using the details in the "Contact" section below, but this procedure is included as part of our ongoing data maintenance plan.
In addition, we may disclose your personal information:
(a) to the extent that we are required to do so by law; (b) in connection with any legal proceedings or prospective legal proceedings; (c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk); (d) to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and (e) to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
10. International data transfers
Information which you provide may be transferred to countries (including the United States, Japan, and other countries) which do not have data protection laws equivalent to those in force in the European Economic Area.
In addition, personal information that you submit for publication on the website will be published on the internet and may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.
You expressly agree to such transfers of personal information.
11. Security of your personal information
We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
We will store all the personal information you provide on our secure (password- and firewall- protected) servers. All electronic transactions you make to or receive from us will be encrypted using SSL technology.
Of course, data transmission over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
You are responsible for keeping your password and user details confidential. We will not ask you for your password (except when you log in to the website).
12. Policy amendments
13. Third party websites
The website contains links to other websites. We are not responsible for the privacy policies or practices of third party websites and, if you submit personal information to any of those sites, your information is governed by their privacy notices. We encourage you to carefully read the privacy policies of any websites you visit.
In addition, if you linked to this Site from a third-party site, we cannot be responsible for the privacy policies and practices of the owners or operators of that third-party site and recommend that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.
Some of our links will go via affiliate marketing companies, where we might earn a commission, and they will act as a Data Processor. Details of these companies and their privacy policies can be found below:
14. Log files
In common with most websites, our Site logs various information about visitors, including anonymised internet protocol (IP) addresses, browser type, internet service provider (ISP) information, referring / exit pages and date / time stamp.
We may use this information to analyse trends, administer the Site, track your movement around the Site and gather broad demographic information.
15. Updating information
You may instruct us to provide you with any personal information we hold about you. Provision of such information will be subject to the supply of appropriate evidence of your identity (for this purpose, we will usually accept an email from the email address in question and a photocopy of a driving license or passport).
We may withhold such personal information to the extent permitted by law.
You may instruct us not to process your personal information for marketing purposes, by sending an email to us using the details in the "Contact" section below. In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt-out of the use of your personal information for marketing purposes.
Under the GDPR rules that start on 25th May 2018, all users will have the following rights:To ask for a copy of your personal information at any time.To ask us to correct, delete or update your personal information.To send your personal information to you or another organisation.To object to automated decision making.Where you've given us your consent to use your personal information in a particular manner, you also have the right to withdraw this consent at any time.
To exercise any of your rights, or if you have any questions relating to your rights, please contact us by using the details set out in the "Contact" section below. You can also unsubscribe from any direct marketing by clicking on the unsubscribe link in the marketing messages we send to you.
If you are unhappy with the way we are using your personal information you can complain to the UK Information Commissioner's Office or your local data protection regulator. More information about your legal rights can be found on the Information Commissioner's website at https://ico.org.uk/for-the-public/. However, we are here to help and would encourage you to contact us to resolve your complaint first.
17. Data controller
The data controller responsible in respect of the information collected on this website is Hoops Media Limited and our Data Protection Compliance Officer can be contacted through the details in the Contact section directly above.
Version Date: 24th May 2018