1.1 Important information and who we are
At Picnic Media Limited (“we”, “us”, or “our”) we are committed to protecting and respectingyour privacy and Personal Data in compliance with the law and guidelines of the EU GeneralData Protection Regulation (“GDPR”).
- The individuals from which we may gather and use data can include;I. CustomersII. SuppliersIII. Business contactsIV. Employees/Staff MembersV. Third parties connected to your customers
and any other people that the organisation has a relationship with or may need to contact.
Full name: Charlotte WoottonEmail address: Privacy@picnic-media.comPostal address: 60 Grays Inn Road, London, WC1X 8AQ, United Kingdom
You have the right to make a complaint at any time to the Information Commissioner’s Office(ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would,however, appreciate the chance to deal with your concerns before you approach the ICO soplease contact us in the first instance.
1.3 Processing Data on Behalf of a Controller and Processors’ responsibility to you
In discharging our responsibilities as a Data Controller we have employees who will deal withyour data on our behalf (known as “Processors”). Therefore, the responsibilities describedbelow may be assigned to an individual, or may be taken to apply to the organisation as awhole. The Data Controller and our Processors have the following responsibilities:
- Ensure that all processing of Personal Data is governed by one of the legal bases laidout in the GDPR (see 2.2 below for more information on those bases);
- Ensure that Processors authorised to process Personal Data have committedthemselves to confidentiality or are under an appropriate statutory obligation ofconfidentiality;
- Implement appropriate technical and organisational measures to ensure a level ofsecurity appropriate to the risk associated with the processing of Personal Data;
- Obtain the prior specific or general authorisation of the Controller before engaginganother Processor;
- Assist the Controller in the fulfilment of the Controller's obligation to respond torequests for exercising the data subject's rights;
- Make available to the Controller all information necessary to demonstrate compliancewith the obligations laid down in the GDPR and allow for and contribute to audits,including inspections, conducted by the Controller or another auditor mandated by theController;
- Maintain a record of all categories of processing activities carried out on behalf of aController;
- Cooperate, on request, with the supervisory authority in the performance of its tasks;
- Ensure that any person acting under the authority of the Processor who has access toPersonal Data does not process Personal Data except on instructions from theController;
- Notify the Controller without undue delay after becoming aware of a Personal DataBreach;
- Designate a data protection officer where required by the GDPR, publish their detailsand communicate them to the supervisory authority; and
- Support the data protection officer in performing their tasks by providing resourcesnecessary to carry out those tasks and access to Personal Data and processingoperations, and to maintain their expert knowledge;
LEGAL BASIS FOR DATA COLLECTION
“Personal Data” means any information about an individual from which that person can beidentified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of Personal Data about you which wehave grouped together below. Not all of the following types of data will necessarily becollected from you but this is the full scope of data that we collect and when we collect it from you:
- Contact Data: This is data relating to your phone number, addresses, email addresses,phone numbers.
- Marketing and Communications Data: This is your preferences in receiving marketinginformation and other information from us.
- Customer Support Data: This includes feedback and survey responses.
- Usage Data: Information about how you use our website, products and services.
We do not collect any Special Categories of Personal Data about you (this includes detailsabout your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation,political opinions, trade union membership, information about your health, and genetic andbiometric data). Nor do we collect any information about criminal convictions and offences.
2.2 The Legal Basis for Collecting That Data
There are a number of justifiable reasons under the GDPR that allow the collection and processing of Personal Data. The main avenues we rely on are:
- “Consent”: Certain situations allow us to collect your Personal Data, such as when youtick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’ toa service.
- “Contractual Obligations”: We may require certain information from you in order tofulfil our contractual obligations and provide you with the promised service.
- “Legal Compliance”: We’re required by law to collect and process certain types of data,such as fraudulent activity or other illegal actions.
- “Legitimate Interest”: We might need to collect certain information from you to be ableto meet our legitimate interests - this covers aspects that can be reasonably expected aspart of running our business, that will not have a material impact on your rights,freedom or interests. Examples could be your address so that we know where todeliver something to, or your name, so that we have a record of who to contact movingforwards.
HOW WE USE YOUR PERSONAL DATA
3.1 Our Uses
We will only use your Personal Data when the law allows us to. Set out below is a tablecontaining the different types of Personal Data we collect and the lawful basis for processingthat data. Please refer to section 2.2 for more information on the lawful basis listed in thetable below.
Examples provided in the table below are indicative in nature and the purposes for which weuse your data may be broader than described but we will never process your data without alegal basis for doing so and it is for a related purpose. For further inquiries please contact ourData Protection Officer.
3.2 Marketing and Content Updates
You will receive marketing and new content communications from us if you have created anaccount and chosen to opt into receiving those communications. From time to time we maymake suggestions and recommendations to you about goods or services that may be ofinterest to you.
3.3 Change of Purpose
We will only use your Personal Data for the purposes for which we collected it, unless wereasonably consider that we need to use it for another reason and that reason is compatiblewith the original purpose. If you wish to get an explanation as to how the processing for thenew purpose is compatible with the original purpose, please contact our Data ProtectionOfficer.
If we need to use your Personal Data for an unrelated purpose, we will notify you and we willexplain the legal basis which allows us to do so.
Please note that we may process your Personal Data without your knowledge or consent, incompliance with the above rules, where this is required or permitted by law.
YOUR RIGHTS AND HOW YOU ARE PROTECTED BY US
4.1 How Does Picnic Media Limited Protect Customers' Personal Data?
We are concerned with keeping your data secure and protecting it from inappropriatedisclosure. Any Personal Data collected by us is only accessible by a limited number ofemployees who have special access rights to such systems and are bound by obligations ofconfidentiality. If and when we use subcontractors to store your data, we will not relinquishcontrol of your Personal Data or expose it to security risks that would not have arisen had thedata remained in our possession. However, unfortunately, no transmission of data over theinternet is guaranteed to be completely secure. It may be possible for third parties not underthe control of Picnic Media Limited to intercept or access transmissions or privatecommunications unlawfully. While we strive to protect your Personal Data, we cannot ensureor warrant the security of any Personal Data you transmit to us. Any such transmission is doneat your own risk. If you believe that your interaction with us is no longer secure, please contactus.
4.2 Opting Out Of Marketing Promotions
You can ask us to stop sending you marketing messages at any time by You can ask us to stop sending you marketing messages at any time by clicking unsubscribe on your email or messaging email@example.com.
Where you opt-out of receiving these marketing messages, we will continue to retain otherPersonal Data provided to us as a result of interactions with us not related to your marketing preferences.
4.3 How to Request your Data and the Process for Obtaining it
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, we could refuse to comply with your request.
We may need to request specific information from you to help us confirm your identity and ensure you have the right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
YOUR DATA AND THIRD PARTIES
5.1 Will We Share Your Data With Third Parties?
We may also share Personal Data with interested parties in the event that Picnic Media Limited anticipates a change in control or the acquisition of all or part of our business or assets or with interested parties in connection with the licensing of our technology.
6.1 HOW LONG WILL WE RETAIN YOUR DATA FOR?
We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your Personal Data for a longer period than usual in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.
7.1 INTERNATIONAL TRANSFER OF DATA
Your information may be stored and processed in the US or other countries or jurisdictions outside the US where Picnic Media Limited has facilities. We are currently storing data in the EU and so, by using Picnic Media Limited, you are permitting and consenting to the transfer of information, including Personal Data, outside of the US.
8.1 NOTIFICATION OF CHANGES AND ACCEPTANCE OF POLICY
All uses of the word "including" mean "including but not limited to" and the enumerated examples are not intended to in any way limit the term which they serve to illustrate. Any email addresses set out in this policy may be used solely for the purpose for which they are stated to be provided, and any unrelated correspondence will be ignored. Unless otherwise required by law, we reserve the right to not respond to emails, even if they relate to a legitimate subject matter for which we have provided an email address. As a matter of common sense, you are more likely to get a reply if your request or question is polite, reasonable and there is no relatively obvious other way to deal with or answer your concern or question (e.g. FAQs, other areas of our website, etc.).
Our staff are not authorised to contract on behalf of Picnic Media Limited, waive rights or make
representations (whether contractual or otherwise). If anything contained in an email from a PicnicMedia Limited address contradicts anything in this policy, our terms or any official public announcement on our website, or is inconsistent with or amounts to a waiver of any Picnic MediaLimited rights, the email content will be read down to grant precedence to the latter. The only exception to this is genuine correspondence expressed to be from the Picnic Media Limited legal department.