MIROMA GROUP WEBSITE PRIVACY AND COOKIES POLICY
(the “Privacy and Cookies Policy”)
The Miroma Group (“we”, “us” or “our”) respects your privacy and is committed to protecting your personal data. This Privacy and Cookies Policy provides information about how we look after your personal data when you visit our websites at www.miromagroup.com or www.contentedgroup.com (the “Websites”) and tells you about your privacy rights and how to exercise these rights. Please read this Privacy and Cookies Policy carefully to understand our practices regarding your personal data.
2. PURPOSE OF THIS PRIVACY AND COOKIES POLICY
This Privacy and Cookies Policy aims to give you information on how the Miroma Group collects and processes your personal data through your use of the Websites.
The Websites are not intended for children and we do not knowingly collect data relating to children.
It is important that you read this Privacy and Cookies Policy together with any other related policies we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy and Cookies Policy supplements other notices and privacy policies, where applicable, and is not intended to override them.
3. DATA CONTROLLER
This Privacy and Cookies Policy is made on behalf of the Miroma Group. For the purposes of the Websites and the Privacy and Cookies Policy, the Miroma Group includes the following companies together:
• Fold 7 Limited, company number: 04001759;
• Hyperactive London Limited, company number: 10305575;
• Miroma International Limited trading as Miroma Outcomes, company number: 04462686;
• New Stance Limited, company number: 10886931;
• The Contented Digital Media Company Limited, company number: 08333466;
• Twelve A.M. Media Limited, company number: 10350204;
• Way to Blue Ltd, company number: 03872642; and
• Attentive, operating as a separate trading arm of Miroma International Limited. Please refer to clause 21 for further related terms.
The above companies are joint controllers and are jointly responsible for the Websites and the processing of your personal data.
If you have any questions or concerns regarding the Privacy and Cookies Policy, or to update or change your personal information, please contact us by email at firstname.lastname@example.org. We will respond to you as soon as reasonably possible.
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, so please contact us in the first instance.
4. CHANGES TO THE PRIVACY AND COOKIES POLICY AND YOUR DUTY TO INFORM US OF CHANGES
We keep our Privacy and Cookies Policy under regular review. If we make any substantial changes in the way we use your personal data, we will post a notice on the Websites to inform you of the change.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
5. THIRD-PARTY LINKS
Our Websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies. When you leave our Websites, we encourage you to read the privacy and cookies policies of every other website you visit.
6. THE DATA WE COLLECT ABOUT YOU
When browsing the Websites, our web server collects logs which may identify the IP address assigned to your device or internet service provider. We also use third party products, including Google Analytics, to collect information about how you view the Websites, which may include your IP address. We may also collect and store other personal data from you, as detailed below.
Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect from you, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data includes first name, last name, title, date of birth and gender;
• Contact Data includes home address, email address and telephone number;
• Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to access the Websites;
• Usage Data includes information about how you use the Websites; and
We also collect, use and share aggregated data such as statistical or demographic data. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can identify you, we treat the combined data as personal data which will be used in accordance with this Privacy and Cookies Policy.
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
7. IF YOU FAIL TO PROVIDE PERSONAL DATA
In the event that we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.
8. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
• Direct interactions. You may give us your Identity Data and Contact Data by filling in forms or by corresponding with us by phone, email or otherwise. This includes personal data you provide when you request marketing to be sent to you, give us feedback, apply for a job vacancy or otherwise contact us.
• Automated technologies or interactions. As you interact with the Websites, we will automatically collect Technical Data about your equipment and browsing actions. We collect this personal data by using cookies, server logs and other similar technologies. Please see the below section on our cookies policy for further details.
• Third parties or publicly available sources. We may receive personal data about you from various third parties, such as Technical Data from analytics providers such as Google Analytics based outside the EU and Identity Data and Contact Data from publicly available sources such as Companies House.
9. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• where we need to perform the contract we are about to enter into or have entered into with you;
• where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and
• where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data.
10. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Type of data
Lawful basis for processing including basis of legitimate interest
To manage our relationship with you, which may include notifying you about changes to our Terms or Privacy and Cookies Policy or contacting you in relation to an application for a job vacancy submitted through the Websites.
(a) Necessary to comply with a legal obligation
(b) Necessary for our legitimate interests (to keep our records updated and to respond to job applicants)
To administer and protect our business and our Websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To use data analytics to improve the Websites, marketing and functionality experiences
Necessary for our legitimate interests (to keep the Websites updated and relevant, to develop our business and to inform our marketing strategy)
11. CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to receive an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for a purpose unrelated to the purpose it was collected for, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
12. DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. We may also seek to acquire other businesses or merge with them. If a change such as this happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy and Cookies Policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
13. INTERNATIONAL TRANSFERS
We may share your personal data within the companies under the common ownership of the Miroma Group. This may involve transferring your data outside the European Economic Area (EEA).
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
14. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
15. DATA RETENTION
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means and any other applicable legal requirements.
In some circumstances you can ask us to delete your data; please see below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
16. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You can find out about these by visiting the ICO website at www.ico.org.uk. You have the right to:
• Request access to your personal data: this is commonly known as a ‘data subject access request’. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data we hold about you: this enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data: this enables you to ask us to delete personal data where there is no good reason for us continuing to process it or where you have successfully exercised your right to object to our processing option where we may have processed your information unlawfully. Note, however, that we may not be able to comply with your request of erasure for specific legal reasons which will be notified to you at the time of your request.
• Object to processing of your personal data: where we are relying on a legitimate interest (or those of a third party) and there is something about your specific situation which allows you to object to processing as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data; this enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party; we will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data; however, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
17. NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
18. COOKIES POLICY
What are cookies? We may use information obtained from cookies or similar technology. Cookies are text files containing small amounts of information which we download onto your device when you visit the Websites. The cookies save onto your device and track, save and store information about your interaction and use of the Websites. We can recognise these cookies on subsequent visits.
Sometimes a cookie resides on your device for just the single time you’re visiting our Websites; this is called a session cookie. Sometimes a cookie remains on your device until deleted or it expires automatically; this is called a persistent cookie. Both types of cookies are used on our Websites.
For more information on cookies, including how to see what cookies have been set and how to manage and block cookies, visit: http://www.aboutcookies.org.uk/
19. WHAT WE MAY NEED FROM YOU
We may need to request specific information from you in order for us to confirm your identity and ensure your 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.
20. TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally, it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
21. ADDITIONAL TERMS FOR ATTENTIVE
Types of information we collection through our services:
When you view and interact with sites and with advertisements where our services are utilised, we may collect through our services information regarding your browsing, usage and interactions. We may also collect information that identifies browsers and devices we have interacted with previously. Such information collected through our services may include the type of Internet browser, browser language, and operating system you use, your device’s Internet protocol address (“IP address”), unique identifiers available at or pertaining to your device, connection type (wired or Wi-Fi), region where your device is located, network to which your device is connected, longitude/latitude of a (mobile) device, mobile carrier (if available), the site and page you came from before, and visited after, viewing an advertisement, and information related to the site and page you are viewing (i.e., in order to ascertain your interests). Devices include computers, mobile phones, tablets, e-readers, or other digital devices capable of maintaining an Internet connection.
We do not collect users’ names, mailing addresses, phone numbers, email addresses or similar personally identifiable information through our services.
We may also receive information from other companies, including our clients, that is collected outside our services and is provided to us for use in connection with the services. We may integrate that information with information collected through our services.
How we collect information through our services:
An advertising ID is an alphanumeric identifier made available by a platform or operating system (such as Apple iOS or Google Android) that allows application developers and third parties to recognize a particular device in an application environment and remember User Information (defined below) and other information.
A pixel is a line of code that is used by a site or third party to assign online activities to a device or browser. The use of a pixel allows us to record, for example, that a device or browser has visited a particular site or page. Additional information from an earlier period or interaction, which may include User Information intended to provide users with more useful and relevant online advertising, may also be associated with such device or browser.
We may collect and utilize information about users and activities across different sites, and associate it across applicable devices and browsers that we have reasonably linked to the same user. We may also utilize information that we receive from other companies, and associate it with information we collect and across applicable devices and browsers that we have reasonably linked to the same user. These practices are intended to help ensure that online users receive the most useful and relevant ads regardless of device or browser.
Disclosure of information to third parties:
We may also disclose the information we collect to third parties, including law enforcement, when we reasonably believe we are obligated to do so by law, and in order to investigate, prevent, or take action regarding suspected or actual prohibited activities, including, but not limited to, fraud and situations involving potential threats to the physical safety of any person.
You may opt out of Attentive Interest-Based Advertising through several mechanisms.
Attentive does not drop cookies, but uses DSPs that do so. You may choose not to receive customized third-party advertisements via Attentive’s DSP targeting cookies on the browser you are using by clicking below, in which case those third-party targeting cookies will be replaced with an “opt-out” cookie, and the Interest-Based Advertising data previously collected or received in association with the replaced third-party targeting cookie will not be used for Interest-Based Advertising on any other device or browser that we have reasonably linked to the browser where the information was collected. In addition, if we have actual knowledge that another device or browser is linked to the opted-out browser, that other device or browser will also be opted out from receiving Interest-Based Advertising via Attentive. Opt-out links to Attentive used DSPs are below.
If you buy a new device, upgrade or change web browsers or delete this opt-out cookie, you will need to perform the opt-out process again. In order for the opt-out process to work, your browser must be set to accept third-party cookies.
In browser environments, you may also refuse or remove cookies from both Attentive and other service providers via the following methods:
• You may adjust your browser settings to refuse or remove cookies, which would result in the elimination of Interest-Based Advertising via cookies from Attentive and from other providers in addition to Attentive. However, by doing so, you may not be able to use certain features on certain web sites you visit or take full advantage of all web site offerings and Interest-Based Advertising. You may refuse or remove cookies by following the directions provided in your browser settings. Further information about cookies is available at www.aboutcookies.org, www.youronlinechoices.com and http://www.aboutads.info/consumers#cookies.
• You may adjust the cookie settings at the level of the web site owner where you granted us your consent to our cookie usage, to the extent made available by the cookie settings deployed by the applicable web site owner.
• You may simply opt out of all Interest-Based Advertising at the following sites:
o www.youronlinechoices.com (by clicking the “Your ad choices” link after selecting your country)
In mobile app environments, you may opt out of Interest-Based Advertising from just Attentive DSPs or from both Attentive DSPs and other service providers via the following methods:
• You may select “Limit Ad Tracking” via your device settings, which will result in the elimination of Interest-Based Advertising via the applicable advertising ID from Attentive and from other providers in addition to Attentive.
• You may opt out of Interest-Based Advertising via the applicable advertising ID from Attentive DSPs and/or other providers via the AppChoices app. Please note that, in order for the AppChoices app to function properly, your “Limit Ad Tracking” device setting must not be selected. Interest-Based Advertising data previously collected or received in association with the replaced advertising ID will not be used via Attentive DSPs for Interest-Based Advertising on any other device or browser that we have reasonably linked to the mobile app environment where the information was collected. In addition, if we have actual knowledge that another device or browser is linked to the opted-out mobile app environment, that other device or browser will also be opted out from receiving Interest-Based Advertising via Attentive DSPs. Additional information regarding the AppChoices app is available at http://youradchoices.com/appchoices.
Additional information regarding user choice in application environments is available at www.networkadvertising.org/mobile-choices.