Welcome to our privacy notice. ALL RESPONSE MEDIA LIMITED respects
your privacy and is committed to protecting your personal data. This
privacy policy will inform you as to how we look after your personal
data and tell you about your privacy rights and how the law protects
you. Please use the Glossary to understand the meaning of some of the
terms used in this privacy policy. Any questions regarding this Policy
and our privacy practices should be sent by email to
contact@refreshyourlives.com
Address
Sutton Yard
65 Goswell Road
London
EC1V 7EN
ALL RESPONSE MEDIA LIMITED is the controller and responsible for
your personal data (collectively referred to as "ALL RESPONSE MEDIA LIMITED", "we", "us"
or "our" in this privacy notice) and our representative in the EU
Havas SA.
You have the right to make a complaint at any time to the UK
Information Commissioner’s Office or in respect of European Resident
personal data the French Data Protection Authority
(https://www.cnil.fr/en/home). We would, however, appreciate the
chance to deal with your concerns before you approach either of these
organisations so please contact us in the first instance by sending an
email to data.protectionuk@havas.com
Personal data, or personal information, 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, use, store and transfer different kinds of personal
data about you which we have grouped together follows:
Where 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 (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including
through:
We may collect, use, store and transfer different kinds of personal
data about you which we have grouped together follows:
ALL RESPONSE MEDIA LIMITED will observe the following principles when processing your
personal information:
We have set out below, in a table format, a description of all the
ways we may 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.
Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
---|---|---|
To manage our relationship with you which will include:
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To enable you to partake in a competition or complete a survey |
|
|
|
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To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
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To use data analytics to improve our website, products/services, customer relationships and experiences |
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Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
To make suggestions and recommendations to you about goods or services that may be of interest to you |
|
|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
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 get an explanation as to how the processing
for the new purpose is compatible with the original purpose, please
contact us by sending an email to data.protectionuk@havas.com
If we need to use your personal data for an unrelated purpose, we will
notify you and we will explain the legal basis which allows us to do
so.
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.
We share your personal data within the ALL RESPONSE MEDIA LIMITED Group. This will
involve transferring your data outside the UK and/or the European
Economic Area (EEA).
Many of our external third parties are based outside the UK and/or the
European Economic Area (EEA) so their processing of your personal data
will involve a transfer of data outside the UK and/or the EEA.
Whenever we transfer your personal data out of the UK and/or the EEA,
we ensure a similar degree of protection is afforded to it by ensuring
at least one of the following safeguards is implemented:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK and/or the EEA.
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 an applicable data protection law requires us to do so.
ALL RESPONSE MEDIA LIMITED websites or services may provide links to third-party
applications, products, services, or websites for your convenience and
information. If you access those links, you will leave the ALL RESPONSE MEDIA LIMITED
website. ALL RESPONSE MEDIA LIMITED does not control those third-party websites or their
privacy practices, which may differ from ALL RESPONSE MEDIA LIMITED practices. We do not
endorse or make any representations about third-party websites. The
personal data you choose to provide to or that is collected by these
third parties are not covered by the ALL RESPONSE MEDIA LIMITED Data Protection Policy.
We encourage you to review the privacy policy of any website you
interact with before allowing the collection and use of your personal
data.
We may also provide social media links that enable you to share data
with your social networks and to interact with ALL RESPONSE MEDIA LIMITED on various
social media sites. Your use of these links may result in the
collection or sharing of data about you, depending on the feature. We
encourage you to review the privacy policies and settings on the
social media sites with which you interact to make sure you understand
the data that may be collected, used, and shared by those sites.
If you post, comment, indicate interest, or share personal data,
including photographs, to any public forum, social network, blog, or
other such forum, please be aware that any personal data you submit
can be read, viewed, collected, or used by other users of these
forums, and could be used to contact you, send you unsolicited
messages, or for purposes that neither you nor ALL RESPONSE MEDIA LIMITED have control
over. ALL RESPONSE MEDIA LIMITED is not responsible for the personal data you choose to
submit in these forums.
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to
fulfil the purposes we collected it for, including for the purposes of
satisfying any legal, accounting, or reporting requirements.
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 the
applicable legal requirements.
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
If you wish to exercise any of the rights set out above, please
contact us by sending an email to data.protectionuk@havas.com
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 may refuse to comply with your request in these
circumstances.
What we may need from you
We may need to request specific information from you to help us
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. Time limit to respond
We try to respond to all legitimate requests within one month.
Occasionally it may 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.
CHANGES TO THIS POLICY
ALL RESPONSE MEDIA LIMITED reserves the right to modify this privacy statement as
needed, for example, to comply with changes in laws, regulations,
ALL RESPONSE MEDIA LIMITED practices and procedures, or requirements imposed by data
protection authorities.
Last update: July 2021
Legitimate Interest means the interest of our business in
conducting and managing our business to enable us to give you the best
service/product and the best and most secure experience. We make sure
we consider and balance any potential impact on you (both positive and
negative) and your rights before we process your personal data for our
legitimate interests. We do not use your personal data for activities
where our interests are overridden by the impact on you (unless we
have your consent or are otherwise required or permitted by law). You
can obtain further information about how we assess our legitimate
interests against any potential impact on you in respect of specific
activities by contacting us.
Performance of Contract Performance of Contract means
processing your data where it is necessary for the performance of a
contract to which you are a party or to take steps at your request
before entering into such a contract.
Comply with a legal or regulatory obligation Comply with a
legal or regulatory obligation means processing your personal data
where it is necessary for compliance with a legal or regulatory
obligation that we are subject to.
Other companies in the ALL RESPONSE MEDIA LIMITED Group acting as joint controllers or processors and who are based in the UK, Ireland, Canada and the UAE and provide administration or marketing services.
Service providers who act as processors or joint controllers who
provide digital marketing, advertising and/or analytics services, such
as Yahoo! and Google. For more details about those partners please
email us
Professional advisers acting as processors or joint
controllers including lawyers, bankers, auditors and insurers based
who provide consultancy, banking, legal, insurance and accounting
services.
HM Revenue & Customs, regulators and other authorities acting as
processors or joint controllers based in the United Kingdom or Jersey
who require reporting of processing activities in certain
circumstances.